Zero Hash gets a Dutch EMI license, a first under the EBA's stablecoin rules

A regulatory first for stablecoin infrastructure

@zerohashx has secured an Electronic Money Institution (EMI) license from De Nederlandsche Bank (DNB), the Dutch central bank, making it the first MiCA-licensed firm to also hold payment services authorization under the European Banking Authority's June 2025 framework for stablecoin operators.

The EMI license was granted to Zerohash Europe B.V., the firm's Amsterdam-based subsidiary, and sits alongside a MiCA authorization that Zerohash received from the Dutch Authority for the Financial Markets (AFM) in October 2025. Holding both licenses is now a regulatory requirement for firms running certain stablecoin payment flows within the EEA.

The backdrop is a June 2025 no-action letter from the EBA, which clarified that custody and transfer of e-money tokens (EMTs) on behalf of clients constitute payment services under PSD2. The EBA advised national regulators to require payment services authorization for such activities from 2 March 2026 onwards, giving firms a nine-month window to put the dual licensing in place. Zerohash has now completed that process ahead of the deadline.

What the dual license unlocks

With both authorizations in hand, Zerohash can operate compliant stablecoin payment flows across the full European Economic Area for banks, brokerages, fintechs, and payment firms. The company describes the combined setup as providing full regulatory certainty for the digital asset and stablecoin services its European entity delivers to financial institution and enterprise clients.

The EBA's guidance was itself a response to an overlap problem built into EU law. EMTs are treated as both crypto assets under MiCA and as funds under PSD2, meaning the same custody or transfer activity can fall under two regulatory regimes simultaneously. A February 2026 EBA opinion set out how national authorities should proceed once the transition period expired, directing them to require CASPs without appropriate PSD2 coverage to cease offering affected EMT services.

Zerohash's move positions it as one of the few firms that has navigated the full dual-authorization path under the new framework, a bar that many smaller operators are still working to clear.

Sources
Zerohash Receives EMI License from Dutch Central Bank (GlobeNewswire via Manila Times)
EBA No-Action Letter on PSD2 and MiCA Interplay (European Banking Authority)
EBA February 2026 Opinion on End of Transition Period (European Banking Authority)