Crypto-Asset Service Provider (CASP) authorisation (Netherlands)
The Crypto-Asset Service Provider (CASP) authorisation in the Netherlands is issued by the Authority for the Financial Markets (AFM) under EU Regulation 2023/1114 (MiCA). Authorisation requires EUR 50,000 to EUR 150,000 capital depending on services, local Dutch substance, fit-and-proper leadership, and DORA compliance. Statutory review takes 40 working days after completeness, while observed processing takes at least five months. Authorised firms can passport across 30 EU/EEA states.
At a glance
| Official name | Crypto-Asset Service Provider (CASP) authorisation under Regulation (EU) 2023/1114 (MiCA)1 |
|---|---|
| Local name | CASP-vergunning |
| Also known as | CASP · AFM CASP licence · Dutch CASP licence |
| Issued by | Authority for the Financial Markets |
| Jurisdiction | Netherlands |
| Licence family | Crypto-asset service provider (MiCA CASP) |
| Legal basis | Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA)2 Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets3 |
| Passporting | EU/EEA passport available: Authorised Dutch CASPs have the right to provide crypto-asset services across all 30 EU and EEA member states through the free provision of services or branch establishment under MiCA Article 65. The applicant submits the cross-border notification template to the AFM (casp.notifications.micar@afm.nl), which forwards the file within 10 working days to host competent authorities, ESMA, and EBA at no regulatory fee. Cross-border services may commence upon notification receipt or at latest 15 calendar days after submission.4 |
| Minimum capital | EUR 50,0002 |
| Application fee | EUR 200 per hour worked by the AFM, with a statutory maximum cap of EUR 100,000 for MiCA Art. 62/63 authorisations (Bbft 2019 Bijlage 2, code EU.A1.08), EUR 50,000 cap for Art. 60 notifications (code EU.A3.08), plus EUR 700 per person for integrity assessment and EUR 2,900 for suitability assessment (or EUR 1,500 / EUR 500 if previously assessed by DNB)5 |
| Annual fee | EUR 8,000 base supervisory levy plus a turnover-based component and service modules under Regeling bekostiging financieel toezicht 2026: custody EUR 4,250; trading platform EUR 4,250; crypto-fiat exchange EUR 2,125; crypto-crypto exchange EUR 2,125; order execution EUR 4,250; placing EUR 2,125; reception/transmission EUR 2,125; advice EUR 4,250; portfolio management EUR 6,375; transfer services EUR 4,2506 |
| Statutory decision time | 25 working days completeness assessment from receipt, followed by 40 working days decision period once complete (Regulation (EU) 2023/1114 Art. 63)2 |
| Public register | official register7 |
| Current holders | 207 |
What it lets you do, and where
What does a Dutch CASP licence let you do, and where can you serve clients?
A Dutch CASP licence lets you provide crypto-asset services in other EU Member States, and throughout the Union, under the notification procedure in Article 65 MiCAR. The AFM processes cross-border passporting notifications within 10 working days, and services may commence within 15 calendar days.194
Activities it covers
| Custody and administration of crypto-assets | Safekeeping or controlling crypto-assets, or the means of access to them such as private keys, on behalf of clients. |
|---|---|
| Operating a crypto-asset trading platform | Managing a multilateral system that brings together buying and selling interests in crypto-assets so that contracts are concluded. |
| Exchange of crypto-assets for funds | Buying or selling crypto-assets against fiat money using the provider's own capital. |
| Exchange of crypto-assets for other crypto-assets | Concluding contracts with clients to swap one crypto-asset for another using the provider's own capital. |
| Execution of orders for crypto-assets on behalf of clients | Concluding agreements to buy or sell crypto-assets on behalf of clients, including subscribing to offers. |
| Placing of crypto-assets | Marketing crypto-assets to purchasers on behalf of or for the account of the offeror or a related party. |
| Reception and transmission of orders for crypto-assets | Receiving a client's order to buy or sell crypto-assets and passing it to a third party for execution. |
| Advice on crypto-assets | Giving personalised recommendations to a client about transactions in crypto-assets or the use of crypto-asset services. |
| Portfolio management of crypto-assets | Managing portfolios that include crypto-assets on a discretionary, client-by-client basis under a mandate. |
| Transfer services for crypto-assets | Moving crypto-assets on behalf of a client from one distributed-ledger address or account to another. |
Where it is valid
Do you need it, and is Netherlands the right choice?
What is a Dutch MiCA CASP licence and do you actually need one?
Yes. A Dutch CASP licence is the authorisation under Article 63 MiCAR for providing crypto-asset services. Article 59 requires it, or a notification under Article 60, to offer crypto-asset services in the EU, and services not defined there are not covered. Under the Dutch MiCA Implementation Act, MiCAR violations are economic offences under the Economic Offences Act (Wed).12627
Is a Dutch CASP licence right for your model, and what are the alternatives?
It depends on your firm type and timeline. The AFM states that even best-case authorisation applications take at least five months and often longer. Credit institutions, CSDs and investment firms can use the Article 60 route instead: they notify their home national competent authority at least 40 working days beforehand and need no authorisation.126
Can one Dutch CASP licence cover the whole EU, and how does passporting work?
Yes. Under Article 65 MiCA, an AFM-authorised CASP can passport its services to other EU Member States. The firm submits the MiCAR cross-border notification template to casp.notifications.micar@afm.nl. The AFM charges no costs and informs the host regulators, ESMA and EBA within 10 working days. Services can start from the date the host authority receives the notification, or at the latest 15 calendar days after submission. Under the ESMA reverse solicitation guidelines, a disclaimer cannot justify unlicensed outreach.2428
Issuing EMTs requires authorisation as a credit institution or electronic money institution under Article 48 MiCA. DNB supervises stablecoin issuers (EMTs and ARTs) and carries out prudential supervision of CASPs under the Twin Peaks model.1929
Not on the AFM's own account: it cautions that processing takes at least five months even in best-case scenarios. The fast-track scrutiny concerns Malta. ESMA launched a fast-track peer review into Malta's MFSA on rapid authorisations and supervisory consistency, and industry media highlighted criticism of rapid 4-day Malta approvals and the European supervisory scrutiny that followed.13031
Crypto advisory and execution services fall within the mandatory licensing perimeter under Article 63 MiCAR, as the AFM defines it. Recital 22 MiCAR exempts fully decentralised services provided without intermediaries, but front-ends with control are captured.132
Article 75(8) MiCAR makes custodial CASPs liable for loss of crypto-assets or means of access resulting from an incident attributable to them, capped at the market value at the time of loss. The RTS drafted by ESMA (Commission Delegated Regulation (EU) 2025/305) require CASP applicants to submit a custody policy and arrangements that comply with Article 75(8) MiCA. The AFM's Good Practices cover designing asset segregation procedures to protect client ownership rights.29
What it really takes
How much capital do you really need for a Dutch CASP licence?
Article 67 and Annex IV MiCA set a permanent minimum capital of €50,000, €125,000 or €150,000, or one quarter of fixed overheads. Prudential safeguards can be met with own funds made up of CET1 items under Articles 26 to 30 CRR, after full Article 36 deductions, or with an insurance policy or comparable guarantee.226
Who do you have to hire for a Dutch CASP licence, and where must they be based?
The people in charge of day-to-day operations and the members of the supervisory board must pass AFM fit-and-proper testing. Under Article 59(2) MiCAR, the place of effective management must be in the EU and at least one director must be resident in the EU. The AFM also supervises compliance with money laundering, terrorist financing and sanctions rules.128
In which language must the application and documents be filed with the AFM?
Applicants submit the AFM's CASP licence application form, the checklist and the supporting documentation via Cryptshare, addressed to crypto@afm.nl.116
Requirements
| Requirement | What is needed | Legal reference |
|---|---|---|
| Capital and people assessed | ||
| Minimum capital | EUR 50,0002 | |
| Ongoing own funds | Ongoing own funds must at all times equal or exceed the higher of the permanent minimum initial capital requirement (EUR 50,000, EUR 125,000, or EUR 150,000) or one quarter (25%) of the preceding year's fixed overheads under MiCA Article 67(1). Capital must consist of Common Equity Tier 1 (CET1) items under CRR Articles 26-30. Prudential safeguards may partially be satisfied through an eligible professional indemnity insurance policy or equivalent guarantee under Article 67(4).2 | MiCA Article 67(1) CRR Articles 26-30 Article 67(4) |
| Who is assessed | The AFM (in consultation with DNB where relevant) assesses the fitness and propriety (suitability and integrity) of day-to-day policymakers (executive directors, management board), supervisory board members, key function holders (Compliance Officer, MLRO, Risk Officer), and qualifying shareholders holding 10% or more of capital or voting rights, or exercising significant influence, including ultimate beneficial owners (UBOs), pursuant to MiCA Article 68 and Joint EBA/ESMA Guidelines. Properness vetting costs EUR 700 per person and standard suitability vetting costs EUR 2,900 per person.5 | MiCA Article 68 |
| Substance and people | ||
| Registered office and operational presence in the Netherlands | The CASP must have its registered office in the Netherlands where it carries out at least part of its crypto-asset services, and its place of effective management within the EU, with at least one executive director resident in the EU.2 | MiCA Article 59(2) |
| Four-eyes governance and fit-and-proper management | The management body must operate under a four-eyes governance model with day-to-day policymakers and supervisory board members who are fit, proper, and of good repute under MiCA Article 68(1) and Joint EBA/ESMA Guidelines, collectively possessing adequate knowledge, skills, and time commitment.1 | MiCA Article 68(1) |
| Anti-money laundering compliance, MLRO, and sanctions screening | CASPs must maintain internal policies, systems, and controls to prevent money laundering and terrorist financing under the Dutch Wwft and EU Transfer of Funds Regulation (EU) 2023/1113 (TFR), including appointing a qualified Compliance Officer / MLRO and ensuring compliance with the Sanctions Act 1977.8 | |
| Client crypto-asset safeguarding and fiat segregation | CASPs must implement strict organizational arrangements to safeguard client property rights. Client fiat funds must be segregated in dedicated accounts with a central bank or authorized credit institution, and client crypto-assets must be held in segregated wallet addresses legally ring-fenced from proprietary assets and protected against creditor claims in insolvency.9 | MiCA Article 70 |
| Digital operational resilience and ICT security (DORA) | CASPs must deploy sound ICT risk management frameworks, robust cryptographic key management, business continuity protocols, and cyber incident reporting mechanisms.10 | MiCA Article 68(6) |
| Conditions to keep the licence | ||
| Activity commencement deadline | The AFM may withdraw a CASP authorisation if the provider does not start using its licence within 12 months from the date the authorisation is granted.2 | MiCA Article 64(1)(a) |
| Dormancy revocation | The AFM may withdraw authorisation if the CASP has expressly renounced its authorisation, or has not provided crypto-asset services for nine consecutive months.11 | MiCA Article 64(1)(b) |
| No interest on asset-referenced or e-money tokens | A CASP must not grant interest, or any other benefit tied to how long a client holds the tokens, on asset-referenced tokens or e-money tokens (MiCA Articles 40(2) and 50(2)).2 | MiCA Articles 40(2) and 50(2)) |
| Client asset segregation and bankruptcy remoteness | Client crypto-assets and funds must be segregated from the provider's own corporate assets, held in designated accounts or separate blockchain addresses, and cannot be used for the firm's own account or claimed by corporate creditors in insolvency.2 | MiCA Article 70 |
| Market abuse prevention and surveillance | CASPs must establish and maintain effective arrangements, systems, and procedures to prevent and detect market abuse, insider dealing, and market manipulation, reporting suspicious transactions and orders to the AFM without delay.2 | Articles 86-92) |
| Ongoing supervisory reporting and fee payment | Regulated CASPs must submit regular prudential and conduct reports to the AFM, maintain ongoing compliance with DORA ICT resilience standards, report material operational or governance changes, and pay the annual supervisory contribution under the Regeling bekostiging financieel toezicht.5 | |
The legal framework
| Level | Document | What it does here |
|---|---|---|
| EU law | Markets in Crypto-Assets Regulation | Directly applicable EU regulation establishing the CASP authorisation regime, scope, operating conditions, capital, governance, conduct of business, refusal grounds, and passporting (Title V, Arts. 59-75, 83-84, 94) |
| Act | Wet op het financieel toezicht (Wft) | Primary financial supervision statute in the Netherlands; designates general regulatory mandates of AFM and DNB (Arts. 1:24, 1:25), integrates MiCA supervisory intervention powers (Art. 1:77n), and administrative fine and penalty payment enforcement (Arts. 1:79, 1:80) |
| Act | Wet van 11 december 2024 tot wijziging van de Wet op het financieel toezicht en de Wet op de economische delicten ter uitvoering van Verordening (EU) 2023/1114 betreffende cryptoactivamarkten (Uitvoeringswet verordening cryptoactiva) (Stb. 2024, 415) | Dutch MiCA implementation act; defines verordening cryptoactiva in Wft Art. 1:1, enacts Art. 1:77n supervisory powers, and amends Economic Offences Act (Wed) to establish criminal sanctions for unlicensed CASP operations and crypto market abuse |
| Act | Wet van 11 december 2024 tot wijziging van de Wet ter voorkoming van witwassen en financieren van terrorisme en enige andere wetten in verband met de uitvoering van Verordening (EU) 2023/1113 (Uitvoeringswet verordening bij geldovermakingen en overdrachten van cryptoactiva te voegen informatie) (Stb. 2024, 414) | Dutch implementation act for the EU Travel Rule; embeds Regulation (EU) 2023/1113 into Wwft, Wft, and Wed, and repeals the former Wwft Chapter 3A registration regime for crypto exchange/custody service providers |
| Act | Wet op de economische delicten (Wed) | Criminalises offering crypto-asset services without MiCA authorisation (Art. 59(1)), breaching cross-border rules (Art. 65(1)), capital breaches (Art. 67(1),(4)), and crypto market abuse (Arts. 88-92) under Art. 1(1°) and (2°) |
| Secondary legislation | Besluit van 11 december 2024 tot wijziging van het Besluit EU-verordeningen Wft en enkele andere besluiten in verband met de uitvoering van Verordening (EU) 2023/1114 betreffende cryptoactivamarkten en Verordening (EU) 2023/1113... (Uitvoeringsbesluit MiCA en TFR) (Stb. 2024, 404) | Inserts Bijlage 36 into Besluit EU-verordeningen Wft, designating AFM for CASP authorisation and conduct supervision (MiCA Arts. 59-66, 68-82) and DNB for own funds (Art. 67) and qualifying holdings (Arts. 83-84); exercises Member State option under Art. 143(3) to end the CASP transition on 30 June 2025 |
| Secondary legislation | Besluit EU-verordeningen Wft | Governmental decree allocating supervisory competences and administrative enforcement powers between AFM and DNB for EU financial regulations, including MiCA in Bijlage 36 |
| Secondary legislation | Besluit bestuurlijke boetes financiële sector | Sets the administrative fine categories, base amounts and maximum fines under Wft Art. 1:81; Besluit EU-verordeningen Wft (Bijlage 36) applies them to MiCA breaches |
| Regulator rules | Beleidsregel geschiktheid 2012 (Stcrt. 2012, 13546) | AFM and DNB binding policy rule setting suitability assessment criteria, competency matrix, and screening standards for management body and supervisory board members |
| Procedure law | Algemene wet bestuursrecht (Awb) | Governs administrative decision-making, filing languages and translations (Art. 2:6, Art. 6:5(3)), default notices and remedies against failure to decide (Arts. 4:17, 6:2(b), 6:12, 8:55d), internal objection before AFM (bezwaar, Art. 7:1, 6-week deadline), and judicial appeal (beroep, Art. 8:1) |
| Procedure law | Wet bestuursrechtspraak bedrijfsorganisatie / Bijlage 2 bij de Awb (Bevoegdheidsregeling bestuursrechtspraak) | Vests exclusive judicial review over AFM and DNB financial supervisory decisions in the District Court of Rotterdam (Rechtbank Rotterdam, sector bestuursrecht) with higher appeal to the Trade and Industry Appeals Tribunal (College van Beroep voor het bedrijfsleven - CBb) |
| Fee schedule | Wet bekostiging financieel toezicht 2019 (Wbft 2019) | Primary statute empowering the Minister of Finance and financial supervisors (AFM and DNB) to levy application fees for one-off supervisory acts and annual supervisory levies on financial institutions (Art. 14(2)) |
| Fee schedule | Regeling bekostiging financieel toezicht eenmalige handelingen | Sets statutory fee schedule: CASP licence application at €200/hr (max €100,000, Item EU.A1.08), reliability check at €700 (Item EU.A8.08), suitability check at €2,900/€1,500/€500 (Items EU.A8.09-11), qualifying shareholder check at €1,100 (Item EU.D1.06), and change of control assessment at €1,600 (Item EU.D1.07), amended by Stcrt. 2024, 21638 |
| Technical standards | Commission Delegated Regulation (EU) 2025/305 of 31 October 2024 supplementing Regulation (EU) 2023/1114 with regard to regulatory technical standards specifying the information to be included in an application for authorisation as a crypto-asset service provider | Specifies detailed information, business plans, governance policies, ICT systems, and documentation required in a CASP authorisation application under MiCA Art. 62(5) |
| Technical standards | Commission Implementing Regulation (EU) 2025/306 of 31 October 2024 laying down implementing technical standards for the application of Regulation (EU) 2023/1114 with regard to standard forms, templates and procedures for the information to be included in the application for authorisation of crypto-asset service providers | Prescribes mandatory standard forms, templates, and procedures for CASP authorisation applications under MiCA Art. 62(6) |
| Technical standards | Commission Delegated Regulation (EU) 2025/303 of 31 October 2024 supplementing Regulation (EU) 2023/1114 with regard to regulatory technical standards specifying the information to be provided by certain financial entities in the notification to provide crypto-asset services | Specifies notification information requirements for already licensed financial entities providing crypto-asset services under MiCA Art. 60(7) |
| Technical standards | Commission Implementing Regulation (EU) 2025/304 of 31 October 2024 laying down implementing technical standards with regard to standard forms, templates and procedures for the notification to provide crypto-asset services | Prescribes standard templates and procedures for financial entities notifying crypto-asset services under MiCA Art. 60(8) |
| Technical standards | Commission Delegated Regulation (EU) 2025/414 of 18 December 2024 supplementing Regulation (EU) 2023/1114 with regard to regulatory technical standards specifying the detailed content of information necessary to carry out the assessment of a proposed acquisition of a qualifying holding in a crypto-asset service provider | Specifies detailed information, questionnaires, and notification files required for acquiring or increasing qualifying holdings in a CASP under MiCA Art. 84(4) |
| Technical standards | Commission Delegated Regulation (EU) 2025/299 of 31 October 2024 supplementing Regulation (EU) 2023/1114 with regard to regulatory technical standards on continuity and regularity in the performance of crypto-asset services | Specifies business continuity policy and operational resilience requirements for CASPs under MiCA Art. 68(10) |
| Technical standards | Commission Implementing Regulation (EU) 2025/294 of 24 October 2024 laying down implementing technical standards with regard to standard forms, templates and procedures for the handling of complaints by crypto-asset service providers | Prescribes complaints-handling procedures, languages, and standard templates for CASPs under MiCA Art. 71(5) |
| Technical standards | Commission Delegated Regulation (EU) 2025/1140 supplementing Regulation (EU) 2023/1114 with regard to regulatory technical standards specifying the records of all crypto-asset services, activities, orders and transactions undertaken | Specifies CASP order and transaction record-keeping requirements under MiCA Art. 68(10) |
| Technical standards | Commission Delegated Regulation (EU) 2025/1142 supplementing Regulation (EU) 2023/1114 with regard to regulatory technical standards specifying requirements on conflicts of interest policies and procedures for crypto-asset service providers | Specifies conflicts of interest policies, procedures, and client disclosures for CASPs under MiCA Art. 72(5) |
| Forms | AFM CASP Licence Application Form and Supporting Documentation Checklists | Mandatory AFM application dossier template (Word docx based on MiCA Art. 62 / CDR 2025/305 / CIR 2025/306) and checklist (Excel), alongside fitness and propriety forms for management body members |
14 related regimes and guidance documents
| Level | Document | What it does here |
|---|---|---|
| Guidance | Joint EBA and ESMA Guidelines on the suitability assessment of the members of the management body of issuers of ARTs and CASPs (EBA/GL/2024/09 / ESMA75-453128700-10) | European supervisory guidelines setting criteria and methodology for evaluating fit and proper requirements for CASP management body members and qualifying shareholders under MiCA Arts. 63(11) and 68 |
| Guidance | ESMA Supervisory Briefing on the Authorisation of CASPs under MiCA (ESMA75-453128700-1263) | Supervisory convergence guidance outlining common EU expectations on substance, governance, outsourcing, and assessment framework for CASP applications under MiCA Arts. 62-63 |
| Guidance | AFM Good practices voorbereiden vergunningsaanvraag | AFM supervisory guidance outlining best practices for CASP application preparation, scope analysis, gap analysis, DORA compliance, client fund safeguarding, and pre-scan engagement |
| Guidance | AFM & DNB Vragen en antwoorden MiCAR / Q&A Cryptopartijen | AFM supervisory guidance clarifying substance, OTC trading client relationships under ESMA QA 2293, custody segregation through separate legal entity (stichting derdengelden), and DORA documentation |
| Related regime | Digital Operational Resilience Act | Directly applicable EU regulation governing ICT risk management, incident classification and reporting, digital operational resilience testing, and third-party ICT service provider oversight directly binding on CASPs (Art. 2(1)(p); MiCA Art. 68(6)) |
| Related regime | Implementatiewet digitale operationele weerbaarheid (Stb. 2024, 357) en Uitvoeringsbesluit verordening digitale operationele weerbaarheid (Stb. 2024, 379) | Dutch implementation act and decree integrating DORA supervisory and enforcement powers into the Wft and designating AFM and DNB as competent authorities |
| Related regime | Transfer of Funds Regulation (travel rule) | Imposes originator and beneficiary information transmission, verification, and recording obligations on CASPs facilitating crypto-asset transfers |
| Related regime | Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft) | Designates CASPs as obliged financial institutions under Art. 1a, imposing mandatory customer due diligence, transaction monitoring, and reporting of unusual transactions to FIU-Nederland; supervised by AFM and DNB under Art. 24 |
| Related regime | Sanctiewet 1977 | Requires CASPs to maintain screening measures, immediately freeze funds and crypto-assets of designated persons or entities under national and international sanctions, and report hits to supervisory authorities |
| Related regime | Fourth Anti-Money Laundering Directive (as amended by the fifth, 2018/843) | EU framework directive on AML/CFT transposed into Dutch national law primarily through the Wwft |
| Related regime | Anti-Money Laundering Regulation (single rulebook) partly in force | EU single rulebook regulation establishing directly applicable customer due diligence, internal control, and reporting requirements for obliged entities including CASPs from 10 July 2027 |
| Related regime | Capital Requirements Regulation | Defines Common Equity Tier 1 (CET1) capital items cross-referenced by MiCA Art. 67 for CASP own funds requirements |
| Related regime | Directive 2014/65/EU on markets in financial instruments | Establishes boundary between crypto-derivatives qualifying as financial instruments and MiCA crypto-assets; authorized MiFID II firms can provide crypto services via MiCA Art. 60 notification |
| Related regime | Directive (EU) 2015/2366 on payment services in the internal market | Governs fiat payment services that may overlap with crypto services (custody, transfer, placement); CASPs providing payment services must hold a separate PSD2 licence or partner with an authorized payment service provider (MiCA Art. 70(4)) |
The procedure under the law
| Step | What the law says | Legal reference |
|---|---|---|
| How to file | The CASP licence application is submitted by sending the completed forms, checklist and accompanying management letter via Cryptshare to crypto@afm.nl. The AFM states that files can only be exchanged with it through Cryptshare.1314 | Algemene wet bestuursrecht (Awb), art. 2:15; Wet op het financieel toezicht (Wft), art. 1:24, 1:25 |
| Language | MiCA recital 25 only addresses crypto-asset white papers and trading-platform operating rules, which must be drawn up in at least one official language of the home or host Member State, or in a language customary in international finance (English at adoption). No filing-language or translation requirement for the application itself is given.15 | |
| What the application contains | The application is submitted via Cryptshare to crypto@afm.nl and must include a cover note, management letter, attention points, a documentation overview, the CASP authorisation form (covering general information, programme of operations, governance, risk management/compliance incl. IT/DORA, business continuity, segregation of funds, AML/Sanctions incl. TFR, prudential safeguards) and the Checklist CASP-license application. For each board and supervisory board member, fitness and probity documents are required. The information to be included is specified by Commission Delegated Regulation (EU) 2025/305.131617 | Regulation (EU) 2023/1114, Art. 62; Commission Delegated Regulation (EU) 2025/305, Arts. 1-21; Commission Implementing Regulation (EU) 2025/306, Annexes I-IV; AFM Checklist CASP-license application |
| Decision clock | AFM acknowledges the application within 5 working days and has 25 working days to check completeness. The 40-working-day assessment period starts when AFM notifies the applicant the file is complete. AFM may ask for further information within 20 working days; the clock is then suspended, for no more than 20 working days, until the reply. AFM decides and notifies within 5 working days. The maximum total is 105 working days (~5 months), often longer. Consequences of silence are not stated.11819 | |
| Fees set by law | AFM application processing fee for CASP authorisation (Behandeling van een aanvraag tot verlening van een vergunning, MiCAR art. 62(1)): EUR 200 per hour (max 100000); AFM reliability assessment per management body member (Betrouwbaarheidstoets lid leidinggevend orgaan, MiCAR art. 68(1)): EUR 700; AFM suitability assessment per management body member (Geschiktheidstoets lid leidinggevend orgaan, MiCAR art. 68(1); reduced to €1,500 or €500 if previously assessed by DNB under Wwft Chapter 3A): EUR 2,900; DNB reliability assessment per qualifying shareholder/member in CASP (Betrouwbaarheidstoets aandeelhouder met een gekwalificeerde deelneming, MiCAR art. 68(2)): EUR 1,100; DNB assessment of proposed acquisition of qualifying holding / change of control in CASP (Beoordeling voorgenomen verwerving, MiCAR art. 83(1)): EUR 1,600; AFM fee for variation/extension of CASP authorisation (Behandeling aanvraag tot wijziging van vergunning, MiCAR art. 62(1)): EUR 200 per hour (max 100000)2021 | Regeling bekostiging financieel toezicht eenmalige handelingen (Stcrt. 2024, 21638), art. 4(3) onderdelen EU.A1.08, EU.A2.08, EU.A8.08-11 en art. 5 onderdeel EU.D1.06-07; Wet bekostiging financieel toezicht 2019, art. 14(2) |
| Grounds for refusal | Under MiCA Art. 63(10), competent authorities must refuse CASP authorisation where objective and demonstrable grounds exist that: (a) the management body threatens effective, sound and prudent management, business continuity, client interests or market integrity, or exposes the applicant to serious money laundering or terrorist financing risk; (b) management body members fail Art. 68(1) criteria; (c) qualifying shareholders fail Art. 68(2) good repute criteria; or (d) the applicant fails or is likely to fail any Title V requirements. Authorities must also refuse where third-country close links hinder supervision (Art. 63(8)).1519 | |
| Appeal | They show only that the College van Beroep voor het bedrijfsleven (CBb) is a supreme administrative court handling financial supervision cases and acting both as first-instance and appeal judge, and that the Algemene wet bestuursrecht contains chapters on objection (bezwaar) and appeal (beroep). No body, deadline or legal basis for appealing a refusal is stated.222324 | Algemene wet bestuursrecht (Awb), art. 6:7, 6:8, 7:1 (6-week / 42-day deadline for filing bezwaarschrift with AFM against first-instance decision); Wet op het financieel toezicht (Wft) and Bijlage 2 bij de Awb (Bevoegdheidsregeling bestuursrechtspraak), art. 8:7 Awb (6-week deadline for judicial review before Rechtbank Rotterdam); Wet bestuursrechtspraak bedrijfsorganisatie, art. 4 (6-week deadline for higher appeal before CBb) |
| Validity | None of the governing texts held for this licence (Markets in Crypto-Assets Regulation; Markets in Crypto-Assets Regulation; Transfer of Funds Regulation (travel rule); Transfer of Funds Regulation (travel rule); Bank Act 1998; Bank Act 1998; Decree on the Funding of Financial Supervision 2019; Decree on the Funding of Financial Supervision 2019; Money Laundering and Terrorist Financing (Prevention) Act; Regulation on the Funding of Financial Supervision 2026; Regulation on the Funding of Financial Supervision 2026; Trust Offices Supervision Act 2018; Trust Offices Supervision Act 2018; Act on the Funding of Financial Supervision 2019; Act on the Funding of Financial Supervision 2019) contains a provision on a fixed term or expiry of the licence. | |
| Change of control | A change of control requires prior approval: the acquirer must notify the competent authority before acquiring a qualifying holding. The authority acknowledges receipt in writing within 2 working days and then has 60 working days to assess. It may request further information by working day 50, suspending the clock for up to 20 working days (extendable to 30 if the acquirer is outside the EU or not regulated). If the authority does not oppose within the assessment period, the acquisition is deemed approved.1525 | |
| Reapplying after a refusal | MiCA Article 63 covers assessment, grant or refusal but sets no re-application delay. The only re-submission rule found concerns incomplete Article 60 notifications by financial entities: ESMA says the entity should withdraw and submit a new, complete application, again subject to the standard timelines. | |
| Serving other countries | Yes: passporting. Under Article 65(1) of MiCAR (Regulation (EU) 2023/1114), a Dutch CASP may serve clients in other EU Member States by notifying the AFM using the "MiCAR template for cross-border notifications". Crypto-asset service providers may provide services throughout the Union through the right of establishment, including a branch, or the freedom to provide services, with no physical presence required in the host state. Within ten working days the AFM informs the host authority, ESMA and EBA; services may then start.415 |
How long it takes
How long does a Dutch CASP licence actually take?
In the AFM's statutory procedure the completeness check takes 25 working days and the assessment period 40 working days. The AFM warns applicants that even in a best-case scenario the review takes at least five months, and often longer.1
How long may the AFM take by law, and what stops the clock?
The AFM acknowledges an application within 5 working days and has 25 working days to check completeness. If it is incomplete, the AFM sets a deadline of 5 to 20 working days for the missing information and may refuse an application still incomplete after that. Once complete, a 40-working-day assessment period starts. The AFM requests any further information within 20 working days, then decides and notifies you within 5 working days. The statutory maximum is about 105 working days (five months).115
Statutory: 25 working days completeness assessment from receipt, followed by 40 working days decision period once complete (Regulation (EU) 2023/1114 Art. 63)2. Observed: At least 5 months in practice, often longer: 'even in a best-case scenario it will take at least five months. In practice, it will often take longer.'1. The statutory clock usually starts only when the regulator treats the application as complete, and pauses while it waits for answers to its questions.
What it costs
What does a Dutch CASP licence cost in total?
The AFM bills CASP application processing at an hourly rate of €200, up to a statutory cap of €100,000 under Dutch financial supervision rules. Fees for vetting come on top of that.5
Approval odds and who can own it
What are the real approval odds for a Dutch CASP licence, and why do applications fail?
The official AFM crypto register lists all crypto-asset service providers that have obtained an authorisation or notification from the AFM or another EU Member State. Two cases show what failure looks like. Public prosecutors requested bankruptcy for the cryptocurrency broker Knaken to protect customers locked out of their funds. DNB fined OKX €2.25 million for historically providing unlicensed crypto services in the Netherlands without Wwft registration.73334
Shareholders and management face suitability and integrity vetting under the joint EBA/ESMA Guidelines. Reaching a qualifying holding of 20%, 30% or 50%, or making the CASP a subsidiary, triggers notification and assessment under Article 83 MiCAR. In the Netherlands, Article 3:95 Wft also requires a prior Declaration of No Objection (VVGB) from DNB before a qualifying holding is acquired.235
How many MiCA CASP licences has the AFM actually granted?
The official AFM crypto register lists all crypto-asset service providers that have obtained an authorisation or notification from the AFM or another EU Member State, so its entries are not limited to licences granted by the AFM.7
After you get the licence
A CASP that also provides PSD2 payment services must follow the PSD2 rules, and DNB is the primary PSD2 supervisor unless an exemption applies. Issuing EMTs requires authorisation as an EMI or credit institution (Article 48 MiCA). Issuing ARTs requires authorisation as an ART issuer under Article 21 MiCA, or being a credit institution (Article 16). DNB supervises prudential requirements, stablecoin issuers and payment institutions, alongside the AFM's conduct oversight.36229
Will you get a bank account and payment processing as a Dutch CASP?
Article 70(3) MiCAR requires clients' funds other than e-money tokens to be placed with a credit institution or a central bank and held in a separately identifiable account. The AFM's Good Practices advise contacting the AFM early on high-impact matters, including scoping, control structures and asset segregation procedures.199
Under Article 64 MiCAR, authorisation must be withdrawn if it is not used within 12 months or if no crypto-asset services are provided for nine consecutive months. Regulated entities pay annual supervisory levies and must stay compliant under the Dutch supervisory decrees. From 23 December 2025, the ESMA taxonomy requires crypto-asset white papers to be filed in iXBRL/XBRL electronic format.23738
Can you appeal an AFM refusal, to whom and by when?
The Trade and Industry Appeals Tribunal (CBb) is the final appellate court for financial regulatory disputes in the Netherlands.24
The licence has no fixed term. Articles 64 and 83 MiCAR govern revocation triggers and the prior assessment of changes of control. Before starting cross-border services, the firm must notify the AFM in advance at casp.notifications.micar@afm.nl. The Regeling bekostiging financieel toezicht eenmalige handelingen sets a €2,400 fee (item EU.D1.07) for assessing a proposed qualifying-holding acquisition in a CASP.4239
Is your old Dutch crypto registration still valid, what happened after the transitional deadline?
No. Firms registered with DNB could use the MiCAR transitional regime in the Netherlands until 30 June 2025, and according to AFM guidance legacy crypto registrations ceased to be valid when the Dutch transitional window expired on 30 June 2025. A Dutch court declared Rotterdam-based Knaken bankrupt after it ran without a MiCA licence; prosecutors say about $8 million (EUR 7 million) of customer money vanished.740
Buying a company that already holds it
The CASP authorisation is granted strictly to the specific legal entity (typically a Dutch B.V. or N.V.) that applied and cannot be sold, transferred, or assigned to another entity. Any commercial acquisition of the regulated business must occur through a corporate share transaction (share deal), subject to prior qualifying holding notification and assessment under MiCA Article 83. An asset deal requires the purchasing entity to apply for and obtain its own separate CASP licence from the AFM.2
Prior approval required. In the Netherlands' Twin Peaks supervisory architecture, change of control and qualifying holdings (gekwalificeerde deelnemingen) are strictly regulated. Any natural or legal person proposing to acquire, increase, or divest a qualifying holding, defined as a direct or indirect holding of at least 10%, 20%, 33% (or 30%), or 50% of voting rights or capital, or the ability to exercise significant influence/control, in an investment firm or fund manager governed by the Wft must obtain a prior Declaration of No Objection (Verklaring van geen bezwaar - VVGB) from De Nederlandsche Bank (DNB) under Wft Article 3:95, with DNB consulting the AFM on conduct-of-business aspects. For crypto-asset service providers (CASPs) under Regulation (EU) 2023/1114 (MiCA Article 83), proposed acquisitions of qualifying holdings require prior assessment and approval by the competent supervisor (AFM charges EUR 2,400 per assessment under Bbft 2019 code EU.D1.07). The statutory assessment period is 60 working days from written acknowledgement of receipt of a complete filing, interruptible once by up to 20 or 30 working days if additional information is required from the proposed acquirer.12
Ready-made companies holding this licence: see verified positions.
CASP in other countries
| Country | Licence | Regulator | Min. capital | Application fee | Statutory time |
|---|---|---|---|---|---|
| Cyprus | Notification by financial entities providing crypto-asset servicesNotification by financial entities providing crypto-asset services under MiCAR Article 60 | CySEC | n/a | EUR 10,000 | ~1.8 mo |
| Cyprus | Crypto-Asset Service Provider (CASP) authorisationCrypto-Asset Service Provider (CASP) authorisation under MiCAR Article 63 | CySEC | EUR 50,000 | EUR 5,000 | ~1.8 mo |
| Czech Republic | Crypto-Asset Service Provider authorisationCrypto-Asset Service Provider authorisation under MiCA and Act No. 31/2025 Coll. | CNB | EUR 50,000 | CZK 20,000 | ~3 mo |
| Estonia | Authorisation to operate as a crypto-asset service providerAuthorisation to operate as a crypto-asset service provider under MiCA | FI | n/a | EUR 3,000 | ~3.9 mo |
| France | Crypto-asset service provider authorizationCrypto-asset service provider authorization under EU MiCA Regulation | AMF | n/a | n/a | ~1.8 mo |
| Germany | Crypto-asset service provider licence | BaFin | n/a | n/a | ~1.8 mo |
| Ireland | Crypto-Asset Service Provider Authorisation | CBI | n/a | n/a | ~1.8 mo |
| Italy | Crypto-asset service provider (CASP) authorization | CONSOB | n/a | EUR 20,000 | ~1.8 mo |
| Latvia | Crypto-asset service provider licenceCrypto-asset service provider licence under MiCA | LB | EUR 50,000 | EUR 2,500 | ~3 mo |
| Lithuania | Crypto-asset service provider licence | LB | EUR 50,000 | EUR 2,425 | ~3 mo |
| Luxembourg | Crypto-asset service provider authorisationCrypto-asset service provider authorisation under MiCA Regulation | CSSF | n/a | EUR 30,000 | ~1.8 mo |
| Malta | Crypto-Asset Service Provider authorisationCrypto-Asset Service Provider authorisation under Regulation (EU) 2023/1114 | MFSA | EUR 50,000 | EUR 10,000 | ~1.8 mo |
| Netherlands | Crypto-Asset Service Provider (CASP) authorisationCrypto-Asset Service Provider (CASP) authorisation under Regulation (EU) 2023/1114 (MiCA) | AFM | EUR 50,000 | EUR 200 | ~3 mo |
| Poland | Crypto-Asset Service Provider authorizationCrypto-Asset Service Provider authorization under MiCA | KNF | EUR 50,000 | n/a | ~3 mo |
| Slovakia | Crypto-asset service provider licenceCrypto-asset service provider licence under MiCA | NBS | EUR 50,000 | EUR 1,700 | ~3 mo |
| Spain | Crypto-asset service provider authorization | CNMV | n/a | n/a | ~1.8 mo |
Values come from each licence's page, where every figure has its source.
Laws behind it
- Markets in Crypto-Assets Regulation: Regulation (EU) 2023/1114
- Transfer of Funds Regulation (travel rule): Regulation (EU) 2023/1113
Getting this licence
Protegra handles this licence end to end: CASP license in the Netherlands: process, timeline and our fee.
Frequently asked questions
What is a Dutch MiCA CASP licence and do you actually need one?
Yes. A Dutch CASP licence is the authorisation under Article 63 MiCAR for providing crypto-asset services. Article 59 requires it, or a notification under Article 60, to offer crypto-asset services in the EU, and services not defined there are not covered. Under the Dutch MiCA Implementation Act, MiCAR violations are economic offences under the Economic Offences Act (Wed).
How much capital do you really need for a Dutch CASP licence?
Article 67 and Annex IV MiCA set a permanent minimum capital of €50,000, €125,000 or €150,000, or one quarter of fixed overheads.
How long does a Dutch CASP licence actually take?
In the AFM's statutory procedure the completeness check takes 25 working days and the assessment period 40 working days.
What does a Dutch CASP licence cost in total?
The AFM bills CASP application processing at an hourly rate of €200, up to a statutory cap of €100,000 under Dutch financial supervision rules.
What are the real approval odds for a Dutch CASP licence, and why do applications fail?
The official AFM crypto register lists all crypto-asset service providers that have obtained an authorisation or notification from the AFM or another EU Member State.
What does a Dutch CASP licence let you do, and where can you serve clients?
A Dutch CASP licence lets you provide crypto-asset services in other EU Member States, and throughout the Union, under the notification procedure in Article 65 MiCAR.
Will you get a bank account and payment processing as a Dutch CASP?
Article 70(3) MiCAR requires clients' funds other than e-money tokens to be placed with a credit institution or a central bank and held in a separately identifiable account.
Who do you have to hire for a Dutch CASP licence, and where must they be based?
The people in charge of day-to-day operations and the members of the supervisory board must pass AFM fit-and-proper testing.
Is a Dutch CASP licence right for your model, and what are the alternatives?
It depends on your firm type and timeline. The AFM states that even best-case authorisation applications take at least five months and often longer. Credit institutions, CSDs and investment firms can use the Article 60 route instead: they notify their home national competent authority at least 40 working days beforehand and need no authorisation.
In which language must the application and documents be filed with the AFM?
Applicants submit the AFM's CASP licence application form, the checklist and the supporting documentation via Cryptshare, addressed to crypto@afm.nl.
Sources
- afm.nl: casp vergunning · retrieved 2026-09-24
- EUR-Lex: CELEX 32023R1114 · retrieved 2026-09-24
- EUR-Lex: CELEX 32023R1113 · retrieved 2026-09-24
- afm.nl: aan en afmelden europees paspoort · retrieved 2026-09-24
- afm.nl: kosten · retrieved 2026-09-24
- zoek.officielebekendmakingen.nl: stcrt 2026 20792 · retrieved 2026-09-24
- afm.nl: cryptopartijen · retrieved 2026-09-24
- afm.nl: voorkomen van witwassen en terrorismefinanciering en het nal · retrieved 2026-09-24
- afm.nl: good practices · retrieved 2026-09-24
- EUR-Lex: CELEX 32022R2554 · retrieved 2026-09-24
- web.archive.org (32023R1114) · secondary · retrieved 2026-09-29
- wetten.overheid.nl: BWBR0020368 · retrieved 2026-09-24
- afm.nl: formulieren · retrieved 2026-10-01
- afm.nl: veilig bestanden uitwisselen · retrieved 2026-10-01
- EUR-Lex: oj · retrieved 2026-10-01
- afm.nl: formulieren · retrieved 2026-10-01
- EUR-Lex: 305 · retrieved 2026-10-01
- mica.wtf: article 63 · retrieved 2026-10-01
- Markets in Crypto-Assets Regulation · retrieved 2026-10-01
- zoek.officielebekendmakingen.nl: stcrt 2024 21638 · retrieved 2026-09-26
- afm.nl: kosten · retrieved 2026-09-26
- wetten.overheid.nl: BWBR0005537 · retrieved 2026-10-01
- afm.nl: bezwaar en beroep · retrieved 2026-10-01
- rechtspraak.nl: College van Beroep voor het bedrijfsleven · retrieved 2026-10-01
- EUR-Lex: oj · retrieved 2026-10-01
- cysec.gov.cy · retrieved 2023-06-09
- eerstekamer.nl: vmj8ckj072z0 (PDF) · retrieved 2024-12-17
- esma.europa.eu: ESMA35 1872330276 1899 Final report on GLs on reverse solici (PDF) · retrieved 2024-12-17
- dnb.nl: crypto service providers · retrieved 2026-09-24
- esma.europa.eu: ESMA42 2004696504 8164 Fast track peer review on a CASP auth (PDF) · retrieved 2025-07-10
- coindesk.com: malta the small island nation granting big exchanges access · secondary · retrieved 2025-06-30
- EUR-Lex: CELEX 32023R1114 · retrieved 2023-06-09
- dutchnews.nl: prosecutors request bankruptcy for dutch crypto firm knaken · secondary · retrieved 2026-06-30
- cointelegraph.com: okx fined 2 6m netherlands operating without license · secondary · retrieved 2025-09-03
- dnb.nl: vvgb voor deelnemingen art 3 95 wft · retrieved 2024-12-20
- afm.nl: contact qa · secondary · retrieved 2024-05-29
- wetten.overheid.nl: 2026 01 01 · retrieved 2026-09-24
- esma.europa.eu: ESMA75 1303207761 6284 Statement to support the smooth imple (PDF) · retrieved 2025-12-23
- wetten.overheid.nl: BWBR0041647 · retrieved 2024-12-20
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