Netherlands
Overview
The Netherlands applies MiCA through a twin-peaks model. The Authority for the Financial Markets (AFM) grants CASP authorisation and supervises conduct; De Nederlandsche Bank (DNB) is responsible for prudential requirements and for issuers of asset-referenced and e-money tokens. The national implementation, the Uitvoeringswet verordening cryptoactiva, entered into force on 4 February 2025.
The Netherlands used a six-month transition. Providers registered with DNB before 30 December 2024 needed an AFM authorisation or notification by 30 June 2025. The AFM said in December 2024 that a complete application takes at least five to six months, so the practical runway was tight.
Regulatory framework
MiCA (Regulation (EU) 2023/1114) is directly applicable. The AFM is the CASP authorisation and conduct authority; DNB covers the prudential requirements and the Title III/IV issuer regimes. The AFM supervises AML/CFT for CASPs, while DNB remains the prudential supervisor.
Certain financial entities can use the Article 60 notification route. Third-country firms can use the Article 60 own-initiative route only where the client approaches them; reverse solicitation is narrow. A Dutch authorisation passports across the EEA after the Article 62 notification.
Licensing & authorisation
Route and clock. Apply to the AFM (MiCA Arts 62–63). The authority acknowledges within 5 working days, assesses completeness within 25 working days and decides within 40 working days of a complete file; the clock stops for information requests. The AFM’s own guidance says a full application takes at least five to six months in practice; the statutory clock is not an end-to-end promise.
Charges. The AFM charges on a time basis under the Bbft fee regulation, subject to a statutory cap. There is no flat CASP application price list; confirm the current rate and cap with the AFM before filing.
Own funds. MiCA Art 67 and Annex IV set the minimum at €50,000 (Class 1), €125,000 (Class 2) or €150,000 (Class 3), plus one quarter of the previous year’s fixed overheads, held continuously. The class follows the services authorised.
Substance and passport. MiCA Art 59 requires the registered office and head office in the Netherlands. Plan for a Dutch B.V., Dutch-resident management, a local AML officer and outsourcing/ICT arrangements that meet AFM, DNB and DORA expectations. Once authorised, notify under Art 62 to passport into the EEA.
AML & Travel Rule
The EU Transfer of Funds Regulation (TFR, (EU) 2023/1113) has applied since 30 December 2024. CASP-to-CASP transfers must carry originator and beneficiary information from the first euro; transfers to or from self-hosted wallets above €1,000 require verification of the counterparty.
The AFM supervises AML/CFT for CASPs; DNB remains the prudential supervisor and FIU-Nederland receives suspicious transaction reports. DORA has applied since 17 January 2025, and the EU AML Regulation (AMLR) applies from 10 July 2027.
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