Regulated United Europe OÜ
Registration number: 14153440
Anno: 16.11.2016
Phone: +372 56 966 260
Email: info@rue.ee
Address: Laeva 2, Tallinn, 10111, Estonia
Crypto License in Netherlands
In 2026, a Dutch crypto business typically needs CASP authorization under MiCA, not the legacy AML-only model. The Netherlands combines AFM authorization with DNB prudential oversight.
Book a CASP readiness assessment
Regulator
AFM/DNB
Timeframe
From 6 months
Cost
28 900 EUR
Capital
From 50 000 EUR
Scope, custody model and readiness level materially affect timing and budget
What a crypto license in Netherlands means in 2026
A crypto license in Netherlands now means, in most cases, authorization as a Crypto-Asset Service Provider (CASP) under MiCA. The pre-MiCA Dutch regime built around DNB AML registration is no longer the main route for firms that provide regulated crypto-asset services in the EU market.
For founders, boards and compliance leads, the Dutch proposition is clear: a serious EU jurisdiction with strong supervisory expectations, real substance requirements and access to MiCA passporting after authorization and notification. The practical question is not whether the Netherlands is “easy”, but whether your model, governance and compliance stack are mature enough for Dutch scrutiny.
At RUE, we structure Dutch CASP projects around the full regulatory stack: MiCA + TFR/Travel Rule + Wwft + sanctions + governance + tax and substance. That is the difference between filing an application and building an operating business that can survive post-license supervision.
RUE supports Dutch CASP projects from scoping to filing readiness: service mapping, corporate setup, governance design, AML and Travel Rule framework, fit-and-proper preparation, application drafting and post-license operating support. Where needed, we align the licensing track with accounting, banking and Dutch substance planning.
Post-MiCA authorization framework
In 2026, the relevant route is generally CASP authorization under MiCA. Legacy AML registration should not be confused with a full MiCA authorization.
Split supervisory model
The Dutch model is functionally split between AFM and DNB. Applicants should prepare for conduct, governance and prudential scrutiny rather than a single-point review only.
EU passporting potential
A Dutch CASP may provide cross-border services across the EU after authorization and the required passporting notification. This is not the same as instant operational freedom in every market.
Travel Rule and AML depth matter
Dutch readiness is not just a policy pack. Regulators expect workable controls for CDD/EDD, sanctions screening, wallet risk analysis, suspicious transaction reporting and Travel Rule operations.
Crypto License in Netherlands
28,900 EUR
Package includes (8)
- Preparation of necessary documents for registration of a new company in Netherlands
- Translation of a certificate of no criminal record through a sworn translator
- Payment of state fees related to company registration
- Payment of notary fees related to company registration
- Preparation of compliance documents for MiCA application
- Preparation of a business plan
- Submission of the necessary documents to AFM/DNB
- Recruitment of local MLRO/Compliance officer
Timeframe: From 6 months
Additional Services
MiCA structuring & jurisdiction selection advisory within the EU
from 2,900 EUR
Legal qualification of tokens (utility vs EMT vs ART vs financial instrument under MiFID II)
from 3,900 EUR
Pre-application gap analysis and readiness assessment
from 4,900 EUR
Regulatory risk memo for business model validation
from 2,900 EUR
Cross-border structuring for non-EU founders entering the EU market
from 5,900 EUR
Annual compliance reviews and internal audits
from 4,900 EUR/year
Updating policies in line with ESMA / EBA guidelines
from 1,900 EUR
Assistance with opening crypto-friendly bank accounts / EMIs
from 2,900 EUR
Core requirements for a Dutch CASP
A Netherlands CASP application is assessed on business model clarity, governance credibility, AML/CTF operability, ICT resilience and financial sustainability. The regulator does not review documents in isolation; it checks whether the operating model, website, client journey, outsourcing map and internal policies describe the same business.
The practical baseline usually includes:
- a Dutch legal entity with real operational substance;
- clear mapping of each service to the relevant MiCA authorization scope;
- management and key function holders able to pass fit-and-proper review;
- minimum own funds corresponding to the applicable CASP class;
- effective AML/CTF, sanctions and Travel Rule controls under the broader Dutch and EU framework;
- documented outsourcing, custody, incident response and complaints-handling arrangements.
A recurring Dutch issue is overreliance on group outsourcing without local control. If critical functions are delegated, the applicant still needs demonstrable oversight, escalation rights, board visibility and auditable vendor governance.
Dutch entity and operational substance +
The applicant should have a real establishment in the Netherlands, not a mailbox structure. Substance is assessed in context: office, decision-making, management availability, local records and effective control over outsourced functions all matter.
Service mapping under MiCA +
The application must identify exactly which crypto-asset services are provided: custody and administration, exchange, execution, reception and transmission of orders, placing, transfer services, advice or portfolio management where applicable. Authorization is activity-based, not branding-based.
Minimum own funds +
MiCA capital thresholds commonly referenced for CASPs are EUR 50,000, EUR 125,000 and EUR 150,000, depending on the service class. The highest-risk service in scope generally drives the minimum own-funds requirement.
Fit-and-proper management review +
Directors, qualifying shareholders and key function holders may be assessed for reputation, competence, time commitment and conflicts of interest. In practice, weak CV-to-role alignment and unclear reporting lines are frequent friction points.
AML, sanctions and Travel Rule framework +
The Dutch compliance stack extends beyond MiCA. Firms should be ready for customer due diligence, enhanced due diligence, sanctions and PEP screening, suspicious transaction reporting to FIU-Nederland, and crypto transfer data controls under the recast TFR.
ICT security and custody controls +
Applicants should document access control, key management, segregation of duties, logging, backup, incident handling, wallet security and vendor oversight. For custody models, regulators typically focus on how private keys are generated, stored, recovered and access-controlled.
Jurisdiction Comparison
Compare Netherlands with other jurisdictions by key conditions for obtaining and operating a MiCA/CASP license: regulator, review period, fees, capital, local substance, and passporting.
* This table focuses on MiCA/CASP authorization conditions. Use the settings icon to customize countries and parameters.
Taxes and cost framing for crypto companies in the Netherlands
Dutch tax analysis should be separated from licensing analysis. A CASP authorization does not determine the final tax treatment of the business, and the VAT position of crypto-related services can differ materially depending on the exact service performed, contractual structure and whether the activity is treated as a financial-service-type exemption or a taxable advisory/technology service.
For planning purposes in 2026, founders usually review four layers in parallel:
- corporate income tax on taxable profits;
- VAT treatment of each revenue stream;
- wage tax and payroll obligations for Dutch substance;
- cross-border structuring, transfer pricing and withholding considerations where a group structure is used.
Where licensing budget is concerned, minimum regulatory capital should not be confused with total launch cash. A more realistic formula is: minimum own funds + 12-month operating burn + compliance reserve + technology/security reserve + professional fees. For many Dutch CASP projects, the total implementation budget materially exceeds the formal capital threshold.
Corporate income tax
Dutch corporate tax applies to taxable profits of the company.
verify current rate
Corporate income tax
Dutch corporate tax applies to taxable profits of the company.
The Netherlands applies corporate income tax on company profits. Because tax bands and thresholds can change, the applicable rate should be confirmed with Belastingdienst or Dutch tax counsel at the time of structuring and filing. For related guidance, see our page on Netherlands crypto tax.
VAT
The standard Dutch VAT rate is 21%, but some crypto-related services may be exempt.
21%
VAT
The standard Dutch VAT rate is 21%, but some crypto-related services may be exempt.
The standard VAT rate in the Netherlands is 21%. That does not mean every crypto service is taxed at 21%. Exchange-type services may be treated differently from software, consulting, token design, marketing or ancillary operational services. Blanket statements that “crypto is VAT exempt” are too broad for transaction planning.
Payroll and wage taxes
Relevant where the Dutch entity has employees or local directors on payroll.
case-specific
Payroll and wage taxes
Relevant where the Dutch entity has employees or local directors on payroll.
If the Dutch CASP has local staff, management or secondees, payroll registration and wage tax compliance should be planned early. This is often overlooked in licensing budgets, especially where local substance is built shortly before filing.
Withholding and group structuring
Cross-border payments may trigger additional review depending on the structure.
case-specific
Withholding and group structuring
Cross-border payments may trigger additional review depending on the structure.
In group structures, founders should review transfer pricing, intercompany service charges, IP ownership, financing flows and any withholding implications. Tax substance that contradicts licensing substance is a common red flag in regulated group setups.
Ongoing compliance after Dutch CASP authorization
A Dutch crypto license is not a one-time filing exercise. In 2026, the operating burden usually includes governance, AML/Travel Rule operations, incident handling, outsourcing oversight and recurring policy refresh.
Governance and control framework
- Board oversight, clear reporting lines and conflict-of-interest management
- Periodic review of policies, procedures and internal controls
- Documented complaints handling and client communication controls
- Change management when services, jurisdictions or outsourcing arrangements evolve
AML, sanctions and FIU reporting
- CDD, EDD and ongoing monitoring under the Dutch AML framework
- Sanctions, PEP and adverse media screening with escalation logic
- Suspicious transaction reporting to FIU-Nederland where triggers arise
- Travel Rule data capture, verification and exception handling for crypto transfers
ICT, custody and outsourcing
- Access control, logging, incident response and business continuity testing
- Custody governance for wallet infrastructure, key management and recovery
- Vendor due diligence, contractual controls and ongoing outsourced-function oversight
- Evidence that critical providers can be monitored, challenged and, if needed, replaced
Recurring operational workload
- Annual or periodic training for AML, sanctions, security and complaints handling
- Financial reporting, audit and accounting support as applicable
- Record retention and evidence management for regulator queries
- Continuous alignment between website disclosures, onboarding flow and licensed scope
RUE handles compliance for you. Our team provides ongoing compliance support, including AML officer services, regulatory reporting, and policy updates. We ensure your license stays in good standing year after year.
Contact us for compliance support →
📝 Check Your Eligibility
Answer a few quick questions to find out if this jurisdiction suits your crypto business
Step 1 of 5
What type of crypto services will you provide?
Exchange (fiat ↔ crypto)
Custody & Wallet Services
Transfer & Payment Services
Advisory / Portfolio Management
Multiple / All of the Above
Step 2 of 5
What is your target market?
European Union only
EU + Global markets
Global (non-EU priority)
Step 3 of 5
Do you already have a registered company in the EU?
Yes, in this jurisdiction
Yes, in another EU country
No, I need to register one
Step 4 of 5
What is your available budget range?
Under €20,000
€20,000 – €50,000
€50,000 – €100,000
Over €100,000
Step 5 of 5
When do you plan to launch?
As soon as possible (1–3 months)
Within 6 months
Within a year
Just exploring options
This Jurisdiction Is a Great Fit!
Based on your answers, this jurisdiction matches your business requirements well. Here's a quick summary:
Recommended License
CASP License
Estimated Budget
€24,000 – €35,000
Estimated Timeframe
4–6 months
EU Passporting
Available
How we handle a Dutch CASP project
Step 1
Scope analysis
We classify the business model under MiCA, identify whether custody, exchange, transfer, advisory or platform elements are in scope, and define the likely capital tier.
Step 2
Structure setup
We align the Dutch entity, ownership chain, substance model, management roles and banking strategy with the intended authorization scope.
Step 3
Document build
We prepare the program of operations, governance set, AML and Travel Rule framework, outsourcing file, financial model and fit-and-proper package.
Step 4
Readiness review
We test consistency across policies, website wording, onboarding flow, client terms, vendor map and risk controls before formal submission.
Step 5
Application filing
We support submission, regulator communication and evidence management during completeness checks and formal review.
Step 6
Q&A and remediation
We coordinate responses to AFM and DNB questions, refine documents where needed and help management prepare for deeper supervisory scrutiny.
Step 7
Post-license support
After authorization, we assist with compliance operations, accounting coordination, policy refresh, banking documentation and change-management planning.
Answers
Frequently Asked Questions
Open the key issues founders, compliance teams and legal leads usually need to confirm before launch.
Do you still need only a DNB registration in the Netherlands in 2026? +
No. In 2026, firms providing regulated crypto-asset services generally need CASP authorization under MiCA, not reliance on the old AML-only registration concept. Legacy Dutch registration should not be treated as equivalent to a full MiCA authorization.
Who regulates a crypto license in Netherlands? +
The Dutch framework involves AFM and DNB, with FIU-Nederland relevant for suspicious transaction reporting. In practice, applicants should prepare for both conduct and prudential scrutiny, not a single-topic review.
How long does a Dutch CASP license take? +
The statutory review benchmark often cited is 105 working days after a complete application is accepted for review. Real end-to-end timing is often around 5-8+ months, because pre-filing preparation and regulator Q&A usually take substantial time.
What is the minimum capital for a crypto license in Netherlands? +
The commonly referenced MiCA own-funds tiers for CASPs are EUR 50,000, EUR 125,000 and EUR 150,000. The applicable threshold depends on the services provided, and the highest-risk service in scope usually drives the minimum level.
Can a foreign shareholder own a Dutch CASP? +
Yes, foreign ownership is possible, but ownership transparency matters. The authorities may review the shareholding chain, UBO information, source-of-funds context and the suitability of qualifying holders. Opaque structures create avoidable friction.
Do I need a Dutch office and local substance? +
Yes, real substance is generally expected. The Netherlands is not designed for mailbox-only regulated structures. The exact level of substance should be proportionate to the service scope, risk profile and outsourcing model, but effective local control is a core issue.
Can a startup with no prior revenue apply for a Dutch crypto license? +
Yes, a startup can apply, but no-revenue status does not reduce regulatory expectations. The key issue is whether the applicant can show credible funding, realistic projections, competent management and an operationally workable compliance framework from day one.
Is custody harder to license than brokerage or advisory? +
Usually yes. Custody models tend to attract deeper scrutiny because they raise questions around private key control, segregation, recovery, access management, incident response and client asset protection. They also often push the project into a higher capital tier.
Do Dutch CASPs need Travel Rule software from launch? +
They need a workable Travel Rule operating model from launch where the rules apply. Whether that is handled through a software vendor, internal tooling or a hybrid workflow depends on the business, but manual, undocumented handling is usually not enough for scale.
Does a Dutch CASP license automatically allow services across the whole EU? +
Not automatically in the everyday sense. A Dutch CASP may use MiCA passporting across the EU after authorization and the required notification process. Passporting helps with market access, but local practical issues such as banking, consumer-facing conduct and marketing implementation still matter.
Will a Dutch crypto license guarantee a bank account? +
No. Licensing may improve the firm’s credibility, but banks and payment providers still apply their own risk-based onboarding standards. They typically assess AML maturity, sanctions exposure, source of funds, transaction profile and management credibility.
What happens if the business model changes after authorization? +
A material change in services, jurisdictions, outsourcing, custody design or governance should be assessed before implementation. In regulated practice, post-license change management is critical because the licensed scope, policy pack and real operating model must remain aligned.
What are the main ongoing obligations after approval? +
The main obligations usually include governance maintenance, AML/CTF operations, sanctions screening, suspicious transaction reporting where required, Travel Rule handling, incident response, outsourcing oversight, record retention, accounting support and periodic policy review.
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Regulated United Europe
