Q&A Required additional own funds for payment institutions and electronic money institutions

Q&A
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Question:

Can DNB require payment institutions and electronic money institutions to hold additional own funds?

Published: 01 February 2024

Latest update: 20 October 2025

Answer:

Yes, this follows from Section 60a of the Decree on Prudential Rules for Financial Undertakings (Besluit prudentiële regels – Bpr) for payment institutions and Section 64(5) of the Bpr for electronic money institutions. DNB may impose an additional capital requirement of up to 20% on a payment institution or electronic money institution if warranted by an assessment of the following:

  • risk management processes
  • database of risk loss data
  • internal control system
  • business continuity management

DNB may find grounds to impose an additional capital requirement based on one or more of the following circumstances (among other things):

  1. The institution has implemented a significant change in its business model with an as yet unproven risk management that is not otherwise capitalised under PSD2;

  2. There is a special risk concentration inherent in the institution's business model that is not easily mitigated and not capitalised under PSD2;
  3. The institution falls outside the established risk tolerance for one or more of the four components listed above when applying the relevant supervisory methodology (currently general supervisory methodology).

The decision to impose an additional capital requirement is provided in writing and explained to the institution in a supervisory meeting, during which DNB indicates how the additional capitalisation contributes to mitigating the shortcoming identified. In the decision, DNB also specifies the conditions that the institution must meet for the additional own funds requirement to be rescinded. If the institution meets these conditions, DNB will take a decision to rescind the additional capital requirement.

DISCLAIMER

Q&As provide further insight into our policy practice by setting out our interpretation of statutory supervisory rules. Institutions subject to our supervision may choose to comply with the laws and regulations in other ways, however. If they do so, they must be able to demonstrate that their interpretation complies with the applicable laws and regulations and substantiate this. To read more about the status of our policy statements, go to the Explanatory guide to DNB's policy statements on Open Book on Supervision.

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