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Crypto banking for crypto-asset service providers licensed by the AFM

The Netherlands gave its DNB-registered crypto firms only six months, and the transition closed on 30 June 2025. Today the AFM grants the licence, while DNB handles prudential supervision and qualifying holdings. We supply the platform and the technical answers both of them will ask for.

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Crypto Banking · CASP

What an AFM licence under MiCA lets you offer

Wallets held for your clients

Crypto accounts with a deposit address and QR code per client. You act as custodian under MiCA and run the keys on custody infrastructure you contract, so Crassula never touches them.

Euro on- and off-ramp

Clients buy and sell crypto against euro with liquidity from a connected provider, and see the rate and fee before they confirm. The euro side settles in their account in the same app.

IBAN accounts and SEPA payouts

Euro accounts with SEPA, SEPA Instant and SWIFT through the bank you work with. Fiat owed to clients and their crypto balances post to one ledger.

Transfers in and out

Internal transfers between your clients and on-chain withdrawals. Originator and beneficiary data go out through a Travel Rule provider you connect.

Passported service across the EEA

After the AFM forwards your notification to other member states, the same apps and back office serve clients there.

What this licence does not cover

  • Serving Dutch clients on an old DNB crypto registration. That route closed on 30 June 2025.
  • Issuing euro stablecoins. Supervision of e-money tokens and asset-referenced tokens sits with DNB and requires a separate status.
  • Deposit taking or lending to clients.
Your market

What the regulator asks about your IT

Each requirement, what the platform gives you for it and who owns it after launch.

1Licence application to the AFM, ideally after an optional pre-scan of the draft

A configured environment and a written ICT description you can put in front of the AFM during the pre-scan, so the feedback covers your real set-up.

You, with our input
2Prudential requirements and own funds (Art. 67 MiCA), supervised by DNB

Ledger exports of client and own-account balances and fee income, which your finance team uses for the own-funds calculation.

Your finance team
3Information on shareholders with qualifying holdings, assessed by DNB

Nothing to provide here. This part of the file is about your owners, not your systems.

You and your shareholders
4ICT systems, security arrangements and DORA compliance

Architecture, hosting, access roles, 2FA, audit trail, backup and incident handling described, plus the details for your register of ICT third-party arrangements.

Crassula drafts, you adopt
5Register of positions per client and segregation (Art. 75 MiCA)

Per-client crypto holdings on separate ledger accounts from your own, with exports to reconcile against the wallets at your custody provider.

Your operations team, on platform data
6Client funds placed with a credit institution or central bank (Art. 70 MiCA)

The euro owed to each client on the ledger, ready to reconcile against your client money account.

Your finance team, on platform data
7Wwft and Sanctions Act 1977 compliance, monitored by the AFM

Onboarding questionnaires per client type, identity checks and screening through connected providers, client limits.

Your compliance officer
8Travel Rule under Regulation (EU) 2023/1113

Originator and beneficiary data captured at onboarding and on each transfer, exchanged through a connected Travel Rule provider.

Your compliance officer
Netherlands

Payment rails and providers

Rails your customers can use

SEPASEPA InstantSWIFTOn-chain transfersInternal transfers

Kraken

MiCA-authorised by the Central Bank of Ireland and passported across the EEA. Liquidity for your exchange service, or Kraken Embed, which went live in the Netherlands with bunq, if you start before your own licence.

Prefer another provider?

Crassula connects 60+ payment, banking and compliance integrations. We will check which ones fit your licence.

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24/7real-time processing, no batch window
60+payment and provider integrations connected
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15+languages the platform speaks
Netherlands

Dates to plan around

Rules that change what you have to build, in the order they apply.

  1. 22 Apr 2024

    The AFM starts accepting MiCA licence applications from crypto-asset service providers.

  2. 30 Dec 2024

    MiCA applies to CASPs, along with the crypto Travel Rule in Regulation (EU) 2023/1113. The AFM becomes the licensing authority.

  3. 17 Jan 2025

    DORA applies to crypto-asset service providers.

  4. 30 Jun 2025

    The six-month Dutch transition ends. Firms registered with DNB need a MiCA licence or a passport to keep serving the Netherlands.

  5. 5 to 6 months

    The AFM's own estimate of the minimum time to process a full licence application.

CASP

Applying to the AFM as a CASP? Name us in your application.

Two Dutch supervisors look at your firm: the AFM decides on the licence and DNB checks your prudential position and your owners. We give you a working platform and the technical part of the file, while your legal advisers handle the rest.

Talk to us about your application

Crassula provides technology and documentation support. We do not provide legal or regulatory advice and cannot guarantee the outcome of an application.

  1. 01

    A platform you can demonstrate

    A configured environment to show the regulator, not slides.

  2. 02

    The technical part of your application, prepared

    ICT systems, security and DORA, outsourcing and business continuity sections, in shape for the AFM pre-scan and the formal file.

  3. 03

    Providers lined up

    Liquidity through Kraken, plus banking, custody and KYC providers from our network, matched to your licence.

A customer checking digital-asset balances at home.
Crypto Banking

How a launch usually runs

Think of a Rotterdam team with a savings app for Dutch households that wants to add bitcoin. Its quickest start is Kraken Embed, which bunq already runs in the Netherlands, so clients can buy and sell under Kraken's authorisation while the team keeps the front end. Its lawyers confirm where the line sits for the team's own role.

In parallel it prepares its own AFM licence. We set up the environment in its brand and write the ICT and DORA part with the team, and it brings that draft to the AFM pre-scan. A new investor taking 15 percent goes through DNB's qualifying holding assessment at the same time. Once the AFM grants the licence, clients move to wallets the team holds itself, with the same app and the same ledger.

For the regulatory background, read the MiCA CASP licence guide and our guide to white-label crypto wallets.

Guides

Read the licence guides

Explore all guidesLicensing, payments, cards and core banking, explained by our team.
Netherlands · CASP

FAQ

The questions teams ask us before a first call.

Not covered here?Bring your question to a demo with our team.
Who decides on our licence, the AFM or DNB?
The AFM grants CASP licences and carries most ongoing supervision, including checks on the Wwft and the Sanctions Act. DNB handles the prudential side and assesses anyone acquiring a qualifying holding in your firm. Plan for questions from both.
What is the AFM pre-scan?
An optional, informal round before you file. You discuss your draft application and MiCA compliance with the AFM and get general feedback. It does not replace the formal review, and you need to be far enough along to talk about real policies.
How long does the AFM take?
The AFM itself says at least five to six months for a full application. MiCA sets 25 working days for the completeness check and 40 for the decision, but questions from the supervisor pause the clock.
We were registered with DNB. Is that still worth anything?
Not as a permission. The registration covered anti-money laundering only, and its transition ended on 30 June 2025. Your existing AML set-up and client data are still useful when you build the MiCA file.
Can we offer crypto in the Netherlands without our own licence?
Kraken Embed is built for that: Kraken executes and holds the assets under its Irish MiCA authorisation, and you run the interface. It already runs in the Netherlands through bunq. Have your lawyers confirm that your own activities stay outside MiCA in that set-up.
Does Crassula hold our clients' crypto?
No. Crassula is software for accounts, exchange, apps and back office. Keys sit with the custody infrastructure you contract, and you answer for custody to your clients and the AFM.
Crypto Banking

Explore your launch market

Netherlands · CASP

What an AFM licence under MiCA lets you offer

Tell us your licence and country. We will map the rails, providers and documents you need.

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