Which regulator issues the Netherlands crypto license under MiCA?

Under MiCA, the Netherlands CASP authorization is issued jointly by DNB (De Nederlandsche Bank) and AFM (Autoriteit Financiële Markten). DNB is the primary supervisor for prudential and AML matters, while AFM supervises conduct-of-business and market integrity. In practice, a single CASP application is submitted and processed through a coordinated NCA process. DNB has been supervising crypto service providers since 2020 under the Dutch AML Act (Wwft) registration regime.

How long does a Netherlands CASP license take?

A Netherlands CASP authorization under MiCA typically takes 4–6 months: company setup (B.V. formation) 1–2 weeks, document preparation 6–10 weeks, then DNB/AFM review up to 65 working days (MiCA Art. 63). The Netherlands has an established financial services supervisory tradition and strong administrative processes. Complex applications or those involving multiple service types may take 6–8 months.

What capital is required for a Netherlands crypto license?

MiCA Article 67 sets three tiers: €50,000 for advisory, order transmission, execution, and placing services; €125,000 for exchange, portfolio management, and transfer services; €150,000 for custody and trading platform operations. The B.V. (Besloten Vennootschap) minimum share capital in the Netherlands is just €0.01 nominal — the MiCA own funds requirement is entirely separate and must be maintained as eligible capital at all times.

What is the difference between DNB and AFM for crypto regulation?

DNB (De Nederlandsche Bank) is the prudential supervisor and AML/CFT authority — it supervises financial soundness, capital adequacy, internal controls, and AML compliance. AFM (Autoriteit Financiële Markten) supervises conduct of business — market integrity, investor protection, fair treatment of clients, and marketing standards. Under MiCA, both authorities have roles in the CASP authorization process. For cross-border (passported) services, DNB leads as the home NCA for prudential matters.

Does the Netherlands have a VASP transition regime under MiCA?

Yes. Crypto service providers registered with DNB under the Dutch AML Act (Wet ter voorkoming van witwassen en financieren van terrorisme — Wwft) before 30 December 2024 may continue operating under the MiCA transitional regime until 1 July 2026, or until a decision on their CASP application is issued. The Netherlands had a relatively strict Wwft crypto registration — firms registered there had to meet AML standards, which provides a foundation for the MiCA CASP application but does not substitute for it.

Is the Netherlands a good jurisdiction for EU passporting?

The Netherlands is a credible but moderately expensive passporting base. DNB and AFM have strong reputations for rigorous supervision — a Netherlands CASP authorization carries high credibility with institutional clients and banking partners. However, government fees (€5,000–€12,000) and operating costs are higher than in Lithuania or Estonia. For firms primarily targeting the DACH or Benelux markets, or those needing high-credibility EU authorization for institutional partnerships, Netherlands is a strong choice.

Can a non-Dutch company get a Netherlands crypto license?

Yes. Foreign companies can establish a Dutch B.V. (Besloten Vennootschap — private limited company) and apply for CASP authorization. The B.V. must have genuine substance in the Netherlands — a registered office, local management presence, and key functions based in the Netherlands. Remote directorships without substance will not satisfy DNB's substance requirements. Crypto License Europe advises on B.V. formation, substance setup, and the full CASP application process.

What are professional fees for a Netherlands CASP license?

Professional fees for a Netherlands CASP license typically range from €10,000–€22,000 for legal, compliance, and consulting services, depending on application complexity and the scope of services authorized. This covers gap analysis, AML/KYC policy preparation, DORA compliance documentation, application drafting, and NCA liaison. Government application fees to DNB/AFM are an additional €5,000–€12,000.

Netherlands Crypto License | DNB CASP Authorization Under MiCA 2026

Netherlands Crypto License: CASP Authorization by DNB and AFM Under MiCA 2026

The Netherlands is one of Europe's most sophisticated financial markets — with high retail crypto adoption, strong institutional infrastructure, and dual supervision by DNB and AFM. Under MiCA, a Dutch CASP authorization carries high credibility with banks, institutional clients, and EU counterparties, while granting full EU passporting rights to all 27 member states. Government fee €5,000–€12,000. Timeline 4–6 months. Capital from €50,000.

Netherlands Crypto License Under MiCA: DNB and AFM

The Netherlands has been supervising crypto service providers since 2020, when DNB (De Nederlandsche Bank) began requiring virtual asset service providers to register under the Dutch AML Act (Wwft — Wet ter voorkoming van witwassen en financieren van terrorisme). This early supervisory experience means Dutch NCAs are well-prepared for MiCA CASP authorization.

Under MiCA Regulation (EU) 2023/1114, CASP authorization in the Netherlands is jointly administered by DNB (prudential and AML supervision) and AFM (conduct-of-business supervision). The Netherlands is the fourth-largest EU economy and has one of Europe's highest rates of crypto ownership among retail investors — making it a strategically important market for crypto service providers.

A Netherlands CASP license is particularly valued by institutional clients, traditional financial institutions, and B2B partners who prioritize regulatory credibility. The Dutch financial system's integration with major European banking networks means that a CASP authorized by DNB and AFM often has an easier path to EUR payment accounts and banking relationships than CASPs from smaller jurisdictions.

DNB/AFM Dual Supervision

The Netherlands operates a twin-peaks model of financial regulation. DNB supervises prudential matters (capital, liquidity, AML) while AFM supervises conduct (market integrity, investor protection). For MiCA CASPs, a single application is submitted — but both supervisors review relevant aspects. This dual-supervision model is similar to the UK's FCA/PRA structure and is designed to ensure both financial soundness and consumer protection.

MiCA CASP Requirements in the Netherlands

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Legal Entity

Dutch B.V. (Besloten Vennootschap) with registered office in the Netherlands. Genuine operational substance — not merely a postal address. Directors with sufficient time and competency.

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Capital (MiCA Art. 67)

€50,000 for advisory/order services · €125,000 for exchange/portfolio/transfer · €150,000 for custody/trading platform. Own funds must exceed fixed overhead provision.

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AML/KYC (Wwft + MiCA)

Full AML program meeting both Dutch Wwft requirements and MiCA Art. 92. MLRO appointment mandatory. DNB has strict AML enforcement record — robust KYC/transaction monitoring required.

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Governance

At least two senior management members, all fit-and-proper under DNB/AFM criteria. Supervisory board or non-executive directors recommended for credibility with DNB.

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DORA Compliance

ICT risk management framework, business continuity plan, incident response, and third-party service provider management per DORA Regulation applicable from January 2025.

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Client Asset Safeguarding

Segregation of client crypto-assets (MiCA Art. 70). Custody CASPs: safekeeping policy, crypto keys management policy, insurance or comparable guarantee.

Capital Requirements by Service Type

CASP Service Type	MiCA Article 67 Minimum	Own Funds Basis
Advisory on crypto-assets	€50,000	Or 25% of fixed annual overheads if higher
Reception & transmission of orders	€50,000	Or 25% of fixed annual overheads if higher
Execution of orders	€50,000	Or 25% of fixed annual overheads if higher
Placing of crypto-assets	€50,000	Or 25% of fixed annual overheads if higher
Portfolio management	€125,000	Or 25% of fixed annual overheads if higher
Exchange for fiat / other crypto	€125,000	Or 25% of fixed annual overheads if higher
Transfer services	€125,000	Or 25% of fixed annual overheads if higher
Custody & administration	€150,000	Or 25% of fixed annual overheads if higher
Operation of trading platform	€150,000	Or 25% of fixed annual overheads if higher

CASP Service Type

MiCA Article 67 Minimum

Own Funds Basis

Advisory on crypto-assets

€50,000