Netherlands VASP to CASP Transition: 2026 Guide

For years, a Dutch crypto business ran on a single line in a register: an anti-money-laundering registration held with De Nederlandsche Bank (DNB), the central bank. It was never a full licence — it authorised you to operate, checked your AML controls, and stopped there. Under the Markets in Crypto-Assets Regulation (MiCA), that registration has been switched off and replaced with a genuine EU credential: the Crypto-Asset Service Provider (CASP) licence, issued in the Netherlands by the AFM (Autoriteit Financiële Markten). If you are working from an old DNB registration, the important fact is that the Dutch window has already closed.

In our practice, the Dutch transition is unusual for one reason: the deadline is behind you, not ahead. The Netherlands cut its MiCA transition window to 30 June 2025 — a full year before the EU-wide 1 July 2026 backstop — so the regime is already fully MiCA and actively enforcing. This guide is the practical path from a lapsed DNB registration to a live AFM CASP authorisation, and what the early cutoff means for anyone still operating on the old footing.

From DNB registration to AFM licence

The change here is not just a new form — it is a new supervisor and a new kind of permission. Under the pre-MiCA regime, a Dutch crypto firm registered with DNB under the country’s anti-money-laundering law. That registration confirmed your AML and integrity controls, but it was explicitly not a prudential or conduct licence, and it carried no authority beyond the Netherlands. It was the Dutch equivalent of the light national registrations that existed across the EU before the rules were harmonised.

MiCA replaced that patchwork with one directly applicable regulation and one licence type that carries across the whole bloc. In the Netherlands, that shifted the centre of gravity to the AFM, which now issues the CASP licence and supervises how you conduct business — client-asset safeguarding, disclosure, complaints and market conduct. DNB does not disappear; under the twin-peaks model it retains prudential supervision of e-money-token (EMT) and asset-referenced-token (ART) issuers. So the firm that once answered only to DNB for AML now answers to the AFM for its licence and conduct, with DNB in the frame where token issuance is involved. Our MiCA regulation explained guide covers the regime change in full; this article focuses on what a Dutch DNB-registered firm specifically has to do about it.

The early cutoff — 30 June 2025

This is the single fact that separates the Netherlands from most of the EU. The transitional relief in Article 143 of MiCA grants firms that were already providing crypto-asset services under national law a grandfathering period in which they may continue on the old basis — up to a backstop of 1 July 2026. Member states were free to shorten it, and the Netherlands did, choosing 30 June 2025.

The Dutch supervisors framed that choice as a deliberate signal. Rather than let a light-touch registration linger for another year, they wanted the market cleared onto full MiCA licences early, and they were prepared to enforce it. For legacy operators, the practical consequence is blunt: the grace period Dutch firms might have assumed they had — the one their peers in slower member states still enjoy — does not exist here. A DNB registration that “still works” in appearance has had no legal standing to provide services since mid-2025. There is no soft landing left to plan for; there is only the gap between where an operation sits today and a granted AFM CASP authorisation.

Old DNB VASP registration vs new AFM CASP licence

What a legacy operator must actually do now

Converting to a CASP is a substance exercise, not a re-registration. The DNB entry most firms held was granted with modest requirements — AML controls, fit-and-proper checks, little in the way of capital or prudential governance. A CASP authorisation is a full financial-services licence, and the AFM assesses it as one. The applicant is a Dutch company with genuine substance — real management in the Netherlands, a real office and a real compliance function, not a nameplate.

The core build looks like this:

• A Dutch company (typically a B.V.) as the licence applicant, with a registered office and genuine operating presence in the Netherlands.
• Class-based initial capital of €50,000, €125,000 or €150,000 depending on the CASP service class, held in an EEA bank or e-money account.
• Fit-and-proper management assessed by the AFM (with DNB where token issuance is in scope), plus a dedicated MLRO and board-level compliance oversight.
• AML/CFT policies aligned to the EU’s fifth and sixth anti-money-laundering directives and the Travel Rule — originator and beneficiary data on transfers under the Transfer of Funds Regulation.
• A DORA-compliant ICT framework — risk management, incident reporting, resilience testing and third-party ICT oversight, applicable to CASPs since 17 January 2025.
• A programme of operations, business plan and financial projections, plus custody, safeguarding, conflicts and complaints-handling policies, and a MiCA white paper where relevant.

Compared with the registration era, when little of this was asked of a Dutch firm, it is a real project — and the ICT and AML builds are the long poles. There is also a Dutch-specific planning note: if your model provides certain payment services tied to e-money tokens, a separate PSD2 payment-institution licence may apply from 1 March 2026, so it pays to scope that overlap before you file rather than after. The full requirements breakdown is in our Netherlands crypto licence requirements guide, and the fee picture — capital, substance and build costs — is in our Netherlands crypto licence cost guide.

What the transition costs — and what it buys

Because the Dutch window has already shut, the honest framing for a legacy operator is remediation, not a leisurely upgrade. Continuing to serve Dutch or EU users on a lapsed DNB registration is unauthorised activity, and the exposure is twofold. First, regulatory: the AFM supervises an early-enforcer regime and can act on unlicensed provision. Second — and usually faster — commercial: crypto-friendly banks, EMI and payment-institution partners verify authorisation status directly, and a registration that resolves to a sunset regime simply fails that check. When it fails, settlement holds and account closures follow quickly, and unlike a fine there is no negotiating your way out of a bank’s risk decision. If a permission lapsed before a new licence was in place, you are in a re-authorisation under pressure — the exact situation our crypto licence renewal in Europe guide exists to help operators avoid.

Set against that, the payoff is reach and standing. The old DNB registration only ever authorised you in the Netherlands; every other EU market was closed or required its own local registration. A CASP authorisation passports across all 27 member states under MiCA Article 65 — you apply once with the AFM, notify the host states you want to serve, and operate EU-wide from a single licence. The credential also carries more weight precisely because the Netherlands enforced early: banks, institutional counterparties and auditors read a Dutch MiCA CASP as a firm that cleared a strict bar, not a light-touch one. In our experience that shows up as smoother onboarding and a shorter due-diligence cycle. The substance you build — the Dutch company, the MLRO, the DORA and AML stack — is the same foundation you reuse to add service classes or scale into new markets, and our Netherlands crypto licence pillar sets out the full picture of what the authorisation unlocks.

The one option that isn’t safe is drifting on a registration that lost its legal footing in mid-2025. Whether you are a Dutch operator regularising an existing business or a new entrant choosing the Netherlands for its credibility, the route is the same full AFM CASP application. Book a free consultation and we’ll size the transition against your service classes, capital, banking needs and timeline before you commit.

This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.