{"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":"2026-02-26T11:58:24","modified_gmt":"2026-02-26T10:58:24","slug":"safeguarding-customer-funds","status":"publish","type":"btv_wiki","link":"https:\/\/www.betaalvereniging.nl\/en\/knowledge-base\/european-legislation\/safeguarding-customer-funds\/","title":{"rendered":"Safeguarding customer funds"},"content":{"rendered":"\n

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

Payment and electronic money institutions receive customer funds and payments in the context of their payment services and are legally obliged to protect these \u2018customer 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 customer funds and payments, for example if the institution goes bankrupt. By completely separating customer 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 asset separation work?<\/h3>\n\n\n\n

In practice, asset separation 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. Third-party funds foundation<\/u><\/strong><\/a><\/li>\n\n\n\n
  2. Quality account<\/u><\/strong><\/a><\/li>\n<\/ol>\n\n\n\n

    1. Third-party funds foundation<\/h2>\n\n\n\n

    Payment service providers currently mainly use a third-party funds foundation with a linked bank account, as this was the only option available in the Netherlands before quality accounts became possible in 2022. In this case, the payment service provider sets up a separate foundation that exclusively manages customer funds. The foundation opens and manages the associated bank account, so that customer 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