Crypto license in Netherlands: MiCA CASP requirements (2026)

The six-month grandfathering window granted to existing DNB-registered crypto service providers closed, ending the Wwft-based registration regime. Any operator without a MiCA CASP licence from the AFM (or a passported EU authorisation) became prohibited from serving Dutch clients.

De Nederlandsche Bank imposed a €2.25 million administrative fine on Aux Cayes Fintech Co. Ltd. (OKX) for providing crypto exchange and custodial-wallet services in the Netherlands without mandatory DNB registration from July 2023 to August 2024, underscoring continued enforcement of the pre-MiCA Wwft regime.

DNB issued an order subject to periodic penalty against Peken Global Limited (KuCoin) for operating crypto services in the Netherlands without registration; KuCoin failed to comply throughout the entire eight-week forfeiture period, triggering the maximum €4 million penalty, the largest single crypto enforcement action by DNB at the time.

The Markets in Crypto-Assets Regulation became fully operational across the EU, including the Netherlands; the AFM immediately granted the EU's first MiCA CASP licences (MoonPay, BitStaete, ZBD, and Hidden Road), with AFM as primary licensing authority for most crypto services and DNB retaining prudential and stablecoin supervisory roles.

DNB fined Bybit Fintech Limited €2.25 million for providing crypto exchange and wallet services to Dutch users without the required DNB registration until September 2023; DNB noted the non-compliance prevented Bybit from filing suspicious-transaction reports with the Financial Intelligence Unit-Netherlands.

Titles III and IV of Regulation (EU) 2023/1114, covering asset-referenced tokens and e-money tokens, became applicable, placing stablecoin issuers operating in the Netherlands under DNB authorisation requirements for the first time and imposing reserve, disclosure, and redemption obligations.

The AFM began accepting MiCA CASP licence applications and passporting notifications ahead of the December 2024 application date, positioning the Netherlands as one of the earliest EU member states with an operational licensing pipeline and demonstrating regulatory readiness ahead of full MiCA applicability.

DNB issued an order subject to penalty against Payward International Markets Limited (Kraken) for providing crypto services without registration; Kraken failed to comply within the eight-week compliance window, triggering the maximum €4 million penalty before eventually registering through a separate Payward entity in February 2024.

The Dutch implementation of the EU Fifth Anti-Money Laundering Directive (Staatsblad 2020, 146) amended the Wwft to require mandatory DNB registration for all providers of fiat-crypto exchange and custodian-wallet services operating in or from the Netherlands, creating the country's first binding crypto regulatory regime and subjecting these providers to AML/CFT compliance obligations.

The AFM and DNB submitted a formal advisory report to the Dutch Minister of Finance concluding that crypto-assets posed significant risks of financial crime, fraud, and investor harm and recommending an AML licensing regime nationally and coordinated regulation at the EU level, a report that directly informed both the Wwft amendment of 2020 and Dutch support for what became MiCA.

De Nederlandsche Bank issued the first of several formal warnings stating that Bitcoin and virtual currencies cannot fulfil all monetary functions, carry high consumer risk due to extreme volatility, and offer weak security guarantees, establishing a cautious but watch-and-regulate stance that would define Dutch policy for nearly a decade before legislative action followed.