Licensing and intellectual property
Trust Office Licence in the Netherlands: Support for Your DNB Application
Your plan checked against the Wtt 2018, your people and your file ready for DNB's tests, so the 13-week period starts on a complete application.
- Licensing authority: DNB, under the Wtt 2018
- Statutory decision: 13 weeks from receipt, paused by every request
- DNB application fee: EUR 6,800 (2026), not refunded on refusal
- At least two daily policymakers, working from the Netherlands
Help with your own trust office licence application
Anyone providing trust services professionally from a Dutch seat needs a licence from De Nederlandsche Bank (DNB) first (art. 3(1) Wtt 2018). That licence, the trustkantoor vergunning, belongs to the applicant. We help founders and corporate-services groups prepare their own application. Background on trust office netherlands rules sits in a separate guide.
DutchRegist holds no DNB licence and provides no trust services, and DNB decides every application (art. 6 Wtt 2018). DNB leaves it to the applicant to determine whether a licence is needed, and recommends an expert advisor. Other regulated businesses follow other routes, such as getting authorised as a crypto-asset service provider in the Netherlands.
What's included
Seven pieces of work, and where ours stops.
Scoping
DNB's two questions applied to your plan: is it a trust service, provided professionally or commercially? Plus the Rtt 2018 exemptions.
Eligibility screen
Seat (art. 3), legal form (art. 13(1)), a transparent control structure (art. 12), the art. 23a country ban against your client base, and the art. 17 tax-advice ban against your group.
People plan
The two daily policymakers, a compliance officer who is not one of them, the yearly audit, and which policymaker answers for each (art. 11 Wtt 2018; Btt art. 18, 19).
The file
Business plan with integrity measures, SIRA, procedures manual and the policies DNB expects, drafted with you (Rtt art. 8(1)).
Person files
Identity and antecedents of every policymaker, director, qualifying holder and the UBO, ready before filing (Btt art. 4 to 7).
Filing and DNB's questions
You file through Mijn DNB with eHerkenning. We prepare the answers to DNB's requests for information, each of which pauses the 13-week period.
The applicant BV or NV
Incorporation is a separate service: the notarial deed and the KVK registration of the company that applies.
Where our work stops
No licence held, lent, sold or transferred (art. 2 Wtt 2018). We do not act as director, policymaker, attorney or compliance officer, give the applicant our address, or sell tax advice with this service. DNB decides.
When a trust office licence is needed
A trust office is anyone providing a trust service professionally or commercially, with no size threshold and no legal-form test (art. 1(1) Wtt 2018).
- Selling legal entities
Selling or mediating in the sale of legal entities is a trust service (limb c). A provider who sells a ready-made Dutch BV to clients needs this licence first.
- Director, trustee or attorney
Acting as director or partner for a client, as trustee, or as an attorney with general management powers (limbs a, d and e; Btt art. 2). More in our guide to nominee director netherlands rules.
- An address plus other work
An address plus legal help, tax returns, accounts or bookkeeping for the same client is domicile plus (limb b). Reception work alone is domicile only, not a trust service according to DNB: the basis of a registered office netherlands service.
- Professional or commercial
One-off or very occasional provision needs no licence. Active promotion, including advertising, or provision to different customers does, and activities aimed at unlicensed trust services are themselves caught (art. 3(4)(a)).
- Not this licence
Managing an investment fund (art. 2:65 Wft) or providing investment services (art. 2:96 Wft) needs an AFM licence. Payment and e-money institutions are DNB licences under the Wft: see our payment institution licence service.
How the DNB application works
Who acts at each step, and the official timing where one exists.
Scoping and eligibility
You, with our assistance: trust service or not, the Rtt exemptions, the seat, the legal form and the bans of art. 17 and 23a. Timing: none published.
The applicant company
A notaris forms the NV, BV or SE, then KVK and UBO registration, EUR 85.15 in 2026 (art. 20 Hrw 2007). Timing: within one week of the deed.
The people
You recruit the policymakers, the compliance officer, the audit function and any supervisory directors, and gather each person's antecedents. Timing: none published.
The file
You, with our assistance: business plan, SIRA, manual, policies and person files (see the documents below). Timing: none published.
Optional pre-filing contact
You or your adviser announce the application to DNB's Expert Centre on Market Access and discuss a complex file first. Timing: none.
Filing
You file in Mijn DNB, under Supervisory applications, with eHerkenning. DNB bills its fees where possible on receipt; they stay due whatever the outcome.
DNB's review
Completeness first. Each request for information pauses the 13 weeks (art. 6(4) Wtt 2018), and a file not supplemented may be ceased within four weeks. DNB says the total tends to be longer than thirteen weeks.
Decision and register
DNB decides, possibly with conditions (art. 6(3)), and enters the licence in its public register (art. 9). Services must start within six months, or the licence may be withdrawn (art. 7(1)(f)).
- Filing in Mijn DNBYou, with eHerkenningDNB fees billed on receipt
- Completeness checkDNBNo published time
- The 13-week periodDNB13 weeks from receipt (art. 6(4) Wtt 2018) Each request for information pauses the clock No or insufficient reply: the file may be ceased within four weeks
- DecisionDNBPossibly with conditions (art. 6(3) Wtt 2018)
- Entry in the public registerDNBArt. 9 Wtt 2018
- Start of servicesThe licence holderWithin six months, or the licence may be withdrawn (art. 7(1)(f) Wtt 2018)
Not sure whether your plan needs a licence at all?
DNB leaves that call to the applicant. We check your plan against the Wtt 2018 before anything is drafted.
The people DNB will test
At the real minimum, three people: two daily policymakers plus a compliance officer who is not one of them (art. 11(1), 16(2) Wtt 2018; Btt 2018 art. 19(2)(c)).
- Two daily policymakers
At least two natural persons determine the daily policy and carry out that work "from the Netherlands" (art. 11(1), (2)). DNB may grant an exemption on application (art. 11(3)).
- An in-house compliance officer
The compliance function is independent and may not be outsourced (art. 15(1), 16(2)). A policymaker may not perform it (Btt art. 19(2)(c)).
- An audit function
It checks compliance at least once a year (Btt art. 18(1)), internally or externally. Compliance and audit sit under two different policymakers (Btt art. 19(4)).
- Owners and the UBO
Policymakers and qualifying holders must be reliable beyond doubt; your UBO is also judged on reputation (art. 10). Automatic fails include a listed conviction under eight years old or a wilful-default tax penalty above EUR 62,500 (Btt art. 7).
Documents DNB will expect
Per person, and for the company that applies.
- Identity of every director, supervisory director, policymaker, qualifying holder and the UBO.
- Answers on antecedents: criminal, financial, supervisory, tax and other (Btt art. 5).
- Consent to DNB's checks with police, tax authorities, supervisors and references (Btt art. 6(1)).
- For a person already assessed under the Wft, the date of that assessment (Rtt art. 8(2)).
- Evidence of knowledge and trust-office management experience for each policymaker.
- Deed and KVK registration of the applicant NV, BV or SE.
- Group structure chart, with name, address and seat (Rtt art. 8(1)).
- Business plan with integrity measures, administrative organisation and internal control.
- SIRA and procedures manual covering the Wtt, the Wwft and the Sanctions Act.
- Conflicts policy, integrity-sensitive functions, risk classification, organisation chart and staff list.
- Compliance work programme with hours, outsourcing contracts and CDD procedures.
- Client-money arrangements (art. 19 Wtt 2018) and eHerkenning for the portal.
Trust office licence requirements, DNB fees and deadlines
The state's rules and DNB's charges only; our fee is on request. DNB tests suitability for policymakers, reliability for policymakers and qualifying holders, and reputation for the UBO.
Trust office licence requirements, DNB fees and deadlines in 2026, from the Wtt 2018, the Btt 2018 and the fee regulation in force from 22 September 2026; checked in October 2026. The fee table changes from 11 January 2027.
| Item | Rule or figure | Source |
|---|---|---|
| Who needs it | Anyone providing trust services professionally or commercially from a Dutch seat | Art. 1(1), 3(1) Wtt 2018 |
| Seat and legal form | NV, BV or SE; a seat outside the member states is barred, save the art. 4 route | Art. 13(1), 3(3) Wtt 2018 |
| People | At least two daily policymakers working from the Netherlands; compliance in-house, not run by a policymaker; audit at least yearly | Art. 11(1), (2) Wtt 2018; Btt art. 18(1), 19(2)(c) |
| DNB application fee | EUR 6,800 | Wtt.D1.01, BWBR0041647 |
| Person tests, each | Suitability EUR 2,900 · reliability EUR 1,600 · reputation of the UBO EUR 1,900 | Wtt.D3.01 to D3.03, BWBR0041647; art. 10 Wtt 2018 |
| Billing and refund | Billed where possible on receipt; due whether approved, rejected, withdrawn or ceased | Art. 3(2) BWBR0041647; DNB |
| Decision period | 13 weeks from receipt, paused by each request; a file not supplemented may be ceased within four weeks | Art. 6(4) Wtt 2018; DNB |
| Annual levy | Charged every year; non-payment is a withdrawal ground | Wbft 2019 art. 15(1); art. 7(1)(e) Wtt 2018 |
| Applicant registration | KVK registration EUR 85.15 (2026), within one week of the deed | Art. 5 Financiële regeling handelsregister 2019 |
| Keeping the licence | Unused for six months: withdrawal; prior consent for people changes; five-year record retention | Art. 7(1)(f), 8(1), 37(4) Wtt 2018 |
What cannot be done, and how we handle it
The rule first, then how we handle it.
- "Can we buy a licence?"
No: a licence is personal and not transferable (art. 2), and buying a licensed office needs DNB's prior consent for the new owners and policymakers (art. 8(1), (2)). Handled: the consent file is prepared like an application.
- "We are outside the EU."
A seat in a state that is not a member state is barred from providing trust services to the Netherlands (art. 3(3)), save the art. 4 route. Handled: the seat question is settled in the eligibility screen.
- "Our group gives tax advice."
A trust office may not give tax advice, nor serve clients implementing its group's tax advice (art. 17); a breach is fine category 2. Handled: your group map is screened first.
- "What if DNB refuses?"
The fee stays due whatever the outcome. DNB's list of common failures starts with policymakers who have integrity issues or fail the fitness assessment. Handled: person files and the SIRA come before filing.
- "Will a bank take us?"
No onboarding time is published, and banks treat trust offices as high risk. Handled: the bank is raised in the plan, not after the licence.
Is your team ready for DNB's fit and proper test?
The person files decide much of the review. Have each one checked before DNB's 13 weeks start.
Why work with us
We screen the plan against the Wtt 2018 before drafting, build a person file for each policymaker, qualifying holder and the UBO before filing, and answer DNB's requests with you, alongside the notaris and the KVK.
Ilse Brouwer, tax, VAT and licensing lead, Amsterdam; Dutch, English and French. She assembles AFM and DNB licence files.
Trust office licence: frequently asked questions
Can you obtain a trust office licence for us, or let us use yours?
No. DutchRegist holds no DNB licence and provides no trust services. A licence is granted to the applicant itself and is personal and not transferable (art. 2 Wtt 2018). We help you prepare your own application: the scoping, the people plan, the file and the answers to DNB's questions. DNB decides.
Can I buy a company that already holds a trust office licence?
Not as a way round the licence. Licences are personal and not transferable (art. 2 Wtt 2018), and a change of owner or policymaker of a licensed trust office needs DNB's prior consent first (art. 8(1) and (2)). The new owners and policymakers are tested much as in an application.
Do both daily policymakers have to live in the Netherlands?
The Wtt 2018 requires at least two natural persons who determine the daily policy and who carry out that work from the Netherlands (art. 11(1) and (2)). DNB may grant an exemption on application where this cannot reasonably be met (art. 11(3)). The sources we rely on set no separate residence rule.
How many people does a Dutch trust office really need?
At least three. Two natural persons determine the daily policy (art. 11(1) Wtt 2018), the compliance function may not be outsourced (art. 15(1) and 16(2)), and a policymaker may not perform it (Btt art. 19(2)(c)). An audit function also checks compliance at least once a year (Btt art. 18(1)).
What does DNB charge, and is the fee refunded if the application fails?
DNB charges EUR 6,800 for the application (Wtt.D1.01), plus EUR 2,900 per person whose suitability it tests, EUR 1,600 per person whose reliability it tests and EUR 1,900 for the reputation test of the trust office's UBO (regulation in force from 22 September 2026). The fees are due whatever the outcome. Our fee is on request.
How long does DNB take to decide on a trust office licence?
DNB decides within thirteen weeks of receipt (art. 6(4) Wtt 2018). The period runs on a complete file: each request for information pauses it, and DNB says the total processing time tends to be longer than thirteen weeks. No total duration is published, so none is promised here.
Can a company outside the EU provide trust services to Dutch clients?
As a rule, no. Anyone seated in a state that is not an EU member state is prohibited from providing trust services to the Netherlands (art. 3(3) Wtt 2018), save the designated-state route of art. 4. A trust office seated in the Netherlands must be an NV, a BV or an SE (art. 13(1)).
Can a licensed trust office also give tax advice?
No. A trust office seated in the Netherlands may not give tax advice, nor serve clients implementing tax advice given by its own group (art. 17 Wtt 2018). A breach falls in fine category 2. A group that sells tax advice has to plan its trust office around this ban.
Do I need a licence to sell ready-made companies, act as a nominee director or provide an address with bookkeeping?
Yes. Selling or mediating in the sale of legal entities, acting as director for a client, and an address combined with bookkeeping, tax returns, accounts or legal help are trust services (art. 1(1) Wtt 2018). Offering them without a licence is itself caught (art. 3(4)(a)), and DNB counts advertising as active promotion.
Is a registered address with mail forwarding a trust service?
Not on its own. DNB calls an address plus reception work, such as taking calls and forwarding unopened mail, domicile only, and says it is not a trust service. The same address combined with legal help, tax returns, accounts or bookkeeping for that company is domicile plus, which needs a licence.
What are the requirements for a trust office licence in the Netherlands?
A Dutch seat and the form of an NV, BV or SE (art. 13(1) Wtt 2018); suitable and reliable policymakers and qualifying holders (art. 10); at least two daily policymakers working from the Netherlands (art. 11); a transparent control structure (art. 12); sound and ethical operations with a SIRA (art. 14); an in-house compliance function.
How do I apply to DNB for a trust office licence, and is there an application form?
The application is filed online in Mijn DNB, under Supervisory applications, and access needs eHerkenning. DNB publishes the application form with explanatory notes, and invites applicants to announce an application to its Expert Centre on Market Access and to discuss a complex file first. DNB bills its fees on receipt where possible.
How do I check whether a trust office is licensed?
Search DNB's public register of trust offices, often called the TCSP register. It lists licensed trust offices, group entities and exempted providers, with name, address, seat, licence date, KVK number and any conditions (art. 9 Wtt 2018). DNB updates the register every business day at 06:00.
Is a trust office licence the same as an AIFM or investment firm licence?
No. The trust office licence is granted by DNB under the Wtt 2018. Managing an investment fund needs an AFM licence under art. 2:65 Wft, and providing investment services an AFM licence under art. 2:96 Wft. The AFM charges EUR 200 per hour of work on each application, up to EUR 100,000.
What happens if trust services are provided without a licence?
Providing trust services from a Dutch seat without a licence breaches art. 3 Wtt 2018, a fine category 3 breach: base EUR 2,500,000 and maximum EUR 5,000,000 (art. 49(2)), and EUR 10,000,000 for a repeat within five years (art. 49(3)). It is also an economic offence.
Request a trust office licence plan
Tell us the trust services you plan and who will run the office; we reply with the scope, the people plan and the file.
Form fields: Name · Email · Company or group · Trust services you plan (Selling legal entities / Director or attorney services / Address plus other work / Trustee / Not sure yet) · Your message Confirmation: Thank you. Our licensing team will reply by email.