Safeheld
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    European Union. Each member state's own rules.

    Payment and e-money institutions are licensed and supervised by their home authority, which applies the PSD2 and E-Money Directive safeguarding rules through national law.

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    Rules applied
    Netherlands, Lithuania and Ireland: payment-service funds and e-money funds, each under its own national law.
    Reports prepared
    DNB prudential report tabs T80.01 and T83.00. Evidence and audit packs for Lithuania and Ireland.
    Checked
    Every business day, for each entity, in its own currency.

    What each authority expects.

    The directives set the methods. Each member state sets the timing, the accounts that qualify and what its supervisor asks for.

    Netherlands

    Payment institutions and e-money institutions licensed in the Netherlands. Supervised by De Nederlandsche Bank.

    Wft art. 3:29a, 3:29aa; Besluit prudentiële regels Wft art. 40a, 40b
    RequirementWhat the rule saysReference
    Payment-service fundsProtected if still held at the end of the business day after receipt.Wft 3:29a(1); Bpr 40a
    HowA dedicated third-party account forming a separate estate, a third-party funds foundation (stichting derdengelden), a separate bank account, or insurance or a guarantee for the full amount.Wft 3:29aa; Bpr 40a(1)-(2)
    E-money fundsProtected as soon as they are available to the institution. Five working days after issue is only the latest date for funds not yet received.Bpr 40b(1)
    How, for e-moneyA separate bank account, a third-party funds foundation, a dedicated account, or insurance or a guarantee. A central bank account is not listed.Bpr 40b(2)-(3)
    Out of scopeInstitutions providing only payment initiation or account information services.Wft 3:29a(3)

    How Safeheld applies it. Investment in secure, liquid, low-risk assets is not counted (stricter). Eurosystem central banks, including DNB, do not offer safeguarding accounts to non-bank providers.

    Returns and reports.

    What is filed, when and where, and exactly what Safeheld produces for it.

    Prudential report T80.01 and T83.00De Nederlandsche Bank
    How often
    Semi-annual, at 30 June and 31 December
    Due
    Set by DNB, 10 February for 31 December
    Filed through
    DNB Digitaal Loket Rapportages, Excel template
    Completion workbook

    Every cell code of the safeguarding method and third-party funds tabs with its value, in whole euros at the ECB reference rate, for keying into the DNB template.

    Safeguarding evidenceBank of Lithuania and Central Bank of Ireland
    How often
    On request and at audit
    Due
    As the authority sets
    Filed through
    The authority's own reporting channel
    Evidence and audit pack

    Daily reconciliations, the account register, breaks and approvals for each entity, with read-only access for auditors and the supervisor.

    The other tabs of the DNB report, such as financial statements and payment volumes, are prepared outside Safeheld. Every report is reviewed and approved by your team before it is filed.

    Every day

    What Safeheld runs for the European Union.

    Reconcile. Every safeguarding and foundation account matched to the ledger, for each entity, in euros and every other currency held.
    Investigate. Breaks worked to their cause. Funds held past the national deadline raised as a breach for that entity.
    Forecast. Funding needs for the next 24 hours, 7 and 30 days, entity by entity.
    Act. Top-ups and transfers proposed and approved within limits, sent to the bank as an ISO 20022 payment file.
    Report. DNB tabs T80.01 and T83.00, and the evidence behind every Lithuanian and Irish return and audit.
    Nexus Payments EuropeEUR, 30 Sep 2026, close of businessMeets
    Owed to customers€18,604,311.20
    Counted under the rules€18,622,005.60
    Excess€17,694.40
    Entities, each under its own law
    Nexus Payments B.V.Bpr 40a, 40bMeets
    Nexus Payments UABart. 17, art. 25Meets
    Nexus Payments Ireland Ltdreg. 17, reg. 29Meets
    Each entity is reconciled and tested on its own. A surplus in one country never covers a shortfall in another.

    Questions.

    Can one group safeguarding account serve several EU entities?

    No. Each institution safeguards its own users' funds under its own licence and national law. Safeheld keeps each entity's position separate and never nets across the group.

    Can we hold safeguarded funds at the central bank?

    Dutch law allows it for payment-service funds, and Irish law lists it, but Eurosystem central banks do not offer safeguarding accounts to non-bank payment providers. In Lithuania, central bank accounts have not been available since 9 April 2025.

    What is a stichting derdengelden?

    A separate third-party funds foundation that holds customer money in its own bank account, outside the institution's estate. It is the route most Dutch institutions use, and Safeheld records it as its own account type.

    Does Safeheld produce the DNB report?

    It produces the safeguarding tabs, T80.01 and T83.00, as a workbook of cell codes and values for the DNB template in the Digitaal Loket Rapportages. The rest of the DNB report sits outside Safeheld.

    What changes under PSD3 and the Payment Services Regulation?

    Nothing applies yet. When the texts are in force, each changed requirement is added as a new rule version and applied from its effective date.

    Customer money in the European Union, accounted for every day.

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