{"id":3040,"date":"2025-10-14T15:01:56","date_gmt":"2025-10-14T13:01:56","guid":{"rendered":"https:\/\/www.betaalvereniging.nl\/en\/?post_type=btv_wiki&p=3040"},"modified":"2026-05-28T08:39:21","modified_gmt":"2026-05-28T06:39:21","slug":"safeguarding-client-funds","status":"publish","type":"btv_wiki","link":"https:\/\/www.betaalvereniging.nl\/en\/knowledge-base\/european-legislation\/safeguarding-client-funds\/","title":{"rendered":"Safeguarding client funds"},"content":{"rendered":"\n

Why must client funds be protected?<\/h2>\n\n\n\n

Payment and electronic money institutions receive client funds and payments in the context of their payment services and are legally obliged to protect these \u2018client funds\u2019. This obligation stems from the Revised Payment Services Directive<\/u><\/strong><\/a> (PSD2) and the revised Electronic Money Directive (EMD2). The Dutch government has incorporated these rules into the Financial Supervision Act (Wft).<\/p>\n\n\n\n

These regulations are intended to prevent creditors of a payment service provider from claiming client funds and payments, for example if the institution goes bankrupt. By completely separating client funds from the payment service provider’s own capital, these funds remain outside the bankruptcy estate and are protected for customers.<\/p>\n\n\n\n

How does fund segregation work?<\/h3>\n\n\n\n

In practice, fund segregation is achieved by means of specially designated bank accounts<\/u><\/strong><\/a> that are classified as segregated asset accounts. These accounts are offered by banks. For payment service providers licensed in the Netherlands, there are two options:<\/p>\n\n\n\n

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  1. Foundation trust account<\/strong><\/a> (Stichting derdengeldenrekening in Dutch)<\/em><\/li>\n\n\n\n
  2. Segregated bank account<\/strong><\/a> (Kwaliteitsrekening in Dutch)<\/em><\/li>\n<\/ol>\n\n\n\n

    1. Foundation trust account<\/h2>\n\n\n\n

    Payment service providers currently mainly use a foundation trust account with a linked bank account, as this was the only option available in the Netherlands before Segregated bank accounts were introduced in 2022. In this case, the payment service provider sets up a separate foundation that exclusively manages client funds. The foundation opens and manages the associated bank account, so that client funds are not held in the name of the payment service provider but in the name of the foundation.<\/p>\n\n\n\n

    Although a foundation for third-party funds is de facto the standard in the Netherlands, it has some limitations:<\/p>\n\n\n\n