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description: "Netherlands crypto asset regulation: 8 categories, 80 sourced findings, updated 2026-11-04. Licensing, token classification, stablecoins, tax treatment."
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# Netherlands Crypto & Digital Asset Regulation

schema crypto-v2.0.0
trajectory: not yet assessed regulated overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/netherlands/), [World Payments](https://payments.gi/jurisdictions/netherlands/)

Last updated 2026-11-04 · 8 categories · 80 sourced
findings · 100 sources in the cumulative register

Download report (PDF) Expand all

Evidence re-verified: 2026-11-04 · Position last changed: 2026-11-04 · Record history & provenance ▾ Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26

[Open in Co-Pilot ↗](/reports/?type=copilot&j=NETHERLANDS)[Build Report](/reports/?j=NETHERLANDS)[Compare](/compare/?j=NETHERLANDS)

Framework posture Regulated 8 of 9 modules populated · AI-synthesised · Tier-1/2 verified

Lead supervisory authority AFM (Autoriteit Financiële Markten) Primary statutory & supervisory perimeter

Next milestone (> 2026-10-26) 2026-Q4 ECB-led push to amend MiCA stablecoin reserve deposit rule

Module coverage & confidence 8 / 9 modules assessed 0 Confirmed · 8 Probable · 0 Uncertain · 1 Not yet assessed

8 Categories

0 Moved this cycle 0 Key judgments 4 Open gaps 80 Findings

9 Tier-1 sources

Confidence mix 8 unpopulated
(sums to 8 rendered categories; click to filter)

No categories moved this cycle.

Law made at European Economic Area (Bloc) level that applies in Netherlands is covered once, on the [European Economic Area (Bloc)](/jurisdictions/european-economic-area-bloc/) page. This page covers Netherlands’s own layer: implementation, national authorities, national options and local enforcement.

## Jurisdiction lead brief

###### Latest update · 4 November 2026

#### Lead Signal

AFM and DNB jointly published an exploratory report on 12 October 2026 finding that Dutch property and securities law, the Burgerlijk Wetboek and the Wet giraal effectenverkeer, currently provides no basis for securities issued, held and transferred exclusively in tokenised form. This is characterised as a legal-infrastructure gap rather than a MiCA-level prohibition: it concerns the civil-law capacity of Dutch private law to recognise a token itself as the full legal basis of title and transfer, not a restriction on crypto-asset service providers under the Markets in Crypto-Assets Regulation. The finding is structural and cross-sector, bearing on Dutch capital-markets infrastructure generally rather than imposing any crypto-specific regulatory restriction.

#### Other Developments

AFM revises fine-calculation policy. Effective 15 October 2026, the AFM changed the way it calculates administrative fines under its Boetetoemetingsbeleid, with severity, undertaking size and post-breach conduct now scaling final fines for MiCA and other AFM-enforced breaches, including those by crypto firms. No new crypto-specific fine has been announced under the revised policy.

Transitional registration period closed. The Dutch transitional period for pre-MiCA DNB-registered crypto service providers ended on 30 June 2025, shorter than the 1 July 2026 outer limit permitted under MiCA Art 143(3). DNB registrations issued under the prior national regime lapsed on that date, and Wwft and Sanctiewet supervision of crypto firms transferred from DNB to the AFM.

#### Cross-Monitor Connections

The tokenisation legal-gap finding has direct relevance to the financial-integrity and world-payments monitors, since it concerns market infrastructure for token-based securities rather than a purely crypto-sector supervisory question; the same AFM/DNB report underlies findings surfaced independently across those monitors this period. Separately, a pending Trade and Industry Appeals Tribunal (CBb) appeal, lodged by DNB on 29 January 2026 against a court judgment reducing a fine for unregistered crypto-service provision, remains outstanding and has relevance to the enforcement posture documented there.

#### Outlook

The AFM/DNB recommendation for a joint follow-up process with government and market participants on the tokenisation gap has no confirmed timetable. The outcome of DNB's pending CBb appeal, lodged 29 January 2026, concerning a pre-MiCA unregistered crypto-service-provision fine, remains unresolved and is worth monitoring for its bearing on enforcement precedent under the now-lapsed national registration regime.

6 earlier updates not shown here.

###### Standing brief · as of 3 August 2026

Written before the update above. Where they differ, the update is the more recent position.

#### Lead Signal

ESMA issued a public statement in June 2026 confirming that the transitional grandfathering period under MiCA Article 143 has closed EU-wide, meaning any entity, including non-EU crypto-asset service providers, offering services to EU clients without a MiCA licence is in breach of EU law and must cease such services, including in business-to-business arrangements. For the Netherlands this closure landed later than at the national level: the Dutch transitional window itself closed a full year earlier, on 30 June 2025, rather than at the EU-wide backstop of 1 July 2026 that an earlier read of the record had assumed applied uniformly. That earlier date placed the Netherlands among the first EU member states to require full AFM Crypto-Asset Service Provider authorisation of every NL-facing firm, or a formal wind-down of NL-facing services. Firms operating in the Netherlands without authorisation have therefore been in a non-compliant position for over a year, not merely since the later EU-wide backstop. AFM's licensing regime itself continues to require CASP authorisation before any entity may provide crypto-asset services in the Netherlands, with already-authorised credit institutions such as ClearBank Europe able to proceed instead via a notification route to the AFM rather than obtaining a fresh standalone licence. The combination of an early-closing national transitional window and continuing EU-level enforcement confirmation places Dutch supervisory posture toward unauthorised crypto activity at its firmest point since MiCA's phased introduction began.

#### Other Developments

The Netherlands' token-classification framework under MiCA Titles II-IV remains settled and actively applied: e-money token issuers domiciled in the Netherlands, including Quantoz Payments B.V. and Fiat Republic Netherlands, must hold authorisation as an electronic money institution or credit institution supervised by DNB, while asset-referenced tokens face Title III's stricter capital and liquidity requirements with EBA holding direct supervisory powers over any token designated significant. Utility and other non-ART/EMT crypto-assets fall under Title II's white-paper publication requirement. Stablecoin issuance detail was corrected this cycle: an earlier illustrative reference to Zerohash's electronic-money-institution licence, which in fact covers a brokerage/service-provider role handling third-party stablecoin flows, has been replaced with Quantoz Payments B.V. as the correct example of a DNB-authorised EMT issuer of EURQ and USDQ; the underlying reserve-backing and at-par redemption requirements for EMT holders are unaffected by the correction. On-chain activity continues to sit outside binding MiCA licensing scope in the Netherlands: staking-as-a-service by non-CASP entities, DeFi lending, and mining or node operation all remain unlicensed, a gap AFM's own leadership has publicly acknowledged pending a possible future "MiCA 2" framework, while the European Commission is separately consulting on whether to expand MiCA to cover tokenisation of real-world assets. Consumer protection continues to rest on longstanding AFM public warnings on virtual currencies and ICOs running since November 2017, reinforced by a joint EBA/EIOPA/ESMA warning issued after MiCA's application that investor protections may be limited depending on the crypto-asset type involved; MiCA Title V obliges CASPs to maintain complaints-handling procedures, though the precise NL-specific application of AFM's turbo-certificate-style conduct-of-business supervision to crypto-assets was not independently confirmed this cycle. On tax treatment, the standing Box 3 deemed-income wealth-tax description of how individual Dutch crypto holders are taxed has been held pending primary-source verification: the record on which it rests predates a December 2021 Dutch Supreme Court ruling that found the deemed-return mechanism unconstitutional, the 2022-2026 interim actual-returns bridging regime that followed, and a February 2026 House-passed replacement Act targeting 2028 effect. VAT exemption for Bitcoin-style exchange transactions under the CJEU's Hedqvist ruling, business-asset income-tax treatment distinct from Box 3, and DAC8 cross-border tax-data reporting obligations effective 1 January 2026 all remain in force as previously described. Cross-border transfer mechanics remain unchanged: an AFM-issued CASP licence continues to passport across the EEA without separate national authorisations required.

#### Cross-Monitor Connections

Two adjacent-monitor connections carry over into this cycle. The AML/CFT surface for Dutch crypto activity, covering Wwft obligations, FIU-Nederland reporting, and travel-rule application to cross-border transfers, continues to be carried by the financial-integrity monitor's subscription baseline rather than independently analysed here, though this record confirms that cross-border crypto transfers involving Dutch CASPs remain subject to applicable AML/CFT checks under the wider EU framework regardless of national MiCA-transposition status. Separately, the stablecoin and tax surfaces intersect with payments-monitor territory: DNB's electronic-money-institution authorisation regime for EMT issuers, together with the reserve-backing and at-par redemption mechanics attaching to euro- and dollar-denominated stablecoins issued from the Netherlands, and the DAC8 cross-border reporting obligation now falling on crypto-asset service providers, both sit on payments-relevant ground that the world-payments monitor tracks in parallel.

#### Outlook

The near-term trajectory in the Netherlands is one of consolidation on the licensing side and continued flux on the tax side. With the national transitional window closed and EU-wide enforcement now explicitly reiterated by ESMA, further tightening is likely to come through supervisory follow-through against remaining unauthorised operators rather than through new primary legislation. The open questions sit elsewhere: whether the European Commission's tokenisation consultation produces a scope-expanding proposal that would eventually reach staking, DeFi lending or mining; and, more immediately, whether the Box 3 wealth-tax treatment of crypto holdings is confirmed against primary Belastingdienst guidance before the interim actual-returns bridging regime lapses at the end of 2026 and the House-passed replacement Act's 2028 effective date approaches Senate consideration.

Read full brief · 1263 words

Key regulatory facts for Netherlands Regulatory Dimension Netherlands Standing Position

Jurisdiction Netherlands (NL)

Regulatory Scope Crypto & Digital Asset Regulation (8 modules, 80 sourced findings)

Crypto Licensing AFM requires CASP authorisation before crypto-asset services may be provided in the Netherlands under MiCA.

Token Classification MiCA Title II/III/IV classification taxonomy is settled and actively applied to NL-domiciled issuers on ESMA's interim register: EMT issuers require DNB/EMI authorisation, ARTs face Title III capital/liquidity rules...

On-Chain Activity Regime Staking, DeFi lending, and mining/node operation remain outside binding MiCA licensing scope in the Netherlands, acknowledged as a gap by AFM leadership and EU supervisors pending a possible 'MiCA 2' framework.

Stablecoin Regime EMT/ART issuer-authorisation framework is settled and applied to multiple NL-domiciled issuers.

Primary Instruments Cited AFM (Autoriteit Financiële Markten), Netherlands MiCA Article 143 national transitional period, Already-authorised Dutch credit institutions (e.g. ClearBank Europe), AFM, De Nederlandsche Bank

Last Confirmed / Updated 2026-11-04 (100 sources in cumulative register)

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### Netherlands: C1 Crypto LicensingGreenEnacted in forceModule confidence: Probable▾

AFM requires CASP authorisation before crypto-asset services may be provided in the Netherlands under MiCA. The national Article 143 transitional grandfathering period closed 30 June 2025, a year ahead of the EU-wide 1 July 2026 backstop, meaning unauthorised NL-facing providers have been non-compliant for over a year. Already-authorised credit institutions such as ClearBank Europe may proceed via AFM notification rather than a fresh CASP licence.

Open gap — crypto-int-4 Forward-looking custody rules not yet in force (CUS6) were not found within budget. no under-indexing note recorded

Horizon · 2026-03-01 (± a quarter) DNB/EBA PSD2-MiCA enforcement restraint on CASP EMT payment services ends In force · Tier 1 source

Horizon · 2026-08-31 (± a quarter) EU Commission MiCA functioning consultation Consultation · Tier 2 source

Horizon · 2026-Q4 (± a year) EU market integration and supervision package proposal Proposed · Tier 3 source

#### Crypto Licensing

The Netherlands operates a fully transposed MiCA licensing regime, supervised by the AFM under the Dutch Implementation Act (Wet implementatie verordening markten in cripto-activa). Any entity providing crypto-asset services in the Netherlands must hold Crypto-Asset Service Provider (CASP) authorisation from the AFM before commencing operations; this requirement's evidentiary basis was flagged this cycle for resting on a single T4 trade-press citation despite in-register T1 ESMA sources supporting the same underlying fact, and its confidence was downgraded from Confirmed to Probable pending re-citation to a primary source, though the underlying licensing requirement itself is not in doubt.

The compliance timeline attached to this requirement was materially corrected this cycle. The national MiCA Article 143 transitional grandfathering period for the Netherlands closed on 30 June 2025 — a full year ahead of the EU-wide 18-month Article 143 backstop of 1 July 2026 that an earlier reading of the record had applied uniformly. This places the Netherlands among the earliest-closing jurisdictions in the EU: unauthorised providers serving Dutch clients have been required to cease NL-facing services or complete wind-down for over a year already, independent of the later EU-wide deadline. This correction changes the practical compliance posture materially — firms that might have assumed an additional year's grace under the EU-wide date have in fact been operating outside the permitted window in the Netherlands specifically since mid-2025.

Not every route into the Dutch market requires a fresh standalone CASP licence. Credit institutions already authorised in the Netherlands, such as ClearBank Europe, may offer crypto-asset services after notifying the AFM of their plans rather than obtaining separate CASP authorisation, reflecting MiCA's accommodation of firms already subject to prudential supervision under other EU financial-services frameworks.

#### Outlook

With the national transitional window closed and ESMA having separately reiterated EU-wide enforcement of the equivalent EU backstop, the near-term trajectory for Dutch crypto licensing is supervisory consolidation rather than fresh rule-making: attention now shifts to how actively AFM pursues firms that remain unauthorised past the national closure date, and whether the sourcing gap flagged on the core CASP-authorisation claim is closed with a primary AFM or ESMA citation in a future cycle.

Read full sub-brief · 356 words Periodic update · new data 2026-11-04

#### Crypto Licensing

The Netherlands' crypto-licensing framework continues to operate under the Markets in Crypto-Assets Regulation (MiCA), fully applicable since 30 December 2024, with the AFM as the licensing authority for crypto-asset service providers and DNB serving as prudential supervisor and qualifying-holding assessor. The principal development this period concerns enforcement mechanics rather than the licensing perimeter itself: effective 15 October 2026, the AFM changed the way it calculates administrative fines under its revised Boetetoemetingsbeleid, with severity, undertaking size and post-breach conduct now scaling final administrative fines for MiCA and other AFM-enforced breaches, including breaches by crypto firms. No new crypto-specific fine has been announced under the revised policy, and the underlying policy document itself was not directly retrieved, with the finding sourced from secondary Dutch-language commentary.

A second development concerns the transitional architecture for firms that held registrations under the Netherlands' pre-MiCA national regime. The Dutch transitional period for pre-MiCA DNB-registered crypto service providers ended on 30 June 2025, a date shorter than the 1 July 2026 outer limit permitted under MiCA Art 143(3). As of that date, DNB registrations issued under the prior national regime lapsed, and supervisory responsibility for Wwft and Sanctiewet compliance by crypto firms transferred from DNB to the AFM. The precise implementing-act provision establishing this earlier cut-off was not located at primary-source level, and the finding carries a Probable confidence rating rather than Confirmed.

Separately, a Trade and Industry Appeals Tribunal (CBb) appeal lodged by DNB on 29 January 2026, against a court judgment that reduced a fine imposed for offering crypto services in the Netherlands without the legally required pre-MiCA registration, remains pending and unresolved.

#### Outlook

The outcome of DNB's pending CBb appeal, lodged 29 January 2026, is the principal open enforcement-precedent question for the pre-MiCA registration regime and remains unresolved. Whether the AFM's revised fine-calculation policy, effective 15 October 2026, produces any new crypto-specific enforcement action under MiCA is also worth monitoring, though no such action has been announced.

6 earlier distinct update(s) Periodic update · new data 2026-10-18

#### Crypto Licensing

The Netherlands' crypto-licensing framework continues to operate under the Markets in Crypto-Assets Regulation (MiCA), fully applicable since 30 December 2024, with the AFM as the licensing authority for crypto-asset service providers and DNB serving as prudential supervisor and qualifying-holding assessor. The principal development this period concerns enforcement mechanics rather than the licensing perimeter itself: effective 15 October 2026, the AFM changed the way it calculates administrative fines under its revised Boetetoemetingsbeleid, with severity, undertaking size and post-breach conduct now scaling final administrative fines for MiCA and other AFM-enforced breaches, including breaches by crypto firms. No new crypto-specific fine has been announced under the revised policy as of this cycle, and the underlying policy document itself was not directly retrieved, with the finding sourced from secondary Dutch-language commentary.

A second development concerns the transitional architecture for firms that held registrations under the Netherlands' pre-MiCA national regime. The Dutch transitional period for pre-MiCA DNB-registered crypto service providers ended on 30 June 2025, a date shorter than the 1 July 2026 outer limit permitted under MiCA Art 143(3). As of that date, DNB registrations issued under the prior national regime lapsed, and supervisory responsibility for Wwft and Sanctiewet compliance by crypto firms transferred from DNB to the AFM. The precise implementing-act provision establishing this earlier cut-off was not located at primary-source level this cycle, and the finding carries a Probable confidence rating rather than Confirmed.

Separately, a Trade and Industry Appeals Tribunal (CBb) appeal lodged by DNB on 29 January 2026, against a court judgment that reduced a fine imposed for offering crypto services in the Netherlands without the legally required pre-MiCA registration, remains pending and unresolved as of this cycle.

#### Outlook

The outcome of DNB's pending CBb appeal, lodged 29 January 2026, is the principal open enforcement-precedent question for the pre-MiCA registration regime and remains unresolved. Whether the AFM's revised fine-calculation policy, effective 15 October 2026, produces any new crypto-specific enforcement action under MiCA is also worth monitoring, though no such action has been announced as of this cycle.

Periodic update · new data 2026-10-11

#### Crypto Licensing

The Netherlands operates its crypto-licensing regime under MiCA (Regulation (EU) 2023/1114), with the AFM as the competent authority for crypto-asset service provider authorisation and conduct supervision. Providing crypto-asset services professionally in or from the Netherlands requires AFM authorisation under MiCA Articles 59 and 62, unless the provider is already an authorised EU financial entity that can instead notify under Article 60. This requirement has been in force since 30 December 2024 and constitutes the core gating mechanism for lawful crypto-asset service provision in the jurisdiction.

The transitional pathway into this regime was shortened at the national level. The Uitvoeringswet verordening cryptoactiva set the MiCA Article 143(3) national grandfathering period for DNB-registered incumbent crypto-asset service providers to end on 30 June 2025, six months rather than the full eighteen-month EU maximum extension to 1 July 2026. This meant incumbent providers that had been operating under the earlier Wwft-era DNB registration faced a compressed window to secure full MiCA authorisation rather than the longer runway available in some other member states.

The enforcement baseline that preceded MiCA illustrates the seriousness with which Dutch authorities have historically treated unregistered crypto-asset activity. DNB fined an unregistered crypto service provider EUR2,850,000 for offering crypto services in the Netherlands without the legally required Wwft-era DNB registration; the Rotterdam court later reduced this to EUR2,277,500 on review, but the underlying finding and the scale of the original penalty stand as a marker of DNB's enforcement posture carried forward into the MiCA-era registration and authorisation requirement now administered by the AFM.

#### Outlook

The exact national cut-off date the Uitvoeringswet verordening cryptoactiva set for MiCA grandfathering has not been independently verified at primary source this cycle, and confirmation of this detail, along with any further enforcement activity against providers that failed to transition within the shortened window, remains open to watch.

Periodic update · new data 2026-09-28

#### Crypto Licensing

Crypto-asset service providers operating in or from the Netherlands must hold AFM authorisation as a Crypto-Asset Service Provider (CASP) under MiCA. The AFM issued the EU's first four CASP licences on 30 December 2024, the day MiCA's CASP provisions came into full application, giving the Netherlands an early and active domestic licensing track record within the EU framework rather than a newly-commencing regime still building its first cohort of licensees.

A genuine point of record conflict exists around the transitional arrangements for legacy crypto service providers previously registered with DNB under the Wwft anti-money-laundering framework rather than licensed under MiCA proper. Available sources disagree on whether the Netherlands applied a national transitional cutoff of 30 June 2025, materially shorter than the EU-wide default 18-month transitional window running to 1 July 2026, or whether the later EU-default date applied directly in the Dutch case. This is treated as a disputed claim rather than resolved fact, because the underlying sources conflict rather than simply being thin; a firm's compliance status during the window between the two candidate dates cannot be stated with confidence pending resolution to a primary AFM or DNB source.

#### Outlook

Resolving the exact NL-specific transitional cutoff date for legacy Wwft-registered CASPs is the single clearest open item in this module; the AFM's own primary licensing register or DNB's own transitional-guidance publication would be the natural next source to close the gap. Beyond that, the Netherlands' status as an early MiCA CASP-licensing jurisdiction, with four licences issued on MiCA's first day of application, is a structural fact likely to remain a stable reference point going forward.

Periodic update · new data 2026-09-21

#### Crypto Licensing

Any entity professionally providing crypto-asset services in the Netherlands must hold AFM authorisation as a crypto-asset service provider under MiCA Article 62. This authorisation requirement is now the sole gateway to lawful crypto-asset service provision in the country, following the close of the Dutch pre-MiCA transitional regime. Firms that had been registered with DNB under the earlier Wwft crypto-registration regime were permitted to continue operating without a full MiCAR licence only until 30 June 2025, when the transitional arrangement ended; the Netherlands ran the shortest such transition period in the EU, closing well ahead of the default deadline available to other member states under MiCA's Article 143(3).

The AFM issued some of the EU's first CASP licences on 30 December 2024, the date MiCA's full CASP authorisation regime took effect, to MoonPay, BitStaete, ZBD and Hidden Road. Bitvavo, a significant domestic exchange, announced its own AFM MiCA licence on 27 June 2025, roughly six months into the fully operational regime. This progression from an early licensing cohort to broader domestic-exchange authorisation indicates the AFM's licensing process has continued to process applications at a steady pace since the regime's full commencement.

DNB's role in this framework is narrower than AFM's: rather than licensing authority, DNB conducts prudential vetting of qualifying-holding owners for CASPs, a supervisory function distinct from AFM's conduct and authorisation role. This division, AFM as licensing and conduct authority, DNB as prudential vetter of ownership, represents one of the more clearly settled DNB/AFM splits among EEA member states implementing MiCA.

#### Outlook

With the transitional regime closed and the authority split between AFM and DNB settled, the Dutch crypto-licensing framework is structurally stable heading into the next cycle. The key development to track is the continued pace of CASP authorisations, particularly whether other significant domestic exchanges or service providers follow Bitvavo's path to full MiCA licensure, and whether AFM publishes any further guidance affecting the authorisation process for new applicants.

Periodic update · new data 2026-09-14

#### Crypto Licensing

The Netherlands' crypto-licensing regime is now defined by two layered authorisations rather than one. The baseline requirement remains MiCA CASP authorisation issued by the AFM, in force since the Netherlands issued the EU's first CASP licences on 30 December 2024; DNB retains prudential oversight and AML-related supervisory expectations alongside the AFM's conduct authorisation. Overlaid onto this baseline, as of 1 March 2026, CASPs transacting EMT-related payment services must additionally hold a PSD2 licence, following the end of a DNB/EBA transitional enforcement-restraint period that had applied since a June 2025 EBA Opinion clarified the PSD2/MiCA boundary. A CASP can avoid the additional PSD2 licence only by qualifying for a Wft exemption or by partnering with an already-authorised payment service provider; absent one of those two routes, dual authorisation is now the operative requirement rather than a future contingency.

This is a Confirmed, T1-sourced development directly from DNB, and it represents a tightening of the practical licensing perimeter for any CASP whose business model involves EMT-denominated payment flows — for example, facilitating payments or settlements in euro-pegged e-money tokens rather than purely custodial or trading services. A CASP that had structured its Dutch operations around MiCA authorisation alone, treating PSD2 as inapplicable during the restraint period, must now reassess whether its EMT-related activity brings it within PSD2 scope.

Separately, and at lower confidence, legacy enforcement from the pre-MiCA era continues to work through the Dutch courts. A crypto service provider was fined by DNB for historic unregistered operation under the former Wwft crypto-registration regime; the Rotterdam court upheld the underlying breach but reduced the penalty to EUR2,277,500, and DNB has appealed that reduction to the Trade and Industry Appeals Tribunal, with a hearing set for 29 January 2026. This is Probable-confidence reporting from a single T3 source, and it concerns a registration requirement that MiCA's CASP regime has since superseded for authorisation purposes — the litigation is about historic conduct, not the forward-looking licensing gate.

#### Outlook

Watch for DNB supervisory guidance clarifying precisely which CASP business models fall within the EMT-payment PSD2 trigger, and for the outcome of DNB's appeal in the Trade and Industry Appeals Tribunal following the January 2026 hearing, which will signal how DNB intends to treat historic Wwft-era non-compliance relative to the current MiCA-era regime.

Periodic update · new data 2026-09-05

#### Crypto Licensing

The Netherlands regulates crypto-asset service provision entirely through the EU Markets in Crypto-Assets Regulation (MiCAR, Regulation (EU) 2023/1114), with no residual national licensing track. The Autoriteit Financiele Markten (AFM) confirms that the prior De Nederlandsche Bank (DNB) VASP transitional regime, which had permitted registered virtual-asset service providers to continue operating while MiCAR's full application approached, ended on 30 June 2025. From that date, every entity providing crypto-asset services to Dutch clients has required a MiCAR authorisation from the AFM, which now functions as the Netherlands' primary crypto-asset service provider (CASP) licensing authority; DNB retains prudential competence over the sector rather than a parallel licensing role.

This settled architecture is already producing authorisation activity. BitPay obtained a MiCA CASP licence from the AFM on 16 July 2026, an authorisation that carries EU-wide passporting rights, allowing BitPay to offer its crypto-asset services across the EU on the strength of its single Dutch authorisation. For firms evaluating the Netherlands as an entry point into the EU crypto market, the AFM authorisation route is now the only route, and the passporting mechanic means a Dutch authorisation can function as an EU-wide market-access decision rather than a Netherlands-only one.

The transition away from the DNB transitional regime also has supervisory-architecture implications: rather than a single national regulator handling both registration and prudential oversight, as under the prior VASP regime, the Netherlands now operates a split model under MiCAR, AFM for authorisation and conduct, DNB for prudential and stablecoin-issuer supervision.

#### Outlook

With the transitional period now closed and the AFM licensing route fully operational, the coming cycle's crypto-licensing signal in the Netherlands is likely to come from the pace and profile of new CASP authorisations, such as the BitPay licence, rather than from further structural change to the licensing framework itself.

Sources and findings (30)
- T4 · The Block[AFM (Autoriteit Financiële Markten)](https://www.theblock.co/post/360216/bitvavo-largest-eur-spot-exchange-secures-mica-license-from-the-netherlands) — providing crypto-asset services in the Netherlands, under the EU Markets in Crypto-Assets Regulation (MiCA)
- T3 · A&O Shearman (aosphere)[Netherlands MiCA Article 143 national transitional period](https://www.aosphere.com/know-how/member-state-implementation-of-mica-updated-tracker/) — 30 June 2025 (a year ahead of the EU-wide 18-month Art.143 backstop of 1 July 2026), after which unauthorised providers had to cease NL-facing services or complete wind-down
- T4 · CoinDesk[Already-authorised Dutch credit institutions (e.g. ClearBank Europe)](https://www.coindesk.com/business/2026/04/13/clearbank-secures-mica-approval-targets-circle-euro-dollar-stablecoins-for-institutional-clients) — the AFM of their plans, rather than obtaining a fresh standalone CASP licence
- T3[AFM](https://gencompl.ai/regulations/mica) — AFM's first MiCA enforcement action: MEXC Global listed on ESMA non-compliant-entities register 16 September 2025, followed by a public consumer warning 24 September 2025
- T1[De Nederlandsche Bank](https://www.dnb.nl/algemeen-nieuws/handhavingsmaatregel-2025/boete-voor-aux-cayes-fintech-co-ltd-vanwege-het-van-juli-2023-tot-augustus-2024-zonder-de-wettelijk-vereiste-registratie-aanbieden-van-cryptodiensten-in-nederland/) — DNB fined Aux Cayes Fintech Co. Ltd. (OKX) EUR 2,250,000 on 27 May 2025 for offering crypto-asset services in NL from July 2023 to August 2024 without required Wwft registration
- T1[Rechtbank Rotterdam](https://www.dnb.nl/en/general-news/enforcement-measures-2026/fine-for-crypto-service-provider-for-offering-crypto-services-in-the-netherlands-without-the-legally-required-registration) — Rotterdam court declared well-founded an appeal against DNB's 2023 order subject to penalty against Payward International Markets Limited (Kraken) for unregistered crypto services, judgment 19 December 2025
- T3[DNB](https://defi-intel.com/jurisdictions/netherlands/) — Dutch transitional/grandfathering period for pre-MiCA DNB-registered crypto service providers ended 30 June 2025 (shorter than MiCA Art 143(3)'s 1 July 2026 outer limit); DNB registrations lapsed and Wwft/Sanctiewet crypto supervision transferred from DNB to AFM.
- T3[AFM / DNB](https://defi-intel.com/regulators/afm-nl/) — MiCA CASP authorisation (Arts 59-64) required to provide crypto-asset services in NL; AFM is licensing authority, DNB the prudential supervisor and qualifying-holding assessor.
- T3[AFM](https://cryptobenelux.com/europa/afm-verandert-boeterekensom-en-dat-kan-cryptobedrijven-hard-raken) — AFM's revised fine-calculation policy (Boetetoemetingsbeleid), effective 15 October 2026, changes how severity, undertaking size and post-breach conduct scale final administrative fines for MiCA and other AFM-enforced breaches, including by crypto firms.
- T1[AFM / DNB white paper supervisory split](https://www.afm.nl/en/sector/cryptopartijen/toezicht/white-papers) — AFM supervises Title II (non-ART/EMT) white papers via notification (not approval); ART/EMT white papers reviewed jointly by AFM and DNB
- T3[AFM MiCA CASP authorisations](https://defi-intel.com/jurisdictions/netherlands/) — AFM issued the EU's first CASP authorisations on 30 December 2024 to MoonPay, BitStaete, ZBD and Hidden Road
- T1[Bitvavo / Societe Generale-FORGE partnership](https://bitvavo.com/en/news/soc-gen-forge) — Bitvavo announced a partnership with Societe Generale-FORGE (SG-FORGE) on 17 December 2025
- T3[Netherlands CASP count](https://www.penning.io/mica/casp-register) — 28 CASPs authorised with Netherlands as MiCA home state as at 29 October 2026
- T1[AFM](https://www.afm.nl/en/sector/actueel/2024/december/sb-start-micar) — A CASP authorisation (or Art 60 notification / passporting) is required to provide crypto-asset services in the Netherlands from 30 December 2024
- T3[Uitvoeringswet verordening cryptoactiva](https://www.njb.nl/wetgeving/staatsbladen/uitvoeringswet-verordening-cryptoactiva-mica/) — AFM and DNB designated as competent authorities under MiCA with administrative and criminal (Wed) enforcement powers
- T1[DNB-registered crypto service providers (legacy VASPs)](https://www.afm.nl/en/sector/registers/vergunningenregisters/cryptopartijen) — National transitional regime for pre-MiCA DNB-registered crypto providers ended 30 June 2025 in the Netherlands (shortened from the EU's default up to 18-month window)
- T3[AFM](https://protegra.io/licensing/licences/casp-mica/netherlands/) — CASP authorisation applications: completeness check within 25 working days, decision within 40 working days of a complete application, with one possible suspension of up to 20 working days
- T3[AFM](https://www.buckinghamcapitalconsulting.com/mica-casp-authorisation) — CASP authorisation withdrawn if unused within 12 months, or where no crypto-asset services provided for nine consecutive months
- T3[AFM; DNB](https://www.springlex.eu/en/packages/mica/mica-regulation/article-111/) — MiCA Art 111 minimum administrative fines: up to EUR 5,000,000 (or more) and up to 15% of turnover for legal persons on the most serious market-abuse breaches; at least EUR 700,000 for natural persons
- T1[AFM; DNB](https://www.dnb.nl/en/sector-information/open-book-supervision/laws-and-eu-regulations/enforcement/administrative-fine-under-the-wft-pw-wtt-wwft-and-sw/) — Wft administrative fine categories: Category 1 fixed EUR 10,000; Category 3 maximum up to 10% (or 15% for binding EU acts) of net turnover; power to fine lapses 5 years after non-compliance
- T1[De Nederlandsche Bank](https://www.dnb.nl/en/general-news/enforcement-measures-2024/fine-for-bybit-fintech-limited-for-offering-crypto-services-in-the-netherlands-without-the-legally-required-registration-until-september-2023/) — DNB fined Bybit Fintech Limited EUR 2,250,000 on 22 October 2024 for providing crypto services in NL without required DNB registration until September 2023
- T2[De Nederlandsche Bank](https://www.banken.nl/nieuws/25155/dnb-deelt-boete-uit-van-bijna-3-miljoen-aan-cryptocom) — DNB fined Foris DAX MT Limited (Crypto.com) EUR 2,850,000 on 19 March 2024 for operating as a crypto exchange in NL without required Wwft registration
- T1[De Nederlandsche Bank](https://www.dnb.nl/media/v4bd2ru0/besluit-tot-het-opleggen-van-een-bestuurlijke-boete-aan-coinbase.pdf) — DNB fined Coinbase Europe Ltd EUR 3,325,000 on 18 January 2023 under Wwft Art 23b/23c for CDD/transaction-monitoring breaches by a crypto service provider
- T2[ESMA](https://cryptobenelux.com/europa/esma-telt-eerste-tien-mica-maatregelen-nederland-meldt-een-openbare-verklaring) — ESMA's first EU-wide MiCA enforcement tally records one public statement from the Netherlands in 2025; the only fine (EUR 600,000) was imposed in Germany, none yet in NL
- T3[MiCA Art 67(1)](https://www.agrc.ai/resources/articles/mica-casp-authorization-requirements) — CASP must hold prudential safeguards = higher of class minimum capital (EUR 50k/125k/150k) or 1/4 preceding year's fixed overheads
- T3[MiCA Annex IV](https://www.lexology.com/library/detail.aspx?g=3ea83e34-3b46-43a2-9ec8-55810c59a810) — CASPs must hold permanent minimum capital by class: EUR 50,000 (Class 1), EUR 125,000 (Class 2), EUR 150,000 (Class 3)
- T3[MiCA Art 67(4)](https://www.springlex.eu/en/packages/mica/mica-regulation/article-67/) — Prudential safeguard may be own funds (CET1), professional indemnity insurance/guarantee covering all served Union territories, or a combination; insurance policy must be disclosed publicly
- T3[EBA No-Action Letter on PSD2/MiCA interplay](https://www.morganlewis.com/pubs/2025/06/e-money-tokens-european-banking-authority-clarifies-psd2-mica-interplay-implications-for-casps) — Where CASP activity involving e-money tokens also qualifies as payment service, firm must cumulatively meet MiCA Art 67 and PSD2 own-funds requirements with no mutualisation
- T2[European Commission targeted consultation on the functioning of MiCA](https://cryptobenelux.com/europa/brussel-toetst-mica-opnieuw-en-raakt-benelux-cryptogebruikers) — Consultation on MiCA functioning (stablecoins, CASPs, DeFi, staking, lending/borrowing, NFTs) published 2026-05-20, closes 2026-08-31
- T3[EU market integration and supervision package](https://corp-intl.com/news/mica-licence-requirements-eu-crypto-licensing) — On 4 Dec 2025 the European Commission proposed a package that would transfer direct supervision of significant CASPs to ESMA

### Netherlands: C2 Token ClassificationGreenEnacted in forceModule confidence: Probable▾

MiCA Title II/III/IV classification taxonomy is settled and actively applied to NL-domiciled issuers on ESMA's interim register: EMT issuers require DNB/EMI authorisation, ARTs face Title III capital/liquidity rules with EBA oversight of significant tokens, other tokens fall under Title II white-paper rules, and NFTs are generally excluded absent large-series/fractionalisation.

C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 8 traced claims · Re-verified 2026-11-04

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### Netherlands: C3 On-Chain Activity RegimeAmberEnacted in forceModule confidence: Probable▾

Staking, DeFi lending, and mining/node operation remain outside binding MiCA licensing scope in the Netherlands, acknowledged as a gap by AFM leadership and EU supervisors pending a possible 'MiCA 2' framework. The European Commission is separately consulting on expanding MiCA to real-world-asset tokenisation, a proposed-stage development only.

Periodic update · new data 2026-10-18

#### On-Chain Activity Regime

The defining development in the Netherlands' on-chain activity regime this period is the joint AFM/DNB exploratory report, published 12 October 2026, finding that Dutch law currently provides no basis for securities issued, held and transferred exclusively in native tokenised form. The gap is located specifically in Dutch property and securities law, the Burgerlijk Wetboek and the Wet giraal effectenverkeer (Wge), neither of which currently recognises a token itself as the sole legal basis of title and transfer for a security. AFM and DNB characterised this explicitly as a legal-infrastructure gap rather than a MiCA-level prohibition: it is a question of whether Dutch private law can give full legal effect to on-chain securities, not a restriction on the crypto-asset services that may be offered under MiCA.

The regulators recommended a joint follow-up process involving government and market participants to address the gap, reflecting the structural, cross-sector nature of the finding, which is as much a capital-markets infrastructure matter as a digital-asset supervisory one. In the absence of legislative clarification, market participants seeking to achieve native on-chain issuance of securities in the Netherlands must continue to rely on hybrid or dual-registration structures that layer a token representation over a conventional legal title recognised under existing law.

This finding is assessed at Confirmed confidence, reflecting its basis in a joint primary publication by both the Netherlands' conduct regulator and its prudential regulator acting together. No other on-chain activity development specific to the Netherlands was identified this period.

#### Outlook

The AFM/DNB recommendation for a joint follow-up process has no confirmed timetable. Whether the Dutch government pursues a legislative amendment to the Burgerlijk Wetboek and Wet giraal effectenverkeer to give on-chain securities a clear legal basis, or market participants continue relying on dual-registration structures indefinitely, is the central open question for the on-chain activity regime in the Netherlands going forward.

C3 · On-Chain Activity — Full Module Record 0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-11-04

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### Netherlands: C4 Stablecoin RegimeGreenEnacted in forceModule confidence: Probable▾

EMT/ART issuer-authorisation framework is settled and applied to multiple NL-domiciled issuers. Quantoz Payments B.V. (EURQ/USDQ) requires DNB EMI/credit-institution authorisation, replacing a misattributed Zerohash brokerage-licence example corrected this cycle. EMT issuers must maintain 100% reserve-backing, holders may redeem at par, and issuers must publish a MiCA white paper per ESMA's interim register.

Horizon · 2026-03-01 (± a quarter) DNB PSD2-licence-or-cooperation requirement for EMT payment services Adopted, not yet in force · Tier 3 source

Horizon · 2026-Q4 (± more than a year) ECB-led push to amend MiCA stablecoin reserve deposit rule Proposed · Tier 2 source

Periodic update · new data 2026-09-05

#### Stablecoin Regime

Stablecoin issuance in the Netherlands is governed by MiCAR Title III and Title IV, with De Nederlandsche Bank (DNB) as the competent supervisory authority. DNB has been the supervisory authority for issuers of e-money tokens (EMTs) and asset-referenced tokens (ARTs) since 30 December 2024, and is also the competent authority for assessing proposed acquisitions of qualifying holdings in crypto-asset service providers under MiCAR Article 84.

Quantoz Payments BV illustrates how the regime operates in practice. Quantoz holds MiCA authorisation for its EURQ and USDQ tokens, issued respectively as an e-money token and an asset-referenced token. The pairing demonstrates that a single issuer can hold parallel authorisations across both stablecoin categories that MiCAR distinguishes, and that DNB's supervisory role extends across both token types rather than being confined to one.

The most significant forward-looking development in this space is the announced plan by nine major European banks, including ING, to launch a MiCA-compliant euro-denominated stablecoin supervised by DNB, expected in 2026. This remains an announced plan rather than a binding or completed authorisation: no launch date, issuance volume or specific authorisation has yet been confirmed. If it proceeds, a bank-consortium euro stablecoin of this scale, under DNB's direct supervision, would be a significant addition to the Netherlands' stablecoin landscape, sitting alongside issuers such as Quantoz within the same MiCAR framework.

#### Outlook

The consortium stablecoin announcement is the clearest signpost for what would change the Dutch stablecoin picture over the coming cycle: a confirmed launch, an authorisation grant, or a stated issuance timeline would move this from an announced plan to an operating fact.

C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 8 traced claims · Re-verified 2026-11-04

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### Netherlands: C5 Consumer ProtectionAmberEnacted in forceModule confidence: Probable▾

AFM/ESA consumer warnings remain ongoing (AFM warnings since Nov 2017; joint EBA/EIOPA/ESMA warning post-MiCA application). CASPs must maintain Title V complaints-handling procedures. NL-specific application of AFM's turbo-certificate-style conduct-of-business supervision to crypto remains unconfirmed.

Open gap — crypto-int-2 Detailed promotions/marketing regime beyond MiCA Art 7/29 text (PRO1) was not confirmed for NL at a primary source. tax_treatment is structurally thin across the estate per bias corrections.

Open gap — crypto-int-3 Best-execution and inducements supervisory expectations (MA4) were not found within budget. no under-indexing note recorded

#### Consumer Protection

Dutch consumer protection for crypto-assets rests on two tiers of supervisory activity plus one specific compliance obligation. At the national level, the AFM has published public warnings on virtual currencies, crypto-assets and initial coin offerings on an ongoing basis since November 2017 — a long-running consumer-information initiative that predates MiCA itself and continues in parallel with it. At the EU level, the three European Supervisory Authorities — EBA, EIOPA and ESMA — issued a joint consumer warning following MiCA's entry into application, noting that investor protections for crypto-assets may be limited depending on the specific type of crypto-asset involved, an acknowledgement that MiCA's protections are not uniform across token types.

On the conduct-of-business side, MiCA-authorised CASPs operating in the Netherlands are required to establish complaints-handling procedures under MiCA Title V. A further, more speculative observation this cycle notes that the AFM applies supervisory expectations analogous to its established enforcement approach on leveraged "turbo" certificates when assessing CASP conduct-of-business obligations toward Dutch retail clients; however, no crypto-specific appropriateness rule paralleling the turbo-certificate regime was directly confirmed in this research cycle, and this observation should be treated as an inference rather than a confirmed supervisory practice.

#### Outlook

The consumer-protection module's framework-level elements — AFM warnings, ESA joint warnings, and Title V complaints-handling — are stable and unlikely to change materially in the near term. The open item is whether AFM's turbo-certificate-style conduct-of-business posture is ever formally extended, or confirmed as extended, to crypto-asset appropriateness assessments specifically; until that is confirmed against a primary AFM enforcement source, this remains an inference rather than an established supervisory fact.

Read full sub-brief · 266 words Periodic update · new data 2026-10-11

#### Consumer Protection

The AFM conducted a review of thirty-three crypto-asset providers assessing compliance with MiCA's marketing and cost-disclosure standards. The review identified significant shortcomings in advertising practices at fourteen of the providers reviewed, and found inadequate cost information at nineteen. Findings concerning ten international providers were shared with other European regulators, indicating the AFM is treating this as a cross-border supervisory matter rather than one confined to domestically-incorporated firms.

This review represents an active 2026 enforcement priority for the AFM, sitting within its MiCA conduct-supervision remit, though it has not this cycle produced a fine or formal order against any named provider; the finding is supervisory in nature. The scale of the review, covering a third of providers surveyed with advertising shortcomings and well over half found to have inadequate cost information, signals that marketing and cost-transparency compliance across the crypto sector reaching Dutch consumers falls meaningfully short of the MiCA standard as currently enforced.

#### Outlook

Whether any of the AFM's findings from this review will progress to a formal fine or order against a named provider, and whether the ten providers referred to other European regulators face coordinated follow-on action, has not been independently verified this cycle and remains a live question for the next observation window.

2 earlier distinct update(s) Periodic update · new data 2026-09-28

#### Consumer Protection

The AFM treats advertising and marketing compliance by unlicensed crypto-asset service providers targeting Dutch clients as an active enforcement priority for 2026. This reflects a consumer-protection posture focused on policing the boundary of the MiCA CASP perimeter, specifically ensuring that platforms without AFM authorisation are not able to market to Dutch residents as though they held equivalent standing to licensed CASPs.

The clearest illustration of this enforcement priority is Binance's continued unavailability to Dutch residents as of mid-2026, reflecting the fact that Binance holds no MiCA CASP licence in the Netherlands. This is a significant data point for consumer-protection purposes because it demonstrates the AFM's willingness to maintain exclusion of a major global platform from the Dutch retail market for as long as that platform remains outside the CASP licensing perimeter, rather than tolerating unlicensed access on the basis of the platform's scale or international standing elsewhere.

#### Outlook

The AFM's active 2026 enforcement priority against unlicensed marketing suggests continued scrutiny of any platform operating without CASP authorisation while targeting Dutch clients. Whether Binance or other major unlicensed platforms move toward AFM authorisation, or continue to operate outside the Dutch market entirely, is the practical marker to track for how this enforcement priority translates into market-access outcomes.

Periodic update · new data 2026-09-14

#### Consumer Protection

The AFM has taken to publicly naming unlicensed crypto venues operating in the Dutch market, including the exchange MEXC, as a consumer-facing enforcement and warning measure. This is a Probable-confidence finding resting on a single T3 secondary source, and it should be read as a a posture signal rather than a formal sanction: the AFM is not merely relying on the MiCA authorisation requirement itself to exclude unlicensed operators from the market, but is actively publicising the names of venues operating without the required authorisation so that Dutch consumers can identify them.

This naming practice sits alongside, but is analytically distinct from, the MiCA authorisation regime itself, which requires CASPs to hold AFM-issued authorisation to professionally provide crypto-asset services in the Netherlands. Where a venue lacks that authorisation and continues to serve Dutch consumers, the AFM's response this cycle has been public disclosure rather than, on the evidence available, a formal enforcement order. The practical consumer-protection effect is to shift some of the burden of avoiding unlicensed venues onto consumer awareness, supplementing rather than replacing the underlying licensing gate.

#### Outlook

Whether the AFM's naming practice expands to a larger list of unlicensed venues, or is followed by formal enforcement action against named entities, will indicate whether this is a standing consumer-protection tool or an initial, isolated measure. No further corroborating source was retrieved this cycle beyond the single T3 report.

Sources and findings (8)
- T1 · EBA[AFM](https://www.eba.europa.eu/sites/default/files/document_library/Consumer%20Corner/Financial%20education/EBA%20Financial%20Education%20Repositories/2022/1026364/NL.pdf) — public warnings on virtual currencies, crypto-assets and initial coin offerings, an ongoing consumer information initiative running since November 2017
- T1 · EBA/EIOPA/ESMA[EBA, EIOPA and ESMA (European Supervisory Authorities)](https://www.eba.europa.eu/publications-and-media/press-releases/eu-supervisory-authorities-warn-consumers-risks-and-limited-protection-certain-crypto-assets-and) — a joint consumer warning following MiCA's application, noting that crypto-asset investor protections may be limited depending on the type of crypto-asset involved
- T1 · ESMA[AFM](https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica) — its enforcement approach on leveraged 'turbo' certificates when assessing CASP conduct-of-business obligations for crypto-assets offered to Dutch retail clients, though no crypto-specific appropriateness rule was directly confirmed in this run
- T1 · ESMA[MiCA-authorised CASPs operating in the Netherlands](https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica) — complaints-handling procedures under MiCA Title V conduct-of-business obligations
- T3[crypto-asset service provider complaints handling](https://www.mica.wtf/eu-level/technical-standards/rts/regulatory-technical-standards-complaints-handling-crypto-asset-service-providers) — CASPs must establish complaint-handling procedures and resolve complaints within a timeframe not exceeding 2 months
- T3[crypto-asset custody and segregation](https://www.headlesslaw.com/mica/articles/75) — Custodians must segregate client crypto-asset holdings from their own holdings and minimise risk of loss from fraud, cyber threats or negligence
- T3[MiCA market abuse regime (Title VI)](https://www.mamotcv.com/insights/fintech-insights-12-mica-prevention-of-market-abuse/) — Market-abuse prohibitions (insider dealing, unlawful disclosure, manipulation) apply to crypto-assets admitted to trading or for which admission has been requested on an EU trading platform
- T3[MiCA Art 75](https://defi-intel.com/regulators/afm-nl/) — Custody-and-safeguarding duties for CASPs (segregation of client crypto-assets, custody policy, liability for loss) apply in NL as in all MiCA member states; no NL-specific gold-plating or derogation identified this cycle.

### Netherlands: C6 Tax TreatmentAmberEnacted in forceModule confidence: Probable▾

Individual holders taxed via Box 3 deemed-income wealth tax; this core claim is HELD pending primary-source verification per Challenger flag f-003 (stale sourcing omits the 2021 Supreme Court ruling, 2022-2026 interim regime, and Feb-2026 replacement Act). VAT exemption (Hedqvist), business-asset income tax, and DAC8 reporting from 1 Jan 2026 remain in force.

Horizon · 2027-01-31 (± a quarter) DAC8/CARF first reporting deadline In force · Tier 3 source

C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 8 traced claims · Re-verified 2026-11-04

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### Netherlands: C7 Cross-Border TransferGreenEnacted in forceModule confidence: Probable▾

MiCA passporting mechanics remain settled: an AFM-issued CASP licence enables EEA-wide operation. ESMA has reiterated that unauthorised entities, including non-EU CASPs, serving EU clients breach EU law and must cease services. Cross-border AML/CFT checks continue to apply irrespective of national MiCA-transposition status, with substantive detail deferred to FIM.

C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 12 traced claims · Re-verified 2026-11-04

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### Netherlands: C8 AML/CFT RegimeGreenEnacted in forceModule confidence: Probable▾

No independent AML/CFT findings were developed for the Netherlands this cycle; this module is intentionally deferred to the financial-integrity monitor's aml_cft_regime subscription baseline, which carries Wwft obligations, FIU-Nederland reporting, and travel-rule application for NL crypto activity. An internal run-metadata source-tier count contradiction (Challenger flag f-004, soft_flag) was noted this cycle and remains outstanding pending upstream metadata correction; it does not concern this module's substantive content.

C8 · AML/CFT Regime — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-11-04

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