Regulatory AlertsNetherlands: lending & credit regulation
RegulatedLending regulated under Wft; AFM supervises conduct, DNB prudential; BNPL now licensed
- Lead regulator
- AFM (Autoriteit Financiele Markten)
- Also involved
- DNB (prudential) · DPA (data) · CB (payment services)
- Core law
- Financial Supervision Act (Wet op het financieel toezicht, Wft)
- Entry capital
- €730,000 (Credit Institution)
- Approval timeline
- 6-12 months
- Customer assets
- Segregated or insured
- Data protection
- GDPR · DPA
- Sandbox
- Yes - AFM Regulatory Sandbox
Consumer and SME lending are regulated under the Wft. The AFM supervises market conduct, while the DNB handles prudential supervision. BNPL providers are now subject to licensing. Credit bureaus require registration. Debt collection is regulated under the Wft and specific collection laws.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Consumer lending | LicenceCredit Institution / Financial Undertaking Requires Wft authorization for consumer credit provision. | €730,000 | 6-12 months | AFM / DNB |
| SME / commercial lending | LicenceCredit Institution / Financial Undertaking Same regime as consumer credit under Wft. | €730,000 | 6-12 months | AFM / DNB |
| Microfinance | LicenceCredit Institution / Financial Undertaking No specific microfinance license; falls under general credit. | €730,000 | 6-12 months | AFM / DNB |
| Buy-now-pay-later | LicenceCredit Institution / Financial Undertaking[1] AFM now licenses BNPL providers as credit institutions. | €730,000 | 6-12 months | AFM |
| P2P lending platform | LicenceInvestment Firm / Credit Institution Platform acting as credit intermediary or lender requires license. | €730,000 | 6-12 months | AFM / DNB |
| Credit bureau / scoring | RegistrationCredit Bureau Registration Credit bureaus must register with the AFM. | — | — | AFM |
| Debt collection | LicenceFinancial Undertaking[2] Debt collection is regulated under Wft; specific conduct rules apply. | — | — | AFM |
New — what changed recently
- 2025-07-01AFM BNPL Market Update 2025 — AFM confirmed BNPL providers are now subject to licensing and supervision as credit institutions.[1]
- 2024-07-03AFM Change Management Principles — New principles for credit providers on IT and operational change management to prevent over-indebtedness.[3]
- 2024-08-29AFM Guidance on Tailored Mortgage Advice — Guidance issued allowing tailored advice for energy-saving measures, reducing information requirements.[4]
Market-entry checklist
- 1Obtain Wft AuthorizationApply for authorization as a credit institution or financial undertaking with AFM and DNB.
- 2Meet Capital RequirementsEnsure minimum capital of €730,000 for credit institutions or higher if required by DNB.
- 3Register as Credit BureauIf operating a credit bureau, register with the AFM as required by law.
- 4Implement AML/KYCEstablish robust anti-money laundering and know-your-customer procedures compliant with Wft.
- 5Adopt AFM Conduct RulesEnsure all lending practices comply with AFM guidelines on fair treatment and affordability.