AFM MiCAR

AFM MiCAR is the supervision of the EU regulation on markets in crypto-assets by the Dutch Authority for the Financial Markets (AFM). The AFM decides on license applications from crypto-asset service providers and receives the notifications of banks and other financial firms. A provider licensed by the AFM may serve clients across the EU and EEA after a cross-border notification.

Before MiCAR, Dutch crypto firms registered with De Nederlandsche Bank under the anti-money laundering law. The Netherlands chose a transitional period of only six months, so registered firms needed a MiCAR license by the middle of 2025. Several firms had their license on the first day the rules applied, 30 December 2024.

The AFM as competent authority for crypto-asset services

The AFM handles license applications from crypto-asset service providers under Article 63 of MiCAR and notifications from other financial institutions under Article 60. A notifying firm can be a credit institution, an investment firm, an e-money institution or a fund manager that already holds a Dutch license. The AFM publishes a step-by-step procedure for applicants and a newsletter with periodic crypto updates for the sector.

Six months of transition and the first licenses

The Netherlands reported a transitional period of six months to ESMA, as the ESMA list of grandfathering periods shows. A firm registered with De Nederlandsche Bank before 30 December 2024 could keep working only until the end of June 2025 without a MiCAR license. Germany and Austria allowed twelve months, and France allowed the full eighteen months.

MoonPay Europe, BitStaete and Zebedee Europe received their licenses on 30 December 2024, the day the rules for crypto-asset service providers applied. Latvia, Hungary, Poland, Slovenia and Finland also chose six months for their MiCA transitional period.

Who holds a MiCAR license in the Netherlands

The ESMA interim register of 18 October 2026 lists 29 crypto-asset service providers with the Netherlands as home member state. Twenty-two of them hold a license under Article 63, and seven firms provide crypto services after an Article 60 notification. Bitvavo is licensed for custody, a trading platform and transfers, which it may passport into 30 countries.

The notifying firms include the neobank Vivid Money, the trading venue operator One Trading and ClearBank Europe, which notified in April 2026. Webull Securities (Europe) and BitPay are among the most recent additions to the Dutch part of the register.

Finance Loop and MiCAR in the Netherlands

Finance Loop connects compliance and digital asset teams in Germany with firms that serve German clients from a Dutch license, such as Bitvavo and MoonPay. At the Bybit EU Crypto Evening in Frankfurt, Mykolas Majauskas, Senior Director of Policy, spoke about compliance under MiCAR. Finance Loop also lists the MiCAR certificate program that EBS Executive School runs with the law firm HEUKING.

Upcoming events on crypto regulation

The AFM register of crypto-asset service providers

The AFM keeps a register of crypto-asset service providers with every license and notification it has granted or received. Providers licensed in another member state appear in the ESMA register instead, together with the countries they passport into.

Applying for a MiCAR license (vergunning)

A firm applies to the AFM for a license, called vergunning in Dutch, through the forms the AFM publishes for MiCAR applications. The application has to show the governance, own funds, custody arrangements and controls against money laundering that MiCAR requires. The requirements for a CASP license are the same in every member state.

The Article 60 notification (notificatie)

A bank or another licensed financial firm that wants to offer crypto services files a notification, called notificatie in Dutch, with the AFM. The firm does not need a second license, but it may start its crypto services only after the AFM has received complete information.

Questions to the AFM about MiCAR

The AFM answers questions about its supervision of crypto products and services by email at crypto@afm.nl and publishes answers to frequent questions. In September 2026 the AFM published a non-paper with its view on the evaluation of MiCAR.

MiCAR in the Netherlands and the EU passport

MiCAR applies in the Netherlands as it does in every member state, and the Dutch implementing act names the AFM as supervisor of crypto-asset service providers. A Dutch license is valid across the EU, so a provider such as Bitvavo can serve German clients after its notification to the AFM has reached BaFin.

MiCAR in the Netherlands and Finance Loop

Finance Loop covers MiCA in its Risk & Compliance track, including the Dutch licenses that Bitvavo and MoonPay passport into Germany. Finance Loop brings compliance officers of banks, brokers and crypto firms together with lawyers and supervisors at events in Frankfurt, Munich, Berlin and Hamburg.

Finance Loop is a professional network and has the goal of driving the institutional use of emerging technologies in finance, such as AI, tokenization, stablecoins, and DeFi. Finance Loop helps its members build skills and personal networks in these fields: Investment & Digital Assets, Payments & Digital Money, Digital Infrastructure & Sovereignty, and Risk & Compliance.

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