For crypto companies aiming to expand across the European market, securing a MiCA license in the Netherlands has become a strategic and forward-looking move. Following the enforcement of Regulation (EU) 2023/1114—commonly referred to as MiCA (Markets in Crypto-Assets)—the regulatory environment for digital assets has shifted toward a standardized and predictable model across the EU.
Among all European jurisdictions, the Netherlands stands out for its readiness to implement MiCA provisions, thanks to its transparent procedures, cooperative regulatory bodies, and experience in supervising financial innovation. This makes it a compelling option for digital asset providers looking for long-term operational certainty within the European Economic Area.
This article provides a structured overview of what it takes to align with MiCA requirements in the Netherlands—covering the licensing landscape, institutional oversight, and key benefits of this jurisdiction.
Why the Netherlands?
The Dutch regulatory ecosystem has earned a reputation for balancing strict supervision with openness to innovation. The country is home to a number of well-established fintech players and has consistently ranked among the EU’s top jurisdictions for digital compliance infrastructure.
- De Nederlandsche Bank (DNB), responsible for prudential oversight, and
- The Authority for the Financial Markets (AFM), overseeing conduct and transparency.
What sets the Dutch framework apart is its insistence on substance over form. Regulators look beyond paperwork. They assess how your business will operate in practice: whether internal controls are solid, risk management tools are in place, and reporting mechanisms meet EU-level expectations. Companies are expected to demonstrate real capacity for governance—not just fulfill symbolic compliance.
- Securing and managing customer-held crypto assets
- Operating centralized or decentralized exchange platforms
- Facilitating crypto-to-fiat and fiat-to-crypto transactions
- Issuing digital tokens (including asset-referenced and e-money tokens)
- Acting on behalf of clients in the execution of digital asset transactions
Holders of a MiCA license in the Netherlands also benefit from automatic passporting rights, meaning they can offer these services across all EU member states without separate licensing procedures in each jurisdiction.
It’s important to recognize that obtaining this license is more than a bureaucratic step—it’s a gateway into the harmonized digital finance market of the EU. Dutch regulators are known for their integrity and thoroughness. That said, once a license is granted, it comes with strong legal backing and high credibility across Europe.
Applicants must be prepared to meet MiCA’s expectations not just at the application stage, but throughout their operational lifecycle. This includes regular disclosures, capital adequacy checks, cybersecurity audits, and mechanisms to mitigate conflicts of interest.
Types of Companies Subject to MiCA Regulation
The MiCA regulation applies to a wide range of crypto-related businesses. Its primary goals are to reduce illegal activity within the digital asset space and bring more stability to the EU crypto market. As a result, both large-scale exchanges and smaller niche players—including fintech startups and crypto-focused platforms—are required to obtain a MiCA license in the Netherlands if they want to operate legally.
A major category under MiCA includes crypto trading platforms, whether centralized or peer-to-peer (P2P). These platforms must meet strict transparency requirements, provide clear and accessible information to users, and implement strong safeguards to prevent fraud and market manipulation. Security protocols for digital asset transfers and customer protections are also non-negotiable under the new rules.
MiCA also covers companies offering custodial services—essentially, firms that store cryptocurrencies on behalf of clients. This includes wallet providers that manage users’ private keys. These companies must demonstrate robust cybersecurity practices, data protection mechanisms, and fully operational KYC (Know Your Customer) and AML (Anti-Money Laundering) systems. To qualify for a license in the Netherlands, custodians must have technical and organizational setups that meet the EU’s cybersecurity standards.
Service providers that facilitate crypto transactions on behalf of clients—like brokers or dealers—are also within MiCA’s scope. These businesses must implement risk management frameworks, ensure the fair execution of trades, and conduct detailed reviews of client fund origins. Transparency and accountability are central to the licensing process in this category.
MiCA gives special attention to companies issuing stablecoins or conducting token sales through ICOs, IEOs, or IDOs. In these cases, licensing involves more than just basic regulatory alignment. Issuers must provide full clarity on how tokens are backed, ensure mechanisms for redemption are in place, and maintain financial reserves that match their issuance volume. The ability to operate under MiCA in the Netherlands depends on having a transparent and well-structured issuance model that protects both users and the broader market.
Steps to Secure a MiCA License in the Netherlands
Launching a crypto venture within the European Union comes with significant regulatory obligations. For those considering the Netherlands as their operational base, obtaining a MiCA license is a fundamental requirement to legally access the EU market under the new crypto-assets regime.
Before starting the formal application process, businesses must undertake a rigorous preparation phase — covering legal compliance, corporate governance, and financial planning.
In the Netherlands, crypto firms are supervised by the Dutch Authority for the Financial Markets (AFM). The licensing process goes beyond paperwork — it demands real, verifiable alignment between a company’s operational setup and MiCA standards.
AFM provides comprehensive guidance that outlines the core compliance areas every Crypto-Asset Service Provider (CASP) must address. These typically include:
- Employing a designated compliance officer with relevant qualifications and oversight responsibilities;
- Defining how clients and counterparties are onboarded and monitored;
- Establishing resilient KYC and AML frameworks to reduce financial crime exposure.
Before filing, the business must complete a self-assessment of its operating model to ensure it aligns with EU regulatory benchmarks. This includes registering a Dutch company, appointing key personnel, and mapping out risk management strategies tailored to the firm's service offerings.
Applicants must compile a comprehensive dossier, including:
- Financial statements and liquidity projections;
- Internal control policies and operational handbooks;
- IT security protocols and compliance workflows;
- Organizational charts and beneficial ownership disclosures;
- Policies addressing customer due diligence and data protection.
Every detail is expected to reflect how the company will function in practice — not just theoretical models.
All materials are submitted digitally through the AFM's licensing system. The submission includes corporate bylaws, executive resumes, AML/KYC process outlines, and documentation of daily workflows that demonstrate regulatory integration across departments.
The AFM reviews each submission carefully, often engaging in several rounds of correspondence to request clarification, corrections, or additional supporting materials. This stage typically spans several weeks to months and demands ongoing readiness to cooperate with the regulator.
Once the AFM confirms full adherence to MiCA obligations, the business is granted its license and added to the national registry of authorized CASPs. From that point, the company may legally offer crypto-related services across all EU member states under the MiCA passporting mechanism.
Due to the complexity and depth of the process, professional legal guidance is highly recommended. Working with regulatory experts ensures that each requirement is addressed thoroughly — particularly in cases where the business model involves innovative technologies or multi-jurisdictional operations.
Preparing for MiCA Licensing in the Netherlands: Core Documentation and Expectations
Getting ready for MiCA licensing isn’t just about compiling a folder of PDFs. It’s about crafting a complete compliance identity — one that regulators in the Netherlands can audit, verify, and trust. Below is a breakdown of the core components you'll need to prepare, but this time we’re not listing them robotically — we’re telling the story the way regulators expect to read it.
Business Model Clarity
Before anything else, Dutch regulators want to see how your business works — and more importantly, why it should exist. Your business plan should cover:
- What problem your crypto venture solves,
- How your platform generates revenue,
- Who your target users are, and
- Where you see the business in 3–5 years.
But don’t forget: MiCA isn’t about innovation alone. They’ll also judge you on how resilient your structure is during stress events — volatility, hacks, legal claims, regulatory shifts.
AML/CTF Procedures That Actually Work
MiCA compliance in the Netherlands starts with one assumption: you are responsible for identifying and stopping bad actors. To demonstrate that, you’ll need detailed internal policies covering:
- How you screen users and counterparties,
- Who’s accountable for monitoring unusual activity,
- What thresholds trigger a compliance response, and
- How regularly you review and update your policies.
This isn’t theoretical — the AFM wants evidence that these systems aren’t just documents, but working parts of your day-to-day operations.
KYC Implementation Strategy
Your KYC flow should be built to stand up to scrutiny. You’ll need to explain:
- The tools and databases you use for identity verification,
- What data you collect and retain,
- How you comply with GDPR, and
- What you do when a client fails verification.
Make it clear your team understands the risks of anonymous onboarding, especially in DeFi-like scenarios. If you outsource KYC to third parties, be ready to disclose those contracts and their legal basis.
Token Issuers — You Have Homework
If your business includes minting or distributing digital assets, especially stablecoins or asset-referenced tokens, Dutch regulators will ask for a complete white paper. This must detail:
- Your asset structure and tech stack,
- Emission logic and distribution plans,
- Liquidity reserves or collateral,
- Risk disclosures for investors.
No vague promises or buzzwords — they expect mathematical modeling, risk assumptions, and redemption mechanisms in case of market disruptions.
Custody & Infrastructure
Storing client assets? You’ll need a custody protocol that’s not just secure but explainable. That means:
- Defining how private keys are stored and backed up,
- Outlining access control roles and procedures,
- Having a real plan for asset recovery or cyber breach scenarios.
Expect to be quizzed on your cybersecurity posture — MiCA doesn’t leave room for “we’re working on it.”
Everything you submit for your MiCA license in the Netherlands should demonstrate that your team understands the gravity of the regulation. It's not about meeting a checklist — it's about proving your operation can stand up in one of the EU's most demanding crypto environments.
Contact our experts and get answers to your questions.
Financial Requirements for Obtaining a MiCA License in the Netherlands
For any company applying for a MiCA license in the Netherlands, meeting the capital requirement is a non-negotiable starting point. The level of statutory capital required depends on the business model and the type of crypto services offered. Regulators treat capital not as a formal checkbox but as an essential buffer that helps absorb operational risks, financial disruptions, and market volatility. It’s the company’s first line of defense — ensuring continuity of service, financial solvency, and protection of client assets.
The lowest capital threshold applies to crypto firms offering only the most fundamental services — typically acting as intermediaries in transactions without ever taking custody of client funds. These businesses carry relatively low operational risk and are not involved in asset storage or conversion. For this reason, the capital requirement is set at €50,000. Dutch authorities consider this sufficient to cover basic liabilities and provide a degree of operational stability in the early stages. However, companies in this category are still expected to implement internal controls, maintain transparent governance, and comply fully with MiCA's structural requirements.
A higher bar is set for crypto companies that go beyond basic brokerage and take on more complex activities, such as storing digital assets or exchanging crypto for fiat and other tokens. These firms fall into the second licensing category and are required to hold at least €125,000 in statutory capital. This amount is intended to cover a wider set of operational risks — including potential failures in custody systems, loss of client funds, or transactional malfunctions. It reflects the broader exposure such companies face and ensures they have enough capital to stabilize their business in case of unexpected losses.
The most demanding capital requirements apply to firms that run trading platforms or act as market makers. These companies operate in high-volume, high-volatility environments where the risks of manipulation, price swings, and systemic shocks are much greater. To secure a MiCA license in this category, an applicant must have at least €150,000 in capital. This base amount may be raised further depending on the company’s scale, the complexity of its operations, or its involvement in algorithmic trading. Dutch regulators are clear on this point: robust capital is critical to maintaining integrity in the trading environment and shielding users from abusive or destabilizing practices.
Issuers of asset-referenced tokens (ART) and electronic money tokens (EMT) are subject to separate financial rules under MiCA. For ART issuers, Article 35 of the Regulation sets the minimum capital requirement at €350,000. In addition to this fixed amount, the company must hold capital equal to 2% of the average value of its reserve assets over the last six months. This structure ensures that as issuance scales, so does financial accountability.
Companies issuing EMTs fall under a regime that closely mirrors the EU’s e-money directive. In the Netherlands, these issuers are required not only to maintain the minimum capital but also to prove access to liquid reserves, uphold operational resilience, and report to regulators on a regular basis. If the Dutch supervisory authority concludes that a specific EMT issuer poses elevated systemic risk, it may impose additional requirements — including increasing the capital reserve by up to 20% above the standard threshold.
The capital requirement under MiCA is more than a regulatory figure. It’s a reflection of a company’s readiness to participate in a highly scrutinized financial system. Dutch authorities expect applicants not only to meet the minimums but to treat capital as a critical part of their risk and responsibility model. Whether a company is launching a simple crypto brokerage or running a global exchange, its ability to remain financially secure under pressure is what earns — and keeps — the license.
MiCA Licensing in the Netherlands: Estimated Costs and Timeframe
Launching a crypto project under MiCA regulation in the Netherlands is not just a matter of filing an application — it’s a complex regulatory journey with layered financial, operational, and legal steps. The final budget will vary significantly depending on the scale of your activities, the type of crypto services you intend to deliver, and how efficiently your team can implement compliance frameworks.
As of 2025, the regulatory filing fee for a MiCA license application stands at approximately €6,800. But this is just the beginning. Businesses also need to plan for:
- Legal registration through the Dutch Chamber of Commerce (KVK)
- Establishment of a corporate bank account
- Due diligence checks on company ownership
- Notarial support for company formation
- Professional advisory and pre-licensing structuring
If your company manages customer wallets (i.e., acts as a custodian), operates in multiple markets, or builds its own trading infrastructure, expect your costs to increase. These profiles demand not only stronger internal control systems but also robust capital reserves, well-documented operating procedures, and technology audits. These features must align with MiCA’s compliance thresholds, which are non-negotiable.
From Submission to Decision: What to Expect
Though officially the review period is cited as three to six months, real-world experience shows the process can stretch to eight or even nine months — especially when regulators request clarifications or identify inconsistencies in the application. It’s common for authorities to issue feedback requiring documentation updates or enhancements before continuing.
However, licensing doesn’t stop at the moment of approval. MiCA introduces an ongoing supervisory framework, which means that companies must continue to meet compliance standards long after licensing.
These continuing obligations include:
- Preparing annual financial statements
- Submitting to third-party audits
- Monitoring transactions under AML/CFT rules
- Regularly reviewing and updating internal policies
What this means in practice: MiCA is not just a cost today — it’s a recurring operational expense. Businesses should account for this in their long-term financial planning, not just during the application phase.
Tax Environment for CASP License Holders in the Netherlands
Crypto companies operating under a MiCA license in the Netherlands fall under the national corporate tax regime. At the time of writing, businesses pay 19% corporate income tax on the first €200,000 of annual profit. Once that threshold is exceeded, earnings above the limit are taxed at 25.8%. These rates apply across the board to registered legal entities, including those involved in crypto asset services.
As for tax treatment of crypto-related activities, not all revenue streams are treated equally. Transactions involving the direct exchange of digital assets — whether swapping crypto for fiat or for another token — are generally not subject to VAT. This reflects the broader EU position that treats cryptocurrencies as a means of payment rather than a taxable good.
However, when a company provides additional services outside of direct exchange — for instance, consulting, technical integration, platform access, or marketing support — those services can fall under the scope of VAT. In the Netherlands, the general VAT rate is 21%. Companies offering a hybrid business model should ensure their accounting processes distinguish between taxable and VAT-exempt revenues to avoid misreporting.
What a MiCA License Actually Means for Your Business
Getting licensed under MiCA in the Netherlands is not just about following rules. It’s about building something that lasts — a business that can operate legally, defend itself during audits, and work with serious partners without hesitation.
This jurisdiction is one of the more demanding in the EU when it comes to digital finance, and the expectations reflect that. You’ll need to prove not just that your systems work, but that your people are qualified, your controls are active, and your reporting is regular and reliable. If that sounds like a lot, it is — but that’s exactly why MiCA exists. It creates a way to separate stable operators from speculative noise.
A license here doesn’t give you shortcuts. What it does give you is stability — the kind that investors, banks, and even other licensed platforms can trust. And that makes everything else — scaling, partnerships, user acquisition — much more realistic.
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