How to get a crypto license in Netherlands: step-by-step for 2026
The Netherlands will require all crypto service providers to hold a license under the upcoming MiCA framework by 2026, making early preparation essential for any crypto founder targeting the EU market.
Understanding the Dutch Crypto License Under MiCA
From 2026, the Markets in Crypto Assets Regulation (MiCA) will be fully enforceable across the European Union, including the Netherlands. The Dutch Authority for the Financial Markets (AFM) will act as the primary regulator for crypto asset service providers (CASPs). Under MiCA, CASPs are divided into three capital tiers based on the services they offer: EUR 50,000 for certain minor services, EUR 125,000 for standard services like exchange and custody, and EUR 150,000 for more complex activities such as operating a trading platform. These capital requirements must be met with own funds, and firms must also maintain professional indemnity insurance or a combination of capital and insurance.
The Netherlands currently operates a registration regime under the Anti Money Laundering and Counter Financing of Terrorism Act (Wwft), but this will be replaced by the full MiCA license. Firms already registered under Wwft will need to transition to the new license. The AFM expects all applicants to demonstrate strong governance, a clear business model, and comprehensive AML/CFT policies. The application process is rigorous and typically takes 6 to 12 months, depending on the complexity of the services and the completeness of the application.
Step 1: Pre Application Preparation and Legal Structure
Before submitting a license application, you must establish a legal entity in the Netherlands. This is typically a private limited liability company (BV). The BV must have its registered office and central administration in the Netherlands. You will need to draft articles of association that comply with Dutch corporate law and include specific clauses related to crypto activities. The company must have at least one director who is a resident of the EU or, if not, the company must appoint a local representative acceptable to the AFM.
You should also prepare a detailed business plan that outlines the types of crypto services you intend to offer, your target market, revenue model, and operational structure. The AFM requires a clear description of the custody arrangements for client assets, including whether you will hold private keys or use third party custodians. Additionally, you must have a strong AML/CFT compliance program in place, including customer due diligence procedures, transaction monitoring, and suspicious transaction reporting. It is advisable to engage a local compliance consultant or legal advisor with experience in AFM applications.
Step 2: Capital Requirements and Insurance
Meeting the capital requirements is a critical part of the application. As noted, the minimum capital depends on your service classification. For most CASPs offering exchange and custody services, the requirement is EUR 125,000. This capital must be held in liquid assets such as cash or government bonds and must be maintained at all times. The AFM may require a higher amount if your business volume or risk profile warrants it. You will need to provide evidence of the capital through audited financial statements or a bank confirmation.
In addition to capital, MiCA requires professional indemnity insurance (PII) covering the risks of loss of client assets, cyber attacks, and professional negligence. The minimum coverage is typically EUR 1 million per claim and EUR 1.5 million in aggregate per year, but this can vary. Some firms may opt to combine capital and insurance to meet the requirement. You should obtain quotes from insurers specializing in crypto risks and ensure the policy is valid for the entire license period. The AFM will review the insurance terms to confirm they meet the regulatory standards.
Step 3: Submission of the Application to the AFM
Once your documentation is complete, you can submit the formal application to the AFM. The application must include the business plan, capital evidence, insurance policy, governance structure, AML/CFT policies, and details of key personnel. The AFM charges an application fee, which is currently around EUR 5,000 to EUR 10,000, but this may be updated under MiCA. The regulator will assess the application within 3 to 6 months, and may request additional information or clarifications. It is common for the AFM to conduct interviews with the management team.
During the assessment, the AFM will evaluate the suitability of directors and shareholders, including their professional experience, integrity, and financial soundness. All beneficial owners must be disclosed, and any criminal record or regulatory sanctions may disqualify the application. The AFM also checks the operational resilience of the firm, including IT systems, cybersecurity measures, and business continuity plans. If the application is approved, the AFM will issue a license that is valid across the EU under the MiCA passporting regime.
Step 4: Post Licensing Obligations and Ongoing Compliance
After obtaining the license, you must comply with ongoing regulatory requirements. These include periodic reporting to the AFM on financial condition, transaction volumes, and AML/CFT metrics. You must also conduct annual audits of your financial statements and AML/CFT controls. The AFM may conduct on site inspections or request ad hoc information. Any changes to the business model, key personnel, or control structure require prior approval from the AFM.
You are also required to maintain the capital and insurance coverage at all times. If your business grows significantly, the AFM may require additional capital. Client asset protection rules under MiCA mandate that client funds and crypto assets be held separately from the firm's own assets, with clear segregation and reconciliation procedures. Failure to comply can result in fines, suspension, or revocation of the license. It is prudent to invest in a compliance management system and retain a local compliance officer to ensure ongoing adherence.
Alternative Jurisdictions: Panama as a Non MiCA Option
For crypto founders who wish to avoid the stringent MiCA requirements, Panama offers an alternative. Panama does not have a dedicated crypto license. Instead, you can incorporate a Sociedad Anonima (SA), which is a standard corporation. Panama applies a territorial tax system, meaning income sourced outside Panama is taxed at 0%. The setup process takes 2 to 3 weeks and costs approximately USD 1,500 to USD 3,000 including legal fees. There are no capital requirements for a standard SA, though you may need a minimum of USD 10,000 in paid in capital for certain activities.
However, operating from Panama without a crypto license means you cannot provide services to EU residents under MiCA. Panama is suitable for founders targeting non EU markets or those who want a low cost jurisdiction for holding and trading crypto assets. You should also consider that Panama has AML obligations under FATF, and banks may be cautious about onboarding crypto businesses. Consulting24 can assist with both Dutch and Panama setups, depending on your target market and risk appetite.
How to Choose the Right Jurisdiction
Work the decision in this order — customers first, everything else second:
- Who are your customers? EU retail means you need a MiCA passport (Lithuania, Malta or another EU CASP). US customers mean state-by-state money-transmitter licensing or a FinCEN MSB — consider a Canada MSB or a US setup. Latin America, Asia or HNW clients mean an offshore or territorial base such as Panama is usually the better fit.
- Do you need a regulator badge? A public-facing exchange chasing institutional partners and fundraising often needs the reputational lift of an EU, Swiss or VARA licence. An OTC desk or token treasury usually does not.
- What is your budget and timeline? Offshore and territorial routes set up in weeks for tens of thousands; premium onshore licences take many months and six figures.
- What about tax? Territorial-tax jurisdictions like Panama charge 0% on foreign-source income; EU jurisdictions apply standard corporate tax. Factor total cost of ownership, not just setup fees.
For many offshore-first founders, Panama lands at the intersection of fast incorporation, low cost and 0% tax on foreign-source income, which is why it features so heavily in our work. But the honest answer is that the “best” jurisdiction is the one that matches the four answers above — and that is a conversation worth having before you spend a cent. See our cost breakdown and application process to ground the decision in real numbers.
Banking and Compliance: Where Most Setups Actually Stall
Incorporation is the easy part of any crypto project. Banking is where timelines slip and where under-prepared founders lose months. Since 2023, banks and payment processors worldwide have tightened their onboarding of crypto-adjacent businesses, and they now expect a genuinely professional application — not a one-page business summary. A thin file is simply rejected, and re-applying with the same bank is far harder than getting it right the first time.
Three documents do the heavy lifting. The first is a written AML/KYC compliance program: your customer-onboarding flow, transaction-monitoring rules, sanctions and PEP screening, a named compliance officer, and record-keeping policies. The second is a clear, evidenced source-of-funds file for both the company and its beneficial owners. The third is a coherent business description that explains who your customers are, how money moves, and what volumes you project. Banks approve businesses they understand; ambiguity reads as risk.
Sequencing matters as much as substance. The correct order is: incorporate the operating entity, build the compliance program, assemble the source-of-funds package, and only then approach banking — ideally through a warm introduction rather than a cold application. Founders who approach banks mid-setup, before their file is complete, create the very delays they are trying to avoid. We make direct introductions to banks and crypto-friendly payment rails as part of every engagement, but the introduction only works if the file behind it is ready.
None of this is optional, and none of it changes much from one jurisdiction to the next — the compliance bar is now broadly global. What changes is the appetite of local banks and the speed of onboarding. Our requirements checklist sets out exactly what you need to assemble before you approach a bank.
Crypto Licensing in 2026: The Bigger Picture
Choosing where to license a crypto business in 2026 is no longer a simple cost calculation. The regulatory map has hardened considerably over the last three years. In the European Union, the Markets in Crypto-Assets Regulation (MiCA) has replaced the patchwork of national VASP registers with a single Crypto-Asset Service Provider (CASP) authorisation that passports across all 27 member states. That passport is powerful — but it comes with capital requirements, governance obligations and a multi-month authorisation process that smaller projects often underestimate.
Outside the EU, the picture is more varied. Offshore and territorial-tax jurisdictions compete on speed, cost and privacy, while major financial centres such as Switzerland, the UAE and Singapore compete on credibility and institutional access. The Financial Action Task Force (FATF) sits over all of them: its “travel rule” and AML standards now apply, in some form, almost everywhere a serious crypto business would consider basing itself. Jurisdictions that ignore FATF expectations end up grey-listed, which quietly closes correspondent-banking doors for every company registered there.
This is why the question behind How to get a is rarely “which licence is cheapest?” It is “which regime matches my customers, my risk appetite and my banking needs?” An EU-retail exchange and an offshore OTC desk serving high-net-worth clients in Latin America have almost nothing in common in terms of the right base. Getting this decision right at the start saves you from the single most expensive mistake in the industry: licensing in the wrong place and having to re-domicile a live business.
Consulting24 has guided more than 200 crypto company setups across 15+ jurisdictions since 2017, which means we have seen how each of these regimes behaves in practice rather than just on paper. The summary below is the same framework we use with clients — and we are always happy to map it to your specific model. Start with our Panama vs Lithuania comparison to see how the trade-offs play out between an offshore base and an EU-passported one.
Common Mistakes to Avoid
The failures we see when founders research How to get a on their own are remarkably consistent, and almost all of them are avoidable. The first is licensing to the headline tax rate. A 0% jurisdiction is worthless if your customers legally require a regulated provider you cannot become there — you will simply have to start again. Decide who you are allowed to serve first, then optimise for tax.
The second is treating the compliance program as paperwork. The AML/KYC program is not a formality to satisfy a regulator; it is the document your bank reads most closely. A generic template downloaded from the internet is transparent to any compliance officer and will sink your banking application. It needs to reflect your actual product, customer base and risk profile.
The third is underestimating banking lead time. Founders routinely budget for incorporation and forget that the bank account — the thing that actually lets the business operate — can take longer than the licence itself. Build banking into your launch timeline from day one, not as an afterthought.
The fourth is ignoring personal tax residency. A company in a low-tax jurisdiction does not erase your obligations where you personally live. Many founders create unexpected liabilities by structuring the company perfectly and ignoring themselves. We introduce qualified tax advisors precisely to close this gap.
The fifth and most expensive is choosing a provider on price alone. The cheapest setup that results in a rejected bank application or a re-domiciliation is far more expensive than doing it properly once. Ask any provider to itemise their fee and explain their banking track record before you commit.
What Happens After You Are Licensed
Getting licensed and banked is the start, not the finish. Every regulated or registered crypto business carries ongoing obligations, and letting them lapse is how companies lose their standing — and their banking. At minimum you will maintain a registered agent or local presence, file annual renewals or supervision fees, keep accounting records, and keep your compliance program live with periodic reviews and updated sanctions and PEP screening lists.
Most jurisdictions also expect you to keep your beneficial-ownership information current and to report material changes — new directors, new shareholders, a pivot in business activity — promptly. Transaction monitoring is not a one-time setup either; screening rules need tuning as your volumes and customer mix evolve. Banks may request periodic refreshes of your KYC and source-of-funds documentation, particularly after a year of trading or a significant change in activity.
This is why we offer ongoing maintenance on an annual retainer rather than treating setup as a one-off transaction. The cost of staying compliant is a fraction of the cost of losing a banking relationship and having to rebuild one from scratch. Plan for it in your year-two budget from the outset, and treat your compliance function as a living part of the business rather than a box you ticked at launch.
It is also worth planning ahead for growth. A structure that suits a pre-revenue startup may not suit the same company once it is processing meaningful volume, adding new product lines, or expanding into new markets. Many of the businesses we work with begin in a fast, low-cost offshore base to validate the model, then add a second regulated entity — an EU CASP, for example — once revenue justifies the cost and the market access genuinely matters. Designing the first structure with that possible second step in mind keeps your options open and avoids a disruptive re-domiciliation later. We map this growth path out with clients during the initial planning stage so the early decisions support, rather than constrain, where the business is heading.
Consulting24 has completed 200+ crypto company setups across 15+ jurisdictions. Talk to our team for a fixed-fee proposal and realistic timeline.
Learn more WhatsApp usEmail mardo@consulting24.co · Phone +372 58155779
About Consulting24 & Mardo Soo
Founder & CEO, Consulting24 · LinkedIn
Consulting24 is an eight-year-old advisory firm that has completed 200+ crypto company setups across 15+ jurisdictions since 2017. Founder and CEO Mardo Soo and the team specialise in crypto, VASP and exchange licensing — from Panama and the EU (MiCA) to Dubai, Canada and the offshore world. We don't push a single “best” jurisdiction; we map your business to the regime that actually fits, then handle incorporation, the AML/KYC compliance program, and banking and payment-processor introductions end to end.
Every engagement begins with an honest conversation about your customers, budget and timeline and ends with a fixed-fee proposal, so you know the all-in number before you commit. We also introduce vetted local lawyers and tax advisors wherever your structure requires them.
Operated by X24Consulting OÜ (Estonian Business Register code 16971898), Põrdi tn 3-63, 10156 Tallinn, Estonia · mardo@consulting24.co · +372 58155779
Frequently Asked Questions
How to get a crypto license in the Netherlands in 2026?
The process involves incorporating a Dutch BV, preparing a business plan and AML/CFT policies, meeting capital requirements (EUR 50,000 to EUR 150,000 depending on services), obtaining professional indemnity insurance, and submitting a detailed application to the AFM. The AFM assesses the application within 3 to 6 months, and upon approval, the license is valid across the EU under MiCA.
What are the capital requirements for a Dutch crypto license?
Under MiCA, the minimum capital tiers are EUR 50,000 for minor services, EUR 125,000 for standard services like exchange and custody, and EUR 150,000 for operating a trading platform. These amounts must be held in liquid assets and maintained at all times.
How long does it take to get a Dutch crypto license?
The application process typically takes 6 to 12 months from preparation to approval. The AFM's assessment phase alone takes 3 to 6 months, but pre application preparation can add several months.
Can I use a Dutch crypto license to serve clients in other EU countries?
Yes, under MiCA, a license from the Netherlands allows you to passport your services to any EU member state without needing additional licenses. You must notify the AFM of your intention to operate cross border.
What happens if I already have a registration under the Dutch Wwft?
Current Wwft registrants will need to transition to the full MiCA license by 2026. The AFM will provide a transition period, but you should start the application process early to avoid gaps in authorization.
What are the ongoing compliance obligations after obtaining the license?
You must submit periodic reports to the AFM on financials, transactions, and AML metrics. Annual audits are required. You must maintain capital and insurance, segregate client assets, and report any changes in business or management to the AFM.
Is Panama a good alternative for a crypto license?
Panama has no dedicated crypto license; you incorporate a Sociedad Anonima with 0% tax on foreign source income. Setup takes 2 to 3 weeks with low costs. However, you cannot serve EU clients under MiCA, and banking may be challenging.
What are the costs associated with a Dutch crypto license application?
The AFM application fee is approximately EUR 5,000 to EUR 10,000. Legal and consulting fees can range from EUR 20,000 to EUR 50,000 depending on complexity. You also need to budget for capital requirements and insurance premiums.
Related reading
More crypto-license guides on this blog
- Crypto License in Panama: Cost, Requirements & Setup (2026)
- Crypto Exchange License: How and Where to Get One in 2026
- Crypto License Cost by Jurisdiction: 2026 Comparison
Crypto licenses by jurisdiction and topic
Compare every route we cover, each with cost, capital, timeline and requirements on consulting24.co:
This article reflects 2026 market conditions and is general guidance, not legal or tax advice. Regulations change — confirm specifics with qualified counsel before acting. Consulting24 (X24Consulting OÜ, Estonian reg. 16971898) introduces vetted local lawyers and tax advisors during every engagement.
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