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Netherlands

The Netherlands regulates crypto under MiCA through amendments to the Financial Supervision Act (Wft), with the AFM as the lead CASP authority and DNB on prudential and ART/EMT supervision; it took one of the EU's shortest transitions, ending 30 June 2025, and granted some of the EU's first CASP licences. Payments and e-money run under the Wft (PSD2/EMD2), supervised by DNB, with the Instant Payments Regulation and DORA in force and PSD3/PSR moving toward adoption. Gambling is regulated by the Kansspelautoriteit (KSA) under the Betting and Gaming Act and the Remote Gambling Act, with online gambling taxed on gross gaming revenue at a rising rate (37.8% in 2026) plus a levy — and the Netherlands is in the euro area and banking union, and taxes private crypto holdings under the Box 3 wealth-tax system rather than as capital gains.

Available licences

Crypto-Asset Service Provider authorisation (AFM under MiCAR and the Wft)

Custody, operation of a trading platform, exchange of crypto-assets for funds or other crypto-assets, execution, placing, reception and transmission of orders, advice, portfolio management and transfer services require authorisation under Article 63 MiCAR, with the AFM as lead authority and DNB on prudential aspects; an authorisation passports across the EEA.

Asset-Referenced Token (ART) issuer authorisation (DNB)

Public offering or admission to trading of a token referencing a basket of values, rights or currencies requires authorisation as an ART issuer under Title III MiCAR, with DNB as prudential supervisor.

E-Money Token (EMT) issuer (credit institution or EMI; DNB)

EMTs (including fiat-backed stablecoins) may be issued only by an authorised credit institution or e-money institution, with redemption at par; DNB is the prudential supervisor.

Article 60 MiCAR notification route (existing financial entities)

Credit institutions, investment firms, e-money and payment institutions and other authorised entities may provide specified crypto-asset services by notifying the AFM at least 40 working days before starting.

Payment Institution authorisation (DNB under the Wft)

A licence to provide payment services under the Financial Supervision Act, supervised by DNB and passportable across the EEA.

E-Money Institution authorisation (DNB)

A licence to issue electronic money and provide related payment services, with EUR 350,000 minimum initial capital, supervised by DNB.

Account Information and Payment Initiation Services (DNB/AFM)

Open-banking providers — account information and payment initiation service providers — fall within the Wft, with strong customer authentication under PSD2.

Banking authorisation (DNB and the ECB/SSM)

Deposit-taking and lending require a banking licence; in the banking union the European Central Bank grants the licence and directly supervises significant institutions, with DNB supervising less-significant ones.

Investment firm authorisation (AFM/DNB — MiFID II)

Investment services in financial instruments require authorisation under the Wft transposing MiFID II, with the AFM on conduct and DNB on prudential supervision.

Remote (online) gambling licence (KSA)

A licence under the Remote Gambling Act to offer online casino, peer-to-peer poker, sports betting and horse-race betting to Dutch players, with mandatory CRUKS self-exclusion checks and a control database in the Netherlands.

Land-based gambling licences (KSA and municipalities)

Land-based casinos (Holland Casino), slot-machine arcades (with municipal approval), lotteries and betting are licensed by the KSA under the Betting and Gaming Act.

Detailed overview

Netherlands at a glance

The Netherlands combines a twin-peaks financial supervisor, a dense retail crypto-exchange market and a strict, high-tax gambling regime. Crypto is supervised by the AFM (lead) and DNB under the Wft; the short transition ended 30 June 2025. Payments run under the Wft with DNB as supervisor and the Instant Payments Regulation and DORA in force. Gambling runs under the Betting and Gaming Act and the Remote Gambling Act, supervised by the KSA. The euro is the currency, and the Netherlands sits inside the euro area and banking union.

Crypto regime under MiCA — AFM-led, dense retail market:

  • MiCA + national implementing law — Regulation (EU) 2023/1114 (MiCAR); implemented through amendments to the Wft and the Wwft, designating the AFM and DNB
  • Competent authorities — the AFM for CASP licensing and conduct; DNB for ART/EMT prudential supervision, prudential requirements for CASPs and AML integrity
  • Grandfathering — closed. The Netherlands chose a short six-month transition: VASPs registered with DNB before 30 December 2024 could continue until 30 June 2025, after which a MiCAR licence is required; that window has expired
  • Pre-MiCA heritage — a DNB VASP register (AML-only under the Wwft); MiCA adds full prudential and conduct requirements and EU passporting
  • Early CASP licences — the AFM issued some of the EU's first CASP authorisations (including MoonPay and BitStaete), and the Netherlands now has a high density of licensed consumer-facing exchanges (Bitvavo, Finst, Coinmerce and others)
  • Substance — a Dutch entity with a real operational office (no mailbox), fit-and-proper management (at least one EU-resident director), AML/KYC, ICT and governance policies
  • AML/CFT — the Wwft and Sanctions Act 1977 apply, with AFM now supervising CASP AML; the EU AML package (Regulation (EU) 2024/1624 / AMLR, with AMLA in Frankfurt) applies from 10 July 2027
  • TFR / DORA — the Travel Rule (Regulation (EU) 2023/1113) applies from 30 December 2024 and DORA from 17 January 2025 (DNB-supervised)
  • Tax — private holders are taxed under the Box 3 wealth-tax system, not on capital gains: crypto is an "other asset" taxed on a deemed return (around 6% for investments) at a 36% rate, above a tax-free allowance (around EUR 57,000 per person), assessed on 1 January value. Following a 2024 Supreme Court ruling, transitional rules (2025–2027) let taxpayers be taxed on actual return where lower, and a proposed reform would tax actual returns (including unrealised gains) from 2028, subject to Senate approval. Professional trading is taxed in Box 1 (progressive, up to 49.5%); corporate income tax is 25.8% (19% on the first EUR 200,000)

Payments and e-money regime (DNB-led):

  • PSD2 — Directive (EU) 2015/2366; transposed by the Wft, supervised by DNB (with AFM on conduct)
  • Payment Institution licensing — initial capital EUR 20,000 (money remittance), EUR 50,000 (payment initiation) and EUR 125,000 (other payment services)
  • EMD2 / E-Money Institution — Directive 2009/110/EC; EUR 350,000 initial capital; stablecoin (EMT) issuers must be EMIs or credit institutions
  • Instant Payments Regulation (Regulation (EU) 2024/886) — euro instant payments: receiving applicable from 9 January 2025 and sending from 9 October 2025
  • DORA (Regulation (EU) 2022/2554) — applicable from 17 January 2025
  • PSD3 / PSR — Commission proposals of 28 June 2023; provisional political agreement reached 27 November 2025, with final compromise texts published 23 April 2026 and formal adoption expected during 2026; the package will repeal PSD2 and EMD2 and fold e-money institutions into payment institutions
  • Banking — in the banking union the ECB grants banking licences and directly supervises significant institutions, with DNB supervising less-significant ones; the Netherlands is a strong fintech and payments market
  • Currency: euro (founding member); no exchange controls

Gambling regime — KSA-licensed, strict and high-tax:

  • Betting and Gaming Act 1964 (Wet op de kansspelen) and the Remote Gambling Act (Koa) — online gambling has been licensed since 1 October 2021
  • Regulator — the Kansspelautoriteit (KSA), an independent authority licensing and supervising land-based and online gambling
  • Remote licences — five-year licences for online casino, P2P poker, sports betting and horse-race betting; the first cohort begins expiring on 30 September 2026
  • Tax — gambling tax on gross gaming revenue, raised from 30.5% (2024) to 34.2% (2025) and 37.8% (2026), plus a 1.95% levy — an effective burden near 40% of GGR
  • Player protection — mandatory CRUKS self-exclusion register, a strict duty of care, deposit limits (lower for 18–24-year-olds) and KYC; crypto/virtual currencies are not permitted for gambling
  • Advertising — a near-total ban on untargeted advertising (since 2023), with sports sponsorship banned from July 2025 and strict 24+ targeting rules
  • Reform and age — the minimum age for high-risk games (e.g. online slots) is being raised to 21, and a broader overhaul of the Remote Gambling Act is under way
  • No EU passport — gambling is licensed nationally

Last verified: July 2026. Reference rate: USD 1 = EUR 0.87 (EUR 1 = USD 1.15).

The Netherlands is a twin-peaks, euro-area jurisdiction: crypto runs under MiCAR with the AFM leading and a dense retail-exchange market, payments sit under the Wft with DNB, and gambling is a strict, high-tax KSA-licensed market with a near-total advertising ban.

Is there a crypto licence in the Netherlands?

Yes. The Netherlands applies MiCAR through the Wft, with the AFM as lead CASP authority and DNB on prudential and ART/EMT supervision. The short transition ended 30 June 2025, so operating now requires an AFM authorisation, a valid MiCA passport, or an Article 60 notification.

The legal foundation:

  • Regulation (EU) 2023/1114 (MiCAR) — the directly applicable EU framework for offerings, admission and crypto-asset services
  • Financial Supervision Act (Wft) — amended to designate the AFM and DNB and assign enforcement powers
  • Wwft and Sanctions Act 1977 — AML/CFT and sanctions obligations
  • Regulation (EU) 2023/1113 — Travel Rule for crypto-asset transfers

Structure:

  • A Dutch entity (typically a BV) with a real operational office and fit-and-proper management (at least one EU-resident director)
  • MiCAR own-funds floors by class — EUR 50,000 (Class 1), EUR 125,000 (Class 2), EUR 150,000 (Class 3) — with the higher of the floor or a fixed-overheads measure
  • AML systems, a white paper for in-scope offerings, custody and client-asset segregation, ICT and governance policies, professional indemnity insurance, and a business plan — submitted to the AFM/DNB after pre-application consultation

Operational reality:

  • The Netherlands moved early and has a dense, consumer-facing exchange market, making it a natural home for retail-focused CASPs
  • The AFM expects genuine Dutch substance and robust IT and consumer-protection arrangements; mailbox structures are rejected
  • New activity should be structured through an AFM authorisation, a valid passport or an Article 60 notification — not the closed transitional regime

Official CASP roadmap: The AFM is the lead CASP authority, maintains a public crypto register, publishes MiCAR application guidance and offers pre-application consultations (with DNB on prudential and ART/EMT matters); the short transition ended 30 June 2025.

Payments & E-money (DNB — PSD2 / EMD2)

Best for payment, remittance, acquiring, wallet and e-money operators that want a strong euro-area fintech market.

What it is: Authorisation as a payment institution or e-money institution under the Wft, supervised by DNB (with AFM on conduct) and passportable across the EEA.

Who it suits: Money-remittance and transfer providers, acquirers, card and wallet issuers, payment-initiation and account-information providers, and e-money issuers (including stablecoin issuers, who must be EMIs or credit institutions).

Covers: The payment services under the Wft — incoming and outgoing transactions, transfers, card and instrument-based payments, money remittance, payment initiation and account information — plus issuance of electronic money.

Operational requirement: A Dutch entity; minimum initial capital by service type; ongoing own-funds and safeguarding of client funds; strong customer authentication; AML/CFT; DORA operational-resilience obligations; and fit-and-proper management.

Headline figures

  • Primary instruments: Financial Supervision Act (Wft) (PSD2 / EMD2); Instant Payments Regulation (EU) 2024/886; DORA (Regulation (EU) 2022/2554)
  • Regulator: DNB (authorisation and prudential supervision); AFM (conduct)
  • Entry capital: payment institutions EUR 20,000 / 50,000 / 125,000 by service type; e-money institutions EUR 350,000
  • Instant payments: euro instant payments receiving from 9 January 2025 and sending from 9 October 2025
  • Reform pipeline: PSD3 / PSR — political agreement November 2025, compromise texts April 2026, adoption expected during 2026; EMD2 to be repealed and EMIs folded into payment institutions
  • Currency: euro (euro-area member); no exchange controls

Is there a gambling licence in the Netherlands?

Yes. The KSA licenses online casino, poker, sports betting and horse-race betting under the Remote Gambling Act — but the regime is strict and heavily taxed, with rising GGR tax and a near-total advertising ban.

The legal foundation:

  • Betting and Gaming Act 1964 (Wet op de kansspelen) — the umbrella statute
  • Remote Gambling Act (Koa, in force 1 October 2021) — the online regime, with the Remote Gambling Decree and advertising/addiction rules
  • KSA — licensing, supervision and enforcement

Structure:

  • Remote licences (five-year term) cover online casino, P2P poker, sports betting and horse-race betting
  • Operators must connect to CRUKS, host a control database in the Netherlands, and meet strict duty-of-care and advertising rules
  • Land-based gambling (Holland Casino, arcades, lotteries) is separately licensed

Gambling — Remote (online) gambling licence (KSA)

Best for operators able to absorb a near-40% effective tax-and-levy burden and meet the Netherlands' strict player-protection and advertising rules.

What it is: A KSA five-year remote licence to offer online casino, poker, sports betting and horse-race betting.

Who it suits: Well-capitalised operators able to meet integrity (Bibob), technical and duty-of-care requirements.

Covers: Online casino, P2P poker, sports betting and horse-race betting.

Operational requirement: CRUKS integration, a Dutch control database, deposit limits, KYC, addiction-prevention duty of care, advertising compliance, and AML/CFT (no crypto payments).

Headline figures

  • Primary instruments: Betting and Gaming Act 1964; Remote Gambling Act (Koa)
  • Regulator: Kansspelautoriteit (KSA)
  • Application fee: EUR 48,000 (non-refundable), plus a financial guarantee
  • Tax: GGR-based gambling tax — 37.8% in 2026 (up from 34.2% in 2025) — plus a 1.95% levy
  • Player protection: CRUKS self-exclusion, deposit limits (lower for 18–24), near-total advertising ban; minimum age 18 (rising to 21 for high-risk games)

Costs and timelines at a glance

  • Crypto: MiCAR via the Wft, AFM (lead) and DNB; own-funds floors EUR 50,000 / 125,000 / 150,000 by class; 25-working-day completeness plus 40-working-day assessment; transition closed 30 June 2025
  • Payments primary instruments: Wft (PSD2 / EMD2); Instant Payments Regulation (EU) 2024/886; DORA
  • Payments regulator: DNB (prudential), AFM (conduct); banking licences via the ECB/SSM (banking-union member)
  • Reform pipeline: PSD3 / PSR — agreement November 2025, compromise texts April 2026, adoption expected during 2026
  • Gambling: KSA five-year remote licences; GGR tax 37.8% (2026) plus 1.95% levy; EUR 48,000 application fee; near-total ad ban
  • Tax: corporate income tax 25.8% (19% on first EUR 200,000); private crypto taxed under Box 3 (deemed return at 36%), professional trading in Box 1
  • Currency: euro (euro-area and banking-union member); no exchange controls
  • FX: USD 1 = EUR 0.87 (EUR 1 = USD 1.15)

Who the Netherlands suits and who it does not

Suitable for

  • Retail-focused crypto exchanges, custodians and brokers wanting a MiCAR CASP authorisation in a dense, consumer-facing market with EEA passporting
  • Crypto and fintech firms that value an early-moving regulator and a deep payments ecosystem
  • Payment, remittance, acquiring, wallet and open-banking operators wanting a strong euro-area fintech base
  • Already-licensed banks, investment firms, payment and e-money institutions that can add crypto-asset services through the Article 60 notification route
  • Well-capitalised gambling operators able to absorb high tax and strict player-protection rules

Not suitable for

  • Crypto holders expecting capital-gains-style treatment — private holdings are taxed under the Box 3 wealth-tax system, with no long-term-hold incentive
  • Mailbox or low-substance structures — the AFM requires a real Dutch office and management
  • Gambling operators sensitive to tax — the GGR tax is 37.8% in 2026 plus a 1.95% levy, and advertising is heavily restricted
  • Gambling operators relying on crypto payments — virtual currencies are not permitted in the Dutch regime
  • Payment or e-money firms expecting to avoid EU prudential, safeguarding, DORA or AML obligations

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