NETHERLANDS Law and Practice Contributed by: Roderik Vrolijk, Rogier Raas, Ingrid Viertelhauzen and Maarten Weekenborg, Stibbe
Stibbe Beethovenplein 10 1077 WM Amsterdam The Netherlands
Tel: +31 20 546 01 58 Fax: +31 20 546 01 23 Email: amsterdam@stibbe.com Web: www.stibbe.com
1. Fintech Market 1.1 Evolution of the Fintech Market A Maturing but Dynamic Ecosystem
third-party oversight obligations across the financial sector. The EU AI Act is being phased in, with bans on prohibited AI practices and AI literacy requirements already effective since February 2025, and obligations for high-risk AI systems applicable from August 2026. Artificial Intelligence in Fintech AI models are increasingly embedded in Dutch fintech products and services. Common applications include fraud detection and behavioural analytics, AML/KYC automation, credit scoring, robo-advisory and cus - tomer service chatbots. Both DNB and the Nether - lands Authority for the Financial Markets ( Autoriteit Financiële Markten , the AFM) have signalled that AI- specific supervision will be intensified, with the AFM focusing on conduct risks such as digital nudging through apps, and DNB emphasising soundness, accountability, fairness, ethics and transparency (their “SAFEST” principles). The European Parliament also published a draft report in May 2025 examining AI’s impact on the financial sector. Fintech firms deploying AI should expect growing regulatory expectations around explainabil - ity, data quality, AI governance and human oversight.
The Netherlands continues to be recognised as one of Europe’s leading fintech hubs, with over 850 active fintech companies and a total tech ecosystem valued at more than EUR240 billion. Amsterdam in particular serves as a magnet for both homegrown champions – such as Adyen, Mollie, Bunq and Bird – and inter - national entrants including CurrencyCloud, Lemonade and Airwallex, which each selected the Netherlands as their base in the European Union (EU). Recent Market Developments Over the past twelve months, fintech lending has shown notable growth. According to the Dutch Cen - tral Bank ( De Nederlandsche Bank , DNB), outstand - ing fintech loans rose from EUR1.8 billion in 2021 to EUR4.4 billion by YE-2024, with the sector’s share of SME financing reaching 2.8%. Embedded finance, regtech and insurtech have continued to expand. Legacy institutions have deepened their engagement with fintech, moving beyond passive investment into developing proprietary solutions and acquiring fintech companies outright. Key Challenges for 2026 The regulatory landscape will be the most significant driver of change. The Markets in Crypto-Assets Regu - lation (MiCAR) licensing regime became fully appli - cable in mid-2025, impacting around 80 previously DNB-registered crypto firms. The Digital Operational Resilience Act (DORA) entered into full application in January 2025, imposing ICT risk management and
2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models Digital Payments and Banking
Digital payments remain the largest and most estab - lished fintech vertical in the Netherlands. Companies such as Adyen, Mollie and Buckaroo provide pay -
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