MiCA CASP authorisation in the Netherlands (AFM)

At a glance

Regulator: AFM (with DNB on prudential matters)
Typical timeline: ~9 to 12 months
Transitional deadline: Closed (6-month window ended around 30 June 2025, the shortest in the EU)
Fees: AFM processing €200/hour capped at €100,000; properness €700 per person; suitability €2,900 per person (reduced if previously DNB-assessed)
CASPs authorised so far: ~23
Pre-MiCA experience: DNB crypto registration since 2020

As of June 2026; figures drift and transitional dates trace to the ESMA grandfathering list. Capital is set EU-wide by service class (€50,000 / €125,000 / €150,000), not by country. Compare member states on the jurisdiction comparison and confirm exact dates on the deadlines page.

Why teams look at the Netherlands

The Netherlands pairs a pragmatic, internationally minded market with a respected supervisory tradition. Crypto firms previously registered with De Nederlandsche Bank (DNB) under the anti-money-laundering regime. Under MiCA’s crypto-asset service provider regime, applying from 30 December 2024, the Autoriteit Financiele Markten (AFM) is the authorising authority, with DNB involved on prudential matters.

The AFM has a reputation for being responsive and clear. The Netherlands suits firms that want an efficient, English-comfortable process and a credible EU regulator.

This page is informational and does not replace legal, regulatory, or tax advice. Confirm current requirements, forms, fees, and timelines directly with the AFM before acting.

The authorisation route

A firm that is not already an EU-authorised financial entity applies to the AFM for authorisation as a CASP under Article 62. A firm already authorised under EU financial law can use the lighter Article 60 notification.

Under Article 63 the AFM has 25 working days to confirm completeness and then 40 working days to decide once the file is complete. The AFM tends to give clear feedback, but a complete, well-evidenced file is still what moves the clock.

What the AFM expects

Local substance

A registered office in the Netherlands and management effectively based there under Article 59(2).

Governance and fit-and-proper

Collective crypto-asset competence and sufficient time under Article 68, with assessment of directors and qualifying shareholders.

AML and client-asset controls

The Dutch market came through a demanding DNB anti-money-laundering registration, so expect close attention to AML, sanctions, and the custody and segregation duties in Article 75.

Prudential safeguards

Own funds, an insurance policy, a comparable guarantee, or a mix under Article 67, at the higher of the class minimum or one quarter of fixed overheads.

Capital and the Article 67 question

The minimum is 50,000 euro, 125,000 euro, or 150,000 euro depending on the services you are authorised for, or one quarter of the previous year’s fixed overheads if higher. If you are weighing insurance against capital, build the evidence first: see the CASP insurance evidence pack and own funds vs insurance.

Coming from a DNB registration

Firms registered with DNB under the anti-money-laundering regime do not convert automatically to a CASP authorisation. They transition onto MiCA through a process the AFM manages. If you hold a DNB registration, confirm the current cut-off date and the exact transition steps with the AFM.

Transitional dates have moved at the member-state level. Confirm any date against current AFM guidance before planning around it.

Responsive, but evidence still wins

The AFM’s clarity helps prepared teams move efficiently. The strongest Dutch files combine genuine local substance, strong AML and custody controls carried over from the DNB era, and prudential safeguards backed by evidence.

FAQ

Is a Netherlands CASP licence valid across the EU?

Yes. A CASP authorisation passports to all 27 member states under Article 65. You authorise in the Netherlands and notify the host states before providing services there.

Does my DNB registration carry over?

Not automatically. It transitions through an AFM-managed process. Confirm the current cut-off and steps with the AFM.

How long does it really take?

The legal decision clock is 40 working days after the file is complete, plus a 25 working day completeness check. Preparing a complete file usually takes several months.