For international payment institutions seeking to gain a foothold in Europe, the Netherlands is a logical choice: a country with a clear regulatory framework, a pragmatic approach, and a supervisor (DNB): known for being critical yet approachable. A good plan starts with a crucial first step: obtaining a licence as a payment service provider. However, entering the Dutch market requires specific expertise.
Projective Group was approached to support the licensing process in the Netherlands for a US-based payment institution. “They had appointed someone responsible for the European rollout who knew me from a previous project,” says Frenkel, Risk and Compliance consultant at Projective Group. “He immediately said: ‘You know how this works. We want to do this with you.’”
You know how this works. We want to do this with you.
The first step was to sharpen the vision for their European landing, and specifically their presence in the Netherlands: how to set up a new entity in a way that meets European requirements, while still aligning efficiently with the existing US infrastructure.
“We started with sessions to outline the contours of the Dutch organisation: what is the minimum staffing required, which functions must be in place, how do you manage outsourcing within the group?” says Frenkel. “For them, it was important to continue using as much of their US processes and IT infrastructure as possible. These are the types of discussions you really need to have upfront.”
The approach consisted of several parallel workstreams:
In a project like this, the licensing aspect is only one side of the story. According to Frenkel, the complexity lay mainly in the practical setup and the translation into a well-managed Dutch entity. Especially given the fact that the company was a US player already operating with existing infrastructure, it was essential to define what needed to be set up locally and what could remain centralised. It was also necessary to continuously demonstrate that the Dutch entity could operate independently and in a controlled manner, even when facing setbacks.
“You can outsource everything – except your responsibility,” says Frenkel. “As the licence holder, you must be able to prove that you meet all requirements, even if parts of the operation are carried out elsewhere in the group.”
You can outsource everything – except your responsibility
Another challenge arose halfway through the process: the implementation of DORA. Although the project was already well underway, the new regulation meant that documentation had to be revised and expanded.
“We had submitted everything, and then DORA came into effect. Four days later, we received a letter from DNB: ‘Show us how you comply with this.’ At that point, you have to adapt quickly. You will always face surprises.”
After approximately four months of preparation, the application was submitted. This initiated a period of intensive interaction with DNB. The case officer at the supervisory authority referred parts of the file to various internal departments – from integrity to IT and outsourcing – each of which submitted detailed questions from their area of expertise.
“You get one round of questions, then silence, and then another fifteen questions,” says Frenkel. “In those moments, you need to move very quickly with your client, so we can respond within one or two weeks. Because as long as there are outstanding questions, the review period is paused.”
According to Frenkel, the average lead time for obtaining a licence for a payment institution is now around fourteen months. “That’s why it’s wiser to take a bit more time upfront and submit a thorough application, rather than rushing and later facing additional questions and delays. In the end, it saves time.”
It’s wiser to take a bit more time upfront and submit a thorough application, than rushing and facing delays
Projective Group remained the point of contact for both the client and the supervisor throughout the entire process. The direct lines with DNB helped ensure clarity on expectations and interpretations.
“Our experience with similar licensing processes means we understand how DNB thinks. That is a huge advantage, especially for parties from outside Europe who are less familiar with this regulatory style.”
After a review period of about fourteen months, the licence was granted. This meant the institution could formally start offering payment services in Europe.
But that was not the end of the collaboration. In the initial phase after licensing, Projective Group continued to support the further development of the Dutch organisation.
“We often take on responsibilities during that phase, so the client can focus on growth,” says Frenkel. “For instance, during the start-up phase, we might temporarily take on the compliance or risk management function. In doing so, we often deploy Ruler, which gives the client access to all relevant laws and regulations and alerts them to any changes or new legislation. Since they do not yet have the time or resources to monitor everything continuously, Ruler is a helpful tool to bridge that gap.”
The aim is always for the client to eventually build their own internal risk and compliance functions. Projective Group stays involved for as long as needed and steps back once the organisation has grown sufficiently to operate independently.
A licence application is far more than just paperwork. It is a complex interplay of strategy, structure, risk, and supervision – and it demands knowledge, experience, and speed. In this project, Projective Group brought all those elements together: from business case to policy, from outsourcing to DORA, from strategy to execution. The result: a licence, a solid foundation, and an organisation ready to grow in Europe.
