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Settlement access is provided through DNB as the national central bank within the Eurosystem: institutions meeting access criteria open T2 RTGS DCAs, T2S DCAs and TIPS DCAs and sign the Conditions for TARGET-NL. SEPA clearing flows through pan-European CSMs (historically Equens, with DNB providing STEP2 access) settling in T2. DNB manages collateral pools and the Correspondent Central Banking Model for cross-border collateral, and authorises settlement agents. De-risking — terminating relationships with whole customer groups without individual assessment under the Wwft — is a recognised DNB and FATF concern, with associated access-to-finance and discrimination follow-up.
DNB defines de-risking as excluding or terminating relationships with whole customer groups for integrity reasons without individual risk assessment — consistent with the FATF definition. The risk-based Wwft approach raises administrative costs and reduces financial access for some customers, with associated access-to-finance and discrimination follow-up. De-risking intersects W11 and FIM and is routed for awareness.
Outlook
W12 is established and confirmed. The standing watch is non-bank PSP access to DCAs under the access criteria, and the de-risking dynamic as a recognised supervisory concern. De-risking carries FIM cross-references that are not WPM conclusions.
Correspondent Banking, Settlement & Access
The Netherlands' instant-payments infrastructure, already six years mature, now carries two overlapping compliance obligations that define this cycle's correspondent-banking and settlement picture. First, since 9 January 2025, Dutch payment service providers have been required to use a harmonised sanctions-screening procedure for instant credit transfers, with DNB monitoring compliance including periodic reporting of sanctions-related rejection rates. This is a Confirmed, T1-sourced finding, and it applies to bank PSPs and non-bank PIs/EMIs alike engaged in instant euro transfers — the screening obligation attaches to the transaction type and currency, not to the type of institution executing it.
Second, Articles 5a-5d of the SEPA Regulation, given effect via the Instant Payments Regulation, require any PSP offering standard SEPA credit transfers to also offer instant credit transfers in euro at no higher cost than standard transfers. This obligation is verified through a mandatory Verification of Payee service applied consistently across the SEPA area. This is a Confirmed finding corroborated at T2 by the Dutch Payments Association alongside the primary T1 DNB material on the sanctions-screening mandate.
The analytical spine of this domain is the bank-versus-non-bank access asymmetry, and this cycle's findings illustrate a case where that asymmetry is narrowing rather than widening: both the sanctions-screening mandate and the mandatory instant-transfer-offering requirement apply uniformly across bank and non-bank PSPs, embedding a common compliance floor into the settlement layer itself rather than preserving differentiated treatment by institution type.
Outlook
The key marker to watch is DNB's periodic reporting on sanctions-related rejection rates for instant credit transfers, which would provide the first empirical signal of how the harmonised screening procedure is performing in practice. Continued monitoring of Verification of Payee service performance across the SEPA area will also indicate whether the mandatory instant-transfer-offering requirement is functioning smoothly for both bank and non-bank PSPs in the Dutch market.
1 earlier distinct update(s)
Correspondent Banking, Settlement & Access
ECB Decision (EU) 2025/222 established a harmonised framework for non-bank payment service providers to access Eurosystem central-bank-operated payment systems, including TARGET, adopted on 27 January 2025 and published in the Official Journal on 6 February 2025. This is a structural change to the bank-versus-non-bank access asymmetry that has historically defined correspondent banking: non-bank PIs and EMIs that previously depended on correspondent banking relationships for settlement now have a harmonised path toward direct Eurosystem access.
For Dutch non-bank payment institutions and e-money institutions, the practical significance of the decision lies in the alternative it offers to correspondent-bank dependency, though the decision establishes the framework rather than itself effecting individual firms' migration to direct access; whether and how quickly Dutch non-bank PSPs take up that path is not yet established by evidence available this cycle.
Outlook
The clearest marker of this decision's practical effect over the coming cycles is whether Dutch non-bank payment institutions or e-money institutions move toward direct Eurosystem access under the new framework, or continue to rely predominantly on correspondent banking relationships for settlement.
Sources and findings (4)
- T1https://www.dnb.nl/en/sector-information/cash-and-payment-systems/target-services-t2-t2s-tips/what-are-the-target-services/legal-documentation/retrieved
- T1https://www.dnb.nl/en/sector-information/cash-and-payment-systems/target-services-t2-t2s-tips/what-are-the-target-services/retrieved
- T1https://www.dnb.nl/en/sector-information/cash-and-payment-systems/collateral-management/retrieved
- T2https://www.nvb.nl/media/5439/undesirable-consequences-of-de-risking-for-customers-and-banks-dutch-banking-association.pdfretrieved