Licensing and intellectual property
Dutch Trust Office Licence Application to DNB
For groups, advisers and founders planning a Dutch trust office
Settle whether your model needs a licence, then file a complete application with the people and the entity in place.
- Licensing authority: DNB, under the Wtt 2018
- Statutory decision period: 13 weeks, stopped by each request
- DNB application fee 2026: EUR 6,800, not refunded
- Two daily policymakers working from the Netherlands
Licence applications for trust office businesses
Anyone seated in the Netherlands who provides trust services professionally or commercially needs a licence from De Nederlandsche Bank (DNB) under the Wet toezicht trustkantoren 2018 (Wtt 2018, the Act on the Supervision of Trust Offices); one service is enough. DNB grants the licence, supervises trust offices and keeps their public register.
We check whether your model needs a licence, coordinate the applicant entity, build the file and support you through DNB's questions, as for a Dutch CASP licence with the AFM. You file, and the trust office's people are your own: we provide no trust services and act as nobody's director.
What's included
Seven parts, each tied to its rule.
Licence analysis
Which of the five trust services your model contains, for whom, and whether a carve-out or an ontheffing (individual exemption) applies.
Group design check
Articles 17 (tax advice), 3a (conduit companies) and 12 (control structure) set against your group chart.
The applicant entity
An NV, BV or SE with its seat in the Netherlands, by notarial deed and KVK registration. We set up a BV in the Netherlands or run our NV formation service.
The application file
The business plan with integrity measures, the systematic integrity risk analysis (SIRA), procedures and each tested person's antecedents.
Filing and DNB's questions
You file through Mijn DNB with your own eHerkenning login; we prepare the answers to DNB's requests.
Changes after the grant
Requests for DNB's prior consent before a new policymaker, qualifying holder or ultimate beneficial owner (UBO) takes their place.
Where our work stops
No trust services, before or after the licence. No director, policymaker or compliance officer, no licensed company for sale, no tax advice to your clients.
When a licence is needed, and when it is not
DNB leaves the first judgement to the applicant: the conditions below decide it.
- The five trust services
Director of an entity outside your group; an address plus legal, tax, bookkeeping or accounts work or director recruitment (reception work does not count); selling or mediating in the sale of legal entities; trustee; a general power of attorney for an entity outside your group.
- Your own group
Directing or representing entities of your own group, an organisationally linked economic unit, is not a trust service, so a management company directing its group's BVs provides none.
- A licence from another EU state
Without a Dutch branch, a trust office with a comparable home licence under sufficient safeguards is outside the prohibition (art. 3(6)); DNB judges comparability, and a Dutch branch needs DNB's licence.
- Seated outside the EEA
Barred from serving the Netherlands unless its state is designated by ministerial regulation and DNB licenses it (art. 3(3) and art. 4(1)).
- Exemptions
Temporary management assignments (art. 3(5)(c)); natural persons directing a STAK (stichting administratiekantoor, trust foundation) that only holds shares for certificate holders; other exemptions by regulation; an ontheffing from DNB, EUR 2,400 in 2026.
- Company formation
Incorporation assistance is not one of the five services; combined with an address, check the address-plus test.
- One of the five trust services?Go to the next questionOutside the licence duty
- For an entity outside your own group?Go to the next questionGroup carve-out (limbs a and e): DNB judges it
- Provided professionally or commercially, and not a temporary management assignment?Go to the next questionCarve-out of art. 3(5)(c) may apply: DNB judges it
- Seated in another EU state with a comparable licence and no Dutch branch?Art. 3(6) may apply: DNB judges comparabilityGo to the next question. Seated outside the EEA: designated state and a DNB licence only
- An exemption by regulation or an individual ontheffing (EUR 2,400, 2026)?Exemption routeThe licence duty applies. Check your model with us
How the licence application runs
DNB's clock starts at filing; before it, no official time is published.
Licence analysis
Which services, for whom, which carve-out; the model checked against the art. 23a ban on clients, object companies or UBOs in Russia, Belarus, EU high-risk third countries or EU non-cooperative tax jurisdictions.
Group design check
Articles 17, 3a and 12 settled before the entity exists. No official time is published for the preparation.
The applicant entity
Deed of the NV, BV or SE before a notaris (civil-law notary); KVK and UBO registration within one week of the deed, at the 2026 KVK fee of EUR 85.15.
The people
Two daily policymakers working from the Netherlands, a compliance officer who is not one of them and an audit function, all recruited by you.
The file
Intended operations with integrity measures, the SIRA, procedures and antecedents, checked against DNB's list of what sinks applications before drafting.
Filing
A complex application may be discussed with DNB first. You file through Mijn DNB; DNB bills EUR 6,800 plus the person-test fees on receipt.
DNB's review
13 weeks from receipt, stopped by every request for information; consideration may cease within four weeks if a request goes unanswered. DNB says the total tends to run longer.
Decision and start
A decision, possibly with conditions, and the public register entry. Services start within six months, or DNB may withdraw the licence.
- Licence analysisBefore filingNo official time is published
- Group design checkBefore filingNo official time is published
- The applicant entityBefore filing: notarial deedKVK and UBO registration within one week of the deed, EUR 85.15 (2026)
- The peopleBefore filingNo official time is published
- The fileBefore filingNo official time is published
- Filing via Mijn DNBApplicantEUR 6,800 plus person tests, billed on receipt
- DNB's reviewDNBArt. 6(4) Wtt 2018: 13 weeks from receiptRequest for information: clock stops. Unanswered request: consideration may cease within four weeks. DNB says the total tends to run longer
- Decision and register entryDNBServices start within six months, or the licence may be withdrawn
Not sure your model needs a licence at all?
In-group work, temporary management or an EU home licence can take a model outside the licence duty. Check before building a file.
What DNB requires of a Dutch trust office
Ten conditions, and what you supply for each.
What a Dutch trust office must carry. Sources: the Wtt 2018, the Besluit toezicht trustkantoren 2018 (Btt 2018, implementing decree) and the Rtt 2018 (ministerial regulation).
| Requirement | What the Wtt 2018 sets | What you supply | Basis |
|---|---|---|---|
| Legal form and seat | An NV, a BV or an SE with its seat in the Netherlands | The notarial deed and the KVK registration | Art. 13(1) Wtt 2018 |
| Fit and proper | Each policymaker suitable and reliable beyond doubt; a final conviction for a listed crime under eight years old, or a wilful-default tax penalty above EUR 62,500, fails automatically unless DNB deviates | Identity and antecedents of each person: criminal, financial, supervisory, tax | Art. 10(1) to (3) Wtt 2018; Btt 2018 art. 6(1), 7(1)(a) and (d), 7(2) |
| Two daily policymakers | At least two natural persons set day-to-day policy and work from the Netherlands (vanuit Nederland); DNB may exempt on application | Two named persons and the Dutch office they work from; the office side is part of Dutch substance requirements | Art. 11(1) to (3) Wtt 2018 |
| The trust office's own UBO | Tested for reputation and reliability | The owners and the UBO, with antecedents | Art. 10(4) Wtt 2018 |
| Control structure | No formal or actual structure that hinders adequate supervision | The group structure chart | Art. 12 Wtt 2018; Rtt 2018 art. 8(1) |
| Sound and ethical operations | A systematic integrity risk analysis (SIRA) and the procedures behind it | The business model, the clients and their countries | Art. 14 Wtt 2018; Btt 2018 art. 10 |
| Compliance in house | The compliance function is not outsourced; a policymaker does not run it | A compliance officer who is not a policymaker | Art. 16(2) Wtt 2018; Btt 2018 art. 19(2)(c) |
| Audit | An audit function checks at least once a year | The audit solution | Btt 2018 art. 18(1) |
| Filing access | Applications through Mijn DNB Supervisory applications | The applicant's own eHerkenning login | DNB application form notes |
| Capital | No capital figure is set in the Wtt 2018 or the Rtt 2018 data list | The funds for the DNB fees, billed on receipt | Wtt 2018; Rtt 2018 art. 8(1) |
State fees and statutory clocks in 2026
What the state charges and how long its clocks run. Our fee is on request.
State fees and clocks, 2026. Sources: the fee regulation for one-off acts (in force from 22 September 2026) and the 2026 levy regulation, checked 29 September to 6 October 2026.
| Item | Amount or period | Basis |
|---|---|---|
| DNB, licence application | EUR 6,800 | Fee code Wtt.D1.01 |
| DNB, suitability test per policymaker | EUR 2,900 | Fee code Wtt.D3.01 |
| DNB, reliability test per person | EUR 1,600 | Fee code Wtt.D3.02 |
| DNB, reputation test of the trust office's UBO | EUR 1,900 | Fee code Wtt.D3.03 |
| DNB, individual exemption instead of a licence | EUR 2,400 | Fee code Wtt.D2.01; art. 5(2) Wtt 2018 |
| KVK, registration of the applicant entity | EUR 85.15, the same for every legal form | Financiële regeling handelsregister 2019, art. 5 |
| DNB, annual supervision levy once licensed | EUR 2,000 base plus a rate per EUR 1,000 of turnover in four bands, from EUR 97.34 down to EUR 4.87 | Wbft 2019 art. 15(1); levy regulation 2026, category 8 |
| DNB decision period | 13 weeks from receipt, suspended on every request for information | Art. 6(4) Wtt 2018 |
| Unanswered request | Consideration may cease within four weeks | DNB application timeline |
| Use of the licence | Within six months of the grant, or it may be withdrawn | Art. 7(1)(f) Wtt 2018 |
DNB bills its fees on receipt and keeps them whatever the outcome; the text due from 11 January 2027 prints the same amounts.
Tax advice and trust services in separate groups
For a structuring group, article 17 decides where a trust office can sit.
What article 17 forbids
A Dutch-seated trust office may not give tax advice, nor serve a client implementing tax advice from its own group (art. 17 Wtt 2018). DNB: not both for the same customer.
What "tax advice" means here
Advising on the set-up, organisation or operation of structures of legal persons and partnerships aimed at applying international and national tax law (art. 1(1) Wtt 2018).
The condition for a group
A group giving tax advice and wanting a trust office for the same clients places the two in separate groups, or accepts they cannot share clients. Breach: fine category 2, base EUR 500,000.
Problems we solve
Where trust office plans go wrong.
- Advertising before the grant
Activities aimed at providing trust services are prohibited before the licence; DNB treats advertising as making a service licensable. Marketing waits for the grant (fine category 3, base EUR 2,500,000).
- "Domestic only" is not the rule
An EU trust office with a comparable home licence and no Dutch branch is outside the prohibition (art. 3(6)). A branch in the Netherlands needs the DNB licence.
- A licence cannot be bought
A licence is personal and not transferable (art. 2). A change of policymaker, qualifying holder or UBO waits for DNB's consent (art. 8).
- Where the policymakers work
The act says the policymakers work from the Netherlands, not that they live there; DNB may exempt on application (art. 11).
- Files that fail
DNB names proposed directors with earlier negative supervisory decisions or criminal investigations. We check the people first.
Planning a trust office inside an advisory group?
Settle article 17 and the in-group question before the entity is formed. Bring us the group chart.
Why work with us
Elif Demir, Compliance, licensing and founder permits lead, Amsterdam. Turkish, Dutch, English.
She assembles licence files for DNB and the AFM, among them applying for a Dutch e-money institution licence with DNB, and files Benelux trade mark registration.
From our practice: the licence question is settled before any application is drafted, because in-group directorships and temporary management sit outside the duty and DNB leaves that judgement to the applicant.
STAK and Foundation Structures in the Netherlands
How a trust foundation is set up, and when its board falls outside the licence duty.
Ready-Made Companies in the Netherlands
Buyer-side checks and the notarial share transfer for an existing Dutch BV.
Trust office licence: frequently asked questions
Do we need a licence to direct our own group's Dutch companies?
No. Acting as director, or as general attorney-in-fact, is a trust service under the Wtt 2018 only for an entity outside the provider's own group, which the act defines as an organisationally linked economic unit. Temporary assignments on management and organisation questions also fall outside the licence duty.
We hold a trust or company service licence in another EU country. Can we serve Dutch clients without a DNB licence?
Possibly. The Dutch prohibition does not apply to a trust office without a Dutch branch that holds a comparable licence in another member state, with sufficient safeguards under its home supervision (art. 3(6) Wtt 2018). Whether a licence is comparable is for DNB to judge. A branch in the Netherlands needs the DNB licence.
Can we buy a Dutch company that already holds a trust office licence?
No. Licences and exemptions under the Wtt 2018 are personal and not transferable (art. 2). Even inside a licensed trust office, a change of policymaker, of a qualifying holder or of the ultimate beneficial owner is not carried out until DNB has given its consent (art. 8).
Our group gives tax advice. Can the same group run a licensed trust office?
Not for the same clients. A Dutch trust office may not give tax advice, nor serve a client who is implementing tax advice given by a person or company in its own group (art. 17 Wtt 2018). A breach falls in fine category 2: base EUR 500,000, maximum EUR 1,000,000.
Do the daily policymakers have to live in the Netherlands?
The Wtt 2018 requires at least two natural persons who set the day-to-day policy of the trust office and who work from the Netherlands (art. 11). The text speaks of working from the Netherlands, not of residence. DNB may grant an exemption on application where the rule cannot reasonably be met.
What does DNB charge for a trust office licence application in 2026, and is the fee refunded if it fails?
In 2026, EUR 6,800 to handle the application, plus EUR 2,900 per suitability test, EUR 1,600 per reliability test and EUR 1,900 for the reputation test of the trust office's UBO. DNB bills the fees on receipt and does not refund them, whether it approves, rejects or ceases consideration, or the applicant withdraws.
Is there a yearly cost once the trust office is licensed?
Yes. DNB charges a yearly supervision levy (Wbft 2019 art. 15(1)). For trust offices in 2026 it is a EUR 2,000 base plus, per EUR 1,000 of turnover, EUR 97.34 up to EUR 230,000, EUR 82.74 up to EUR 1,080,000, EUR 34.07 up to EUR 8.9 million and EUR 4.87 above.
How long does DNB take to decide?
The Wtt 2018 gives DNB 13 weeks from receipt of the application (art. 6(4)), and the period stops on every request for information. If a request goes unanswered, DNB may cease consideration within four weeks. DNB itself says the total processing time tends to be longer than 13 weeks.
Can the compliance function be outsourced?
No. A trust office with its seat in the Netherlands keeps the compliance function in house (art. 16(2) Wtt 2018). A policymaker may not also be involved in compliance or audit, and an audit function checks the trust office at least once a year under the implementing decree.
Which legal form must a Dutch trust office have, and is there a minimum capital?
A trust office with its seat in the Netherlands is an NV, a BV or an SE (art. 13(1) Wtt 2018). No capital figure is set in the Wtt 2018 or in the data list of the ministerial regulation. The applicant does need the funds for DNB's fees, which are billed on receipt.
What happens if we offer trust services before the licence is granted?
Activities aimed at providing trust services are prohibited without the licence (art. 3(4)(a) Wtt 2018), and DNB says a service becomes licensable when it is actively promoted, for instance by advertising. The fine is category 3: base EUR 2,500,000, maximum EUR 5,000,000, and EUR 10,000,000 for a repeat within five years.
What does DNB do for trust offices, and where is the register of licensed trust offices?
De Nederlandsche Bank grants trust office licences under the Wtt 2018, supervises trust offices under that act and under the Dutch anti-money-laundering act (Wwft), and keeps the public register under art. 9 Wtt 2018, in which each licence is entered after the decision. Anyone can check a trust office there.
Does a trust office need the AFM, and what does the AFM license?
No. DNB licenses trust offices. The AFM licenses investment firms (art. 2:96 Wft) and fund managers (art. 2:65 Wft). An investment firm that does not deal on own account needs own funds of at least EUR 75,000, and the AFM charges EUR 200 per hour, capped at EUR 100,000, for a general investment-firm licence.
Is there a general business licence in the Netherlands?
No. The Netherlands has no general business licence: permits exist for defined sectors. A business starting in the financial services sector must apply for a licence. For a trust office, that licence is granted by De Nederlandsche Bank under the Wtt 2018; investment firms and fund managers apply to the AFM.
What changes for trust offices in 2027?
From 10 July 2027 the EU anti-money-laundering regulation, Regulation (EU) 2024/1624, applies and treats trust and company service providers as obliged entities. Directive (EU) 2024/1640 requires them to be licensed or registered, with transposition due by the same date. The Dutch implementation has not been published.
Request a trust office licence plan
Tell us what the business would do and for whom.
- Name
- Company
- Which services would the business provide?
- Are the clients inside or outside your own group?
- Does the group hold a trust or company service licence in another EU state?
- Does the group also give tax advice?
- Are two day-to-day policymakers already identified?
Confirmation: Thank you, we reply to the email address you gave.