MiCA CASP Licence in the Netherlands, Built Around Your Group

No. The Dutch transition ended on 30 June 2025 for providers registered with DNB under the old Wwft regime, and MiCAR's EU-wide ceiling of 1 July 2026 has also passed. A firm without an AFM licence or a notification may not provide crypto-asset services, so trading starts after the grant, not during the procedure.

No. Art. 59(2) MiCAR asks for at least one director resident in the Union, effective management in the Union and a registered office in a Member State where part of the services are carried out. The AFM's pre-scan asks about group entities, FTE per entity and the head office, so real presence is examined, though no threshold is published.

No. Acting as a director for a client is a trust service under the Wtt 2018, the Trust Offices Supervision Act, which needs a DNB trust-office licence, and we do not hold one. You appoint your own board, including the Union-resident director, and we prepare the AFM fit-and-proper file for each person you appoint.

Both, on different people. The AFM tests every member of the management body for reliability and suitability, at EUR 700 and EUR 2,900 per person in 2026. DNB tests the reliability of every qualifying holder, at EUR 1,700 each, and assesses the prudential requirements inside the AFM procedure. DNB does not grant the licence.

In 2026, EUR 200 per hour of AFM work, capped at EUR 100,000 (tariff code EU.A1.08). The tests are billed apart: EUR 700 and EUR 2,900 per board member, and EUR 1,700 per qualifying holder for DNB. The one-off charges are VAT-free, and an annual supervision levy follows. Our fee is on request.

The AFM puts the statutory clocks at 105 working days in total, about five months, and says experience shows at least five months even in the best case. The business.gov.nl portal states five to eight months. An incomplete file or an information request lengthens the procedure, so we promise no duration of our own.

Ownership is tested on repute and on supervision. Every direct and indirect holder of 10 percent or more of the capital or voting rights must be of good repute, and DNB tests each one at EUR 1,700 (2026). Close links, or third-country law over a linked person, that prevent effective supervision are grounds for refusal.

A proposed acquisition at 10 percent, crossing 20, 30 or 50 percent, becoming a subsidiary, or a disposal needs prior written notice. DNB assesses it through MyDNB within 60 working days of the acknowledgement of receipt, at EUR 2,400 for the assessment plus EUR 1,900 for the acquirer's reputation test (2026).

There is no registration any more. Since 30 December 2024 a provider of crypto-asset services needs a licence or a notification from the AFM or another European supervisor. The old DNB registration lapsed when the Dutch transition ended on 30 June 2025, and the AFM crypto register lists who holds a licence or notification.

Yes, through a licensed or notified provider. Providing crypto-asset services without a licence or notification breaches art. 59(1) MiCAR, which is an economic offence under the Dutch Economic Offences Act (WED). The AFM can also prohibit services and advertising and order an unlicensed provider to stop, under art. 1:77n Wft.

A registered office in a Member State where part of the services are carried out, effective management in the Union and a Union-resident director; a board and qualifying holders of good repute; own funds by service class; client funds placed with a bank or central bank; and a complete eight-section application file, as the requirements table sets out.

MiCAR Annex IV sets EUR 50,000, EUR 125,000 or EUR 150,000 by service class, or a quarter of the preceding year's fixed overheads if that is higher. It can be held as own funds, an insurance policy, a comparable guarantee or a mix. The BV itself has no statutory minimum capital (art. 2:178 BW).

Only at the client's own exclusive initiative, under the reverse solicitation rule of art. 61 MiCAR. The exemption ends once the firm solicits clients or prospective clients in the Union, whatever disclaimer it uses, and it never covers new products. Serving EU clients beyond that needs an authorisation or a notification in the Union.

Yes, by passport. The licence covers services throughout the Union, through establishment, a branch or free provision, with no physical presence needed in the host state. The AFM forwards the passport notification within 10 working days, and services may start at the latest on the 15th calendar day after submission (art. 59(7) and 65 MiCAR).

Not necessarily. A firm already authorised as a credit institution, investment firm, e-money institution, UCITS management company or AIFM may notify under art. 60 MiCAR instead of applying under art. 63. The 2026 AFM fee for a notification is capped at EUR 50,000 rather than EUR 100,000. We set out the conditions; the choice is yours.