The Netherlands granted the EU's first MiCA licences in December 2024 and chose one of the bloc's shortest transitions — six months. The Dutch route splits the work between the AFM, which grants the licence, and DNB, which polices capital and shareholders. It is also one of the few with fully published price tags: €200 per hour up to €100,000 for the application, plus per-person fees for board screening. Here is the complete picture.
Published: July 2026 · Data as of 16 July 2026 · Reading time: ~9 minutes
Key Takeaways
- The AFM grants CASP authorisations and leads conduct and market-abuse supervision; DNB assesses prudential requirements and qualifying holdings under the Dutch "twin peaks" model.
- The Netherlands was the first EU regulator to accept applications (22 April 2024) and granted its first licences in December 2024 — three in that year.
- The Dutch transition was among the shortest in the EU: grandfathering for DNB-registered providers ended 30 June 2025, a full year before the EU deadline.
- Application costs are published: €200 per hour, capped at €100,000 for a licence, plus €2,900 per person for fitness and €700 for integrity screening of board members.
- The AFM warns a full application takes at least 5 to 6 months in practice; the statutory maximum is around 105 working days.
- As of July 2026 the register shows 28 Dutch-authorised CASPs; an AFM review in April 2026 found information shortcomings at a majority of the 33 CASPs it examined — "the period of leniency has ended".
The First Mover
MiCA's CASP rules apply from 30 December 2024, but the Dutch Authority for the Financial Markets (AFM) opened its doors early: from 22 April 2024 it processed licence applications so that approved firms could start on day one. By its own account it was the first European regulator to do so, and in December 2024 it granted the EU's first CASP licences — three by year-end.
That head start shows in the register:
Where Germany's curve spikes at its December 2025 deadline and France's at June 2026, the Dutch profile is flat and steady — four authorisations in December 2024, then a regular drumbeat through 2025 and 2026, reaching 28 by July 2026, third in the EU.
The Legal Plumbing: Implementation Act and a Six-Month Transition
Two Dutch acts of 11 December 2024, in force from 4 February 2025, wired MiCA into national law. The first — the Uitvoeringswet verordening cryptoactiva — amended the Financial Supervision Act (Wft) and the Economic Offences Act. The second implemented the Transfer of Funds Regulation (the crypto travel rule) in the Dutch AML act (Wwft) and, crucially, contained the transitional regime: providers registered with DNB under the old regime could continue only until 30 June 2025, or until their MiCA licence was granted or refused.
That six-month grandfathering (versus 18 months by default, per ESMA's official list) ranks among the EU's shortest — the old DNB crypto registration under the Wwft, in place since 2020, was retired barely half a year into the MiCA era, and the legacy AFM-published register formally expired on 30 June 2025.
Twin Peaks: AFM Licenses, DNB Guards Prudence
The Dutch division of labour is the cleanest expression of the "twin peaks" model applied to crypto:
| Task | Authority |
|---|---|
| Licence applications and notifications | AFM |
| Conduct supervision, market abuse (MiCA Title VI) | AFM |
| Prudential requirements in the application | DNB |
| Ongoing prudential supervision, yearly reporting | DNB |
| Qualifying holdings (declarations of no objection) | DNB |
| AML (Wwft) supervision of CASPs | AFM (since 4 Feb 2025) |
| Stablecoin (ART/EMT) issuers | DNB |
One interface trap the Dutch regulators flag explicitly: CASPs handling e-money tokens may additionally need a payment-services (PSD2) licence; supervisors committed to enforcement restraint on that point only until 1 March 2026.
The Application, Step by Step
The AFM offers a voluntary pre-scan: the applicant sends a slide deck covering its group structure, intended MiCA services, fit-and-proper candidates, risk framework, ICT/DORA plans, AML setup and asset-segregation design, then gets a one-hour online meeting with general feedback. It is explicitly not a substitute for review — but it prices in surprises early.
The application itself is filed in English on AFM forms (application form plus a checklist, integrity and suitability forms per board member, standardized CVs), submitted by secure file transfer to the AFM's crypto team. The statutory clock is MiCA's: 25 working days for completeness, 40 for assessment — around 105 working days maximum in the AFM's own arithmetic — but the regulator is unusually candid that a real application takes at least 5 to 6 months. Its published "good practices" urge applicants to do a gap analysis, design asset segregation carefully, reference supporting documents with page numbers, and apply in good time "to avoid the risk of having to cease activities".
Capital follows MiCA Annex IV — €50,000 (Class 1), €125,000 (Class 2), €150,000 (Class 3), or one quarter of fixed overheads if higher — with the details set out in DNB's prudential reporting manual for crypto providers, which also fixes the yearly reporting cycle.
What Dutch CASPs actually do clusters heavily at the custody-and-transfer end:
What It Costs
The Netherlands publishes its price list — a rarity:
| Item | Fee |
|---|---|
| Licence application | €200/hour, capped at €100,000 |
| Notification (Art. 60 route) | €200/hour, capped at €50,000 |
| Integrity (propriety) screening | €700 per person |
| Fitness (suitability) assessment | €2,900 per person (reduced to €1,500 or €500 if previously assessed by DNB) |
Ongoing supervision is funded through annual levies under the Dutch financial supervision funding act, set each year by ministerial regulation.
After the Licence: A Demanding Supervisor
Ongoing duties run to both authorities: suspicious transactions and orders (STOR) and DORA incident reports via the AFM Portal; management changes notified to the AFM in advance, with a review period of up to 4–6 months and prior approval required; changes in shareholders, outsourcing or business operations reported to the crypto team; a periodic AML questionnaire; and yearly prudential reporting to DNB.
On AML, CASPs count as "financial institutions" under the Wwft since 4 February 2025 — the AFM took over crypto AML supervision from DNB and published a dedicated CASP annex to its Wwft guideline in May 2025. The travel rule applies in full, including an obligation to identify and verify ownership of self-hosted wallets for transfers of €1,000 or more. Unusual transactions go to FIU-Nederland.
The AFM has moved quickly from onboarding to enforcement posture. In April 2026 it reviewed 33 CASPs active on the Dutch market (home-licensed and passporting): advertising shortcomings at 14, cost-information failures at 19. Dutch firms received supervisory letters; foreign firms were referred to their home regulators — with the pointed message that "the period of leniency has ended".
This article is part of our country-by-country series on MiCA licensing. See also: Germany (BaFin), France (AMF) and the full EU licence map 2026.
Frequently Asked Questions
Who grants MiCA CASP licences in the Netherlands? The AFM. DNB assesses the prudential side of the application, supervises capital on an ongoing basis, and clears qualifying shareholders.
How much does a Dutch CASP licence cost? €200 per hour up to a €100,000 cap for the application, plus €700 (integrity) and €2,900 (fitness) per board member assessed. Annual supervision levies apply after authorisation.
How long does the AFM take? The statutory maximum is about 105 working days (25 + 40 working days plus notifications and suspensions), but the AFM itself says a full application takes at least 5 to 6 months.
Can applications be filed in English? Yes — all AFM CASP application, notification and fit-and-proper forms are published in English.
What happened to the old DNB crypto registration? It ended with the Dutch transition on 30 June 2025. Since then, every crypto-asset service provider active in the Netherlands needs a MiCA authorisation (or an EU passport from another Member State).
Sources
- AFM — CASP licence (application process, English)
- AFM — CASP notification (Article 60 route, English)
- AFM — CASP pre-scan (English)
- AFM — costs of licence or notification (English)
- AFM — CASP forms (English)
- AFM — good practices for licence applications (English)
- AFM — reporting obligations for CASPs (English)
- AFM — MiCAR supervision start, 30 December 2024 (English)
- AFM — accepting crypto licence applications from 22 April 2024 (English)
- AFM — Annual Report 2024 (English, PDF)
- AFM — Wwft annex for crypto-asset service providers, May 2025 (English)
- AFM — Transfer of Funds Regulation / travel rule (English)
- AFM — press release April 2026: CASP advertising and cost information review (English)
- DNB — MiCAR (English)
- DNB — licence application for CASPs and PSD2 interplay (English)
- DNB — prudential reporting manual for crypto service providers (English, PDF)
- Wetten.overheid.nl — Uitvoeringswet verordening cryptoactiva (Dutch)
- Wetten.overheid.nl — implementation act TFR incl. transitional regime (Dutch)
- ESMA — list of MiCA grandfathering periods under Art. 143(3) (PDF)
- ESMA — Markets in Crypto-Assets Regulation (MiCA), interim register
- Regulation (EU) 2023/1114 (MiCA) — EUR-Lex
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Analysis based on official AFM, DNB, Dutch government and ESMA publications and ESMA's interim MiCA register (CASP file), 16 July 2026 snapshot. Counts are unique legal entities per home Member State.
Disclaimer: This article is provided for general information and analytical purposes only. It does not constitute legal, regulatory, investment, tax or any other form of professional advice, and it should not be relied upon as such. While we strive for accuracy, the underlying registers and regulatory frameworks are updated frequently and details may have changed since the stated data date. Always verify current information directly with official sources (ESMA, the European Commission, and national competent authorities such as the AFM and DNB) before making any decision. MICA Watch accepts no liability for any loss or damage arising from the use of this content.