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Safeguarding of payment service users' funds is implemented in the Wft via PSD2/EMD2, with two mechanisms: segregation (a third-party-funds foundation or, since 2022, a quality account) or an insurance/comparable guarantee. AFM supervises conduct and information provision; DNB supervises prudential soundness; ACM oversees access and instrument charges. The quality account (kwaliteitsrekening), added by the Financial Markets Amendment Act 2022, modernises segregation but currently carries a restriction limiting it to NL-registered banks.
The quality account (kwaliteitsrekening) was added to the Wft in 2022 via the Financial Markets Amendment Act, modernising the segregation toolkit. At introduction a restriction limited quality accounts to NL-registered banks. As of June 2026 the research does not verify whether this Dutch-registered-bank restriction remains operative, and the caveat is carried explicitly: current-status verification against a 2024-2026 source is outstanding.
On conduct supervision, four authorities supervise PSD2 in NL with distinct remits: DNB on prudential matters (financial position, secure account access, risk management, authentication), the ACM on access to payment systems and accounts and on instrument charges, the AFM on information provision and customer treatment, and the Autoriteit Persoonsgegevens on personal data processing. This multi-authority conduct and access architecture is distinctive to the Netherlands.
Outlook
W1b is established and confirmed on the safeguarding mechanism and supervisory split. The principal open item is the currency of the quality-account bank restriction, which should be verified against a current source. The forthcoming PSD3/PSR and EU PSR will reshape conduct and safeguarding obligations, but on the late-2027/early-2028 horizon flagged under W1a.
Conduct, Safeguarding & Financial Promotions
The Netherlands completed a key conduct-layer milestone under the EU Instant Payments Regulation this cycle. From 9 October 2025, Dutch payment service providers are required to offer a Verification of Payee service, confirming that a payee's name matches the provided IBAN before an instant credit transfer is sent, under EU Regulation 2024/886. This anti-fraud verification mandate is designed to reduce misdirected-payment and authorised-push-payment-style fraud risk at the point of transfer initiation, and it applies across both bank-PSPs and non-bank PSPs offering instant credit transfer services in the Netherlands.
This conduct obligation builds on an earlier phase of the same regulation: since 9 January 2025, Dutch PSPs receiving instant credit transfers have been required to apply a harmonised sanctions-screening procedure rather than conducting transaction-by-transaction checks. Together, the sanctions-screening and Verification of Payee obligations represent the conduct and safeguarding dimension of the Netherlands' full instant-payments build-out, layering fraud-prevention and financial-crime controls directly into the payment-execution chain rather than treating them as separate back-office processes.
Outlook
With both the receive-side sanctions-screening obligation and the send-side Verification of Payee mandate now in force, the conduct-layer build-out under the Instant Payments Regulation is complete for the Netherlands. The next conduct-relevant development to monitor is how PSD3/PSR's eventual transposition will interact with these existing instant-payments conduct obligations for non-bank PSPs required to seek PI reauthorisation.
1 earlier distinct update(s)
Conduct, Safeguarding & Financial Promotions
The Payment Services Directive 3 and its accompanying Payment Services Regulation reached political trilogue conclusion in March 2026, producing provisional legislative texts, with formal entry into force expected in early 2027. For Dutch payment institutions and electronic-money institutions, the practical consequence flagged for that same 2027 window is a migration to a unified payment-institution-authorised-to-issue-e-money licence category, replacing the current separate payment-institution and electronic-money-institution licensing tracks. This gives non-bank payment firms operating in the Netherlands a firm, though not yet immediate, structural deadline to begin planning licence consolidation, governance changes, and safeguarding-arrangement reviews ahead of the new regime's application. No Dutch-specific conduct or financial-promotions rule change beyond this anticipated licence migration was evidenced in the research this cycle.
Outlook
With PSD3/PSR's provisional text concluded and formal entry into force expected in early 2027, Dutch non-bank payment institutions and electronic-money institutions have roughly a one-year window to prepare for migration to the unified licence category. The absence of a filed final text in this cycle means the precise safeguarding and conduct requirements attached to the new licence remain to be confirmed.
Sources and findings (4)
- T3https://advapay.eu/emoney-and-payment-institution-licensing/e-money-and-payment-institution-license-in-the-netherlands/retrieved
- T2https://www.betaalvereniging.nl/en/knowledge-base/european-legislation/safeguarding-customer-funds/retrieved
- T1https://www.dnb.nl/en/sector-information/open-book-supervision/laws-and-eu-regulations/psd2/retrieved
- T3https://www.blenheim.nl/en/blog/licence-for-payment-services-under-psd2/retrieved