🇳🇱 Crypto licence in the Netherlands

The regime

Crypto businesses serving the Dutch market need MiCA CASP authorisation from the AFM (Autoriteit Financiële Markten), which replaced the old DNB crypto registration regime that ran from 2020. The AFM handles conduct and authorisation; DNB keeps prudential and AML oversight.

The Netherlands ran one of the EU's shortest national transition windows — six months, ending 30 June 2025 — pushing firms onto full MiCA authorisation ahead of most of the bloc. That head start made the AFM one of the first regulators to authorise major exchanges, and Dutch approvals a steady source of licensing news.

Requirements

• CASP authorisation from the AFM under MiCA (Regulation (EU) 2023/1114) — one licence covering exchange, custody, brokerage, transfer and advisory services.
• Minimum own funds: €50,000 (Class 1 — reception/transmission of orders, advice, transfers), €125,000 (Class 2 — adds custody and exchange against funds) or €150,000 (Class 3 — operating a trading platform).
• Substance in the Netherlands: a registered office, effective management in the EU and at least one EU-resident director.
• Safeguarding: segregation of client crypto-assets and client funds from the firm's own book, with a custody policy.
• AML/CTF: EU framework compliance including Travel Rule originator/beneficiary data under the Transfer of Funds Regulation.
• Operational resilience: governance, conflicts, complaints, outsourcing and ICT-risk (DORA) arrangements sized to the service classes sought.

Licensed firms

Firms authorised by the AFM under MiCA include:

• Bitvavo — the largest Dutch exchange, in the AFM's first CASP cohort
• MoonPay — on-ramp provider, authorised by the AFM in 2025
• Hidden Road — prime broker, authorised by the AFM in early 2025

Snapshot, not the register: verify current status against AFM register before relying on it.

Do I need a Dutch licence if I already hold MiCA authorisation elsewhere in the EU?

Check the AFM's public register or ESMA's interim MiCA register. A CASP authorised anywhere in the EU may passport into the Netherlands, so a firm serving the Netherlands legally may hold its licence from another member state.

What happened to the old DNB crypto registration?

It was retired. DNB registrations stopped conferring the right to operate after the Dutch MiCA transition window closed on 30 June 2025; firms needed full AFM authorisation from that date.