MiCA · Netherlands · CASP Licensing

MiCA in Netherlands.
Market that works

In most EU jurisdictions MiCA licensing is still theoretical — regulators are forming their expectations in real time, banking access stays uncertain until you have already committed capital, and you become the test case for rules that are not yet settled.

The Netherlands is the exception. AFM has already authorised CASPs, publishes concrete examples of what it rejects, and lets you pre-scan your model with the regulator before you file. Protegra takes you through Dutch CASP authorisation and into live, supervised operations — as one engagement, in English.

Calculate your Year 1 cost ⟶ Schedule a free call ⟶
Why teams choose Protegra

Built for crypto — not adapted to it

100% crypto-focused.

Every engagement is built around the regulatory and operational realities of crypto and fintech licensing.

Start your application ⟶

We only do this

Our team works across the Netherlands, Latvia, Malta, Poland, and the Czech Republic exclusively on crypto and fintech licensing — MiCA, AML, DORA — because a CASP file needs someone who has already solved the same problem for another exchange or custodian.

We built the step generalists skip

The optional AFM pre-scan is not a formality we include to look thorough — it is the step where weaknesses in governance, AML, or DORA readiness surface before they become formal rejection reasons.

We stay after the licence is issued

Most advisers consider the engagement done at authorisation. Ongoing AML monitoring, tax reporting under DAC8, and disclosure standards are part of the same engagement — not a separate upsell later.

A working market.
Not a waiting room.

Regulatory facts

The Netherlands at a glance: what are the numbers?

9%
Innovation box · tax treatment

Standard corporate income tax remains separate. Qualifying IP-driven profit may use the Dutch innovation-box rate.

~12
Months · realistic timeline

Filed around month three, accepted as complete — or not — in month four or five, assessed from month six. A year is the number to plan against; nine months is achievable only when your documentation is already partly in place. The AFM itself says that even a best-case application takes at least five months and in practice often longer.

27
EU markets · passporting

One Dutch authorisation can be passported across the EU through the MiCA notification process.

Regulator
Dutch Authority for the Financial Markets (AFM) as licensing authority, with prudential supervision by De Nederlandsche Bank (DNB).
Corporate form
Dutch private limited company (Besloten Vennootschap, BV) as the standard vehicle for CASP activities.
Substance
Registered office in the Netherlands, local management and decision-making, and at least one EU-resident director or comparable local “mind and management” presence expected by regulators.
Why the Netherlands

Why choose the Netherlands for a MiCA licence?

Market

A real fintech hub, not a licensing address
  • Amsterdam HQ, international team — no relocation required for most crypto hires.
  • Major European exchange on-site plus an existing crypto and fintech ecosystem.
  • English-language regulatory environment throughout the AFM process.

Access

You can talk to AFM before you file
  • Optional pre-scan lets you present your model before formal submission.
  • AFM publishes concrete examples of what it rejects — documented, not guessed.
  • Banking access for licensed CASPs is an established path, not a negotiation from zero.

Clarity

The rules do not change once you are live
  • DAC8 crypto tax reporting sits inside a clear Dutch legal framework.
  • AFM and DNB supervisory expectations continue under documented standards.
  • EU passporting across 27 markets — AFM files the outgoing notification at no extra fee.
Start your application ⟩

Amsterdam.
Your EU base.

Choose your licence class

Which MiCA class fits your business?

MiCA defines three CASP licence classes by service scope and capital requirement.
Identify yours below — then use the calculator to get your full cost breakdown.

Class 1 · min. own funds€50.000

Advisory, order flow, and transfer services

Advice, portfolio management, reception and transmission of orders, execution of orders, placing, and transfer services. The right starting point for firms not planning to hold client crypto-assets or operate a trading venue.

Calculate cost ⟶Apply for Class 1 ⟶
Most commonClass 2 · min. own funds€125.000

Exchange and custody services

The most commercially relevant class for active crypto businesses. Covers exchange activity and custody — the natural fit for firms handling client assets, crypto-to-fiat or crypto-to-crypto exchange, and a broader MiCA operational model.

Calculate cost ⟶Apply for Class 2 ⟶
Class 3 · min. own funds€150.000

Trading platform authorisation

The highest MiCA class, for firms that plan to operate a crypto-asset trading platform — building market infrastructure rather than offering individual crypto services.

Calculate cost ⟶Apply for Class 3 ⟶
Cost calculator

How much should you set aside for a Dutch MiCA licence?

Toggle the services that apply to your model and get a real Year 1 estimate — legal fees, capital reserve, regulator fees, and ongoing costs — before you commit to anything.

Three levels of support

How much of the work do you want us to do?

01 · TEMPLATES

You get the documents. You file them yourself.

€15.000
  • The full policy, procedure and governance pack for this regulator
  • Application forms filled in as far as your own data allows
  • One handover session so you know what goes where
  • You deal with the regulator yourself
02 · TAILORED

We write the file around your business.

€70.000
  • Everything above, rewritten around your actual model
  • Business plan, governance and AML/CFT built from your data
  • We assemble and check the whole file before it goes in
  • You submit and answer; we stay on call throughout
Every figure on this page assumes this level
03 · TO DECISION

We carry the file to the regulator’s answer.

€140.000
  • Everything above, and we file it
  • Every regulator question and clarification round comes to us
  • Meetings and pre-application engagement handled for you
  • We stay on the file until the decision is issued

One licence, three levels — the regulator asks for exactly the same file in all three, and what changes is how much of it sits with you. The middle level is the default here: every price on this page is quoted at it, and the selector above the total switches between them. Moving up or down changes our fee and nothing else — not the capital, not the state fees, not the statutory clock. Carrying a file to the decision is not a promise of approval: no adviser can give one, and an adviser who does is selling you something other than advice.

Legal feesPreparation + regulator management+€70.000
Share capital reserveRequired by class+€125.000
BV incorporationIncl. VAT and tax analysis+€4.500
Monthly operating costsBoard, MLRO, office — annualised+€72.000
DORA & IT securityDocumentation + audit+€15.000
Accounting10 months at €400/mo+€4.000
Statutory fixed fees — paid directly to AFM / KVK
AFM application processing€200/hr, capped at €100.000
AFM properness assessment€700 per person
AFM suitability assessment€2.900 per person
KVK registration€85,15
Roadmap with Protegra

How long does the Dutch licence take, step by step?

Plan for a year, and know which month answers what. The file goes in around month three. Whether the AFM accepts it as complete — a separate decision, and the first real one — comes back in month four or five. Assessment runs from month six, and the regulator states plainly that “even in a best-case scenario it will take at least five months” from filing and that “in practice, it will often take longer”. Nine months end to end is achievable, but only where your documentation already exists in part — a written programme of operations, policies, an audited history. Each step below says what is actually done in it and what we need from you.

We fix which of the ten crypto-asset services in Article 3(1)(16) you will apply for, and write the legal reasoning for why the others do not apply — the AFM asks for exactly that, in writing. In parallel the BV is incorporated with a Dutch registered office, the day-to-day policymakers and supervisory board are named, and the shareholder chain is mapped, because qualifying holders are assessed by DNB separately and charged for separately. From you: the ownership chain up to the ultimate beneficiaries, passports and CVs for everyone who will be assessed, and a decision on who will sit in the Netherlands.
The AFM runs an optional CASP pre-scan: you write to crypto@afm.nl, they invite you to a one-hour online meeting, and you send a slide deck at least one working day beforehand answering their published questions — every registration you hold anywhere in the world, any transitional regime you are relying on and when it expires, the services you will apply for and why not the others, the group structure with headcount per entity, and your planned Dutch presence in offices and people. The feedback is general and is not a formal review, which is exactly why it is worth having before the file is frozen.
Six weeks of concentrated work, overlapping the pre-scan because the AFM only accepts parties whose preparations are already advanced. Programme of operations per service; governance arrangements and a fit-and-proper file for every policymaker; AML and sanctions policy with the business-wide risk assessment, transaction monitoring and Travel Rule arrangements behind it; ICT and DORA arrangements; the outsourcing register and the contracts under it; client-asset segregation and custody policy; the own-funds calculation against your class; a business plan with three-year projections; complaints, conflicts, market-abuse and disclosure policies. The file is built as one document set that answers the same way in every chapter — incoherence across chapters is what supervisors read for.
The application goes to the AFM by e-mail through Cryptshare, and the AFM acknowledges receipt within five working days. This is also where the regulator’s meter starts: €200 per hour capped at €100,000 for handling the application, plus €700 per person for the properness assessment and €2,900 per person for the suitability assessment — reduced to €1,500 or €500 for anyone DNB already assessed under the old registration regime — with DNB charging separately for the qualifying shareholders.
A separate stage with its own answer, and the one most roadmaps hide inside the total. The AFM has 25 working days to decide whether your file is complete. If something is missing it sets a deadline of five to twenty working days to supply it, and it may refuse to consider an application that is still incomplete after that — not a rejection on the merits, simply a file that never entered assessment. Expect the answer in month four or five. What comes back is either “complete, the assessment period starts” or a list, and the length of that list is the clearest early signal of how the rest will go.
The statutory assessment period is 40 working days from the day the file is declared complete. Within the first twenty the AFM may request anything further it needs, and that request suspends the clock until you answer; the decision is then notified within five working days. On paper that is about two months. In practice this stage runs from month six and commonly well beyond it, because each suspension is a round trip and most files make several. Running alongside it is the part no statute covers: the people named in the file actually hired, the systems actually running, the outsourcing contracts actually signed, the policies matching what the organisation does rather than what the application promised. A licence is granted to an operating company, not to a plan for one.
07Ongoing

Post-licensing support

Included, not optional

Most advisory firms consider the engagement done at authorisation. We stay on — the difference between a licence you hold and a business you can actually run.

Ongoing AML & sanctions monitoring

Continuous transaction monitoring, periodic risk assessments, and policy updates aligned with AFM and DNB expectations.

DAC8 tax reporting

Crypto-asset tax reporting obligations under DAC8 managed as part of your live compliance programme.

MiCA disclosure compliance

Ongoing review of crypto-asset white papers, marketing materials, and cost disclosures against AFM’s published standards.

Supervisory relationship management

Structured handling of AFM and DNB information requests, periodic reporting, and supervisory meetings after authorisation.

Begin Step 1 ⟶Book a free call first ⟶
Why Protegra

Turning a CASP application into a working business.

Most firms do not struggle because they lack a licence strategy. They struggle because a Dutch CASP application and a working, supervised business are two different things — and most advisers only help you with the first one.

See how we work ⟶

The local execution gap

A Netherlands application is not just documents. It is aligning your business model, governance, AML, and outsourcing with what Dutch regulators expect in practice.

⟶ We shape the model around Dutch supervisory practice from day one.

The regulatory interpretation

MiCA sets the framework, but AFM applies it its own way. Without someone who has sat across the table from AFM before, you are guessing.

⟶ The optional pre-scan surfaces their expectations before you file.

The post-licence setup challenge

A licence you cannot operate under is a wasted licence. Tax reporting, disclosures, and ongoing supervision start the day you are authorised.

⟶ DAC8, disclosures, and AFM monitoring are part of the same engagement.

The generalist advisor risk

A law firm that knows “regulation” is not the same as one that knows how a CASP actually runs day to day.

⟶ We only do crypto and fintech licensing — nothing else.
Client experience

How these problems get resolved.

Select a problem to see how a real client moved from stuck to authorised.

Before Protegra
“We had worked with two law firms before Protegra. Both knew MiCA on paper.”
With Protegra
“Neither had sat inside a Dutch BV with AFM asking questions about your governance setup. That gap is real and expensive.”
CCo-founder, Class 2 exchange
Amsterdam
Talk to an expert ⟶Schedule a free call ⟶
FAQ

Netherlands CASP licence: common questions.

About the calculator
01How close is the calculator to what I will actually spend in Year 1?
It is a planning estimate based on the chosen class and selected operating components. Regulator time, management structure, and the final scope of work can change the total; we confirm those after reviewing your business model.
02Why is share capital treated differently from the other costs?
Share capital is a prudential reserve held by the company rather than a professional fee. It remains on the company's balance sheet subject to MiCA's own-funds rules.
03Can I get a documented breakdown to take to my board or investors?
Yes. We can provide a line-by-line estimate covering licensing, regulator charges, operational setup, and recurring compliance costs.
About the Dutch CASP licence
04How do I know which MiCA class my business model actually falls under?
We map each product flow and crypto-asset service against MiCA before incorporation or filing, then confirm which services must appear in the programme of operations.
05What realistically drives the AFM timeline, and where is time usually lost?
Completeness, governance readiness, supporting evidence, and the speed of responses matter most. Time is usually lost where documents describe different operating models or control owners.
06What does the Dutch tax position actually look like for a CASP?
The legal entity is generally subject to Dutch corporate income tax. Innovation-box treatment may apply only to qualifying self-developed IP income and needs separate tax analysis.
Working with Protegra
07How is Protegra different from a law firm that already advises on MiCA?
We combine licensing strategy with operational implementation: entity setup, governance, AML, DORA, outsourcing, regulator dialogue, and the post-licence routines needed to stay compliant.
08What obligations begin the moment the licence is granted?
Ongoing AML monitoring, client disclosures, incident and outsourcing controls, prudential safeguards, recordkeeping, and supervisory reporting begin immediately.
09How do you avoid committing capital before the application is actually ready?
We stage entity, governance, documentation, and staffing work against readiness gates so commitments happen in the right order, with the optional AFM pre-scan used where it materially de-risks the file.
Get a personalised plan ⟶Book a call ⟶

Reference: Crypto-asset service provider (MiCA CASP) licences compared in the Licensing Atlas.

Written by Anastasia Sidorenkova ·
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