The Netherlands operates under EU MiCA while maintaining robust national oversight through De Nederlandsche Bank (DNB) and the AFM. Crypto service providers must register with DNB for AML compliance. The country has a mature regulatory framework emphasizing consumer protection and financial crime prevention. The Netherlands is home to numerous crypto businesses and maintains a supportive yet well-regulated environment. Dutch authorities have been proactive in enforcement actions against non-compliant operators while supporting legitimate businesses with clear regulatory pathways.

Regulatory Authority: DNB (central bank), AFM (financial markets). Framework: EU MiCA + Dutch national requirements. Registration: Mandatory DNB registration for crypto service providers. Taxation: Income tax or capital gains tax depending on classification. AML/CFT: Stringent requirements; active enforcement. Consumer Protection: Strong investor safeguards. Licensing: Clear pathways for compliant businesses. Enforcement: Proactive against non-compliant operators. Banking: Good integration with traditional finance. Innovation: Supportive of legitimate crypto businesses.

MiCA Implementation in Netherlands

Netherlands implements the EU Markets in Crypto-Assets Regulation (MiCA) through AFM (Autoriteit Financiële Markten), the Dutch financial markets authority.

Regulatory Authorities

AFM (Autoriteit Financiële Markten): Responsible for CASP licensing and supervision under MiCA. Website: https://www.afm.nl/en/sector/cryptopartijen

DNB (De Nederlandsche Bank): Previously responsible for VASP registration (pre-MiCA). Current role: AML/CFT supervision continues. Website: https://www.dnb.nl

Transition from VASP to CASP

Old Regime (Pre-MiCA): DNB VASP registration required. Closed to new applicants 30 December 2024.

Transition Timeline: 30 December 2024 - MiCA provisions kick in. 30 June 2025 - Transitional period ENDED. Legacy VASPs had until 30 June 2025 to obtain CASP license or cease operations.

Current Status (Post-30 June 2025): All crypto service providers MUST have AFM CASP license or notification. No grandfathering beyond 30 June 2025. Unlicensed providers must cease operations.

CASP (Crypto-Asset Service Provider) License

Definition: Legal person or other undertaking whose occupation or business is the provision of one or more crypto-asset services to clients on a professional basis, authorized under Article 59 MiCAR.

Ten Crypto-Asset Services: (1) Custody and administration (2) Trading platform operation (3) Exchange for fiat (4) Exchange for other crypto (5) Order execution (6) Placing (7) Reception and transmission of orders (8) Advice (9) Portfolio management (10) Transfer services

Authorization Paths

Path 1 - Full CASP License (Article 63 MiCAR): Apply to AFM for new CASP authorization. Required for entities not already regulated. Comprehensive application process.

Path 2 - CASP Notification (Article 60 MiCAR): For already-regulated financial institutions (credit institutions, central securities depositories, investment firms, market operators, e-money institutions, UCITS management companies, AIFMs). Notify AFM 40 working days before providing services. Faster process than full license.

Application Timeline

Minimum Duration: Best Case - at least 5 months. Typical - often longer (6-12 months).

Factors Affecting Duration: Application completeness and quality, Product/service complexity and risk level, Organizational changes required, Responsiveness to AFM questions.

Application Process Steps: (1) Pre-scan (optional preliminary assessment) (2) Preparation (gather documentation, establish governance) (3) Submission (complete application via AFM portal) (4) Assessment (AFM reviews application) (5) Clarifications (back-and-forth with AFM) (6) Decision (license granted or refused)

Fit and Proper Requirements

Assessed Persons: Day-to-day operations managers, Supervisory board members, Shareholders with qualifying holdings.

Assessment Criteria: Reputation and integrity, Competence and experience, Time commitment, Independence (supervisory board).

Guidelines: Joint EBA and ESMA Guidelines on suitability assessment of shareholders and members with qualifying holdings in issuers of ARTs and CASPs.

Capital Requirements

€50,000 for lower-risk services, €125,000 for medium-risk, €150,000 for higher-risk (e.g., trading platforms), OR 25% of previous year fixed overheads - whichever is HIGHER.

CASP Requirements

General: Legal person, EU registered office, director resident in EU, effective management in EU.

Governance: Robust governance arrangements, Risk management systems, Business continuity plans, ICT security (DORA compliance).

Client Protection: Segregation of client assets, Insolvency protection provisions, Complaints handling procedures, Conflicts of interest management, Orderly wind-down plans.

Conduct: Act honestly/fairly/professionally, Fair/clear/not misleading information, Risk warnings to clients, Transparent cost disclosure, Climate impact disclosure for consensus mechanisms.

Additional Regulations: AML-CFT (EU Directive 2015/849 + TFR Regulation), DORA (Digital Operational Resilience Act), Market Abuse (MiCA provisions apply).

European Passport

CASPs licensed in Netherlands can provide services across all EU countries. Must register passport with AFM. No additional authorization needed in other Member States.

Key Advantages

Early Adopter (had VASP regime before MiCA), Clear Process (AFM provides detailed guidance and forms), EU Passport (access to entire EU market), Fintech Hub (strong crypto ecosystem in Amsterdam), Regulatory Clarity (well-established supervisory approach).

Tax Treatment of Cryptocurrency in Netherlands

Netherlands has a unique tax system where crypto is taxed as wealth (Box 3) rather than capital gains, with a deemed return approach.

Regulatory Authority

Belastingdienst (Dutch Tax and Customs Administration). Website: https://www.belastingdienst.nl

Box System Overview

Netherlands uses a "box" system dividing income into three categories: Box 1 (income from work and home), Box 2 (substantial interest in a company), Box 3 (income from savings and investments).

Cryptocurrency Classification: Treated as savings and investments (Box 3). Taxed on deemed return, not actual gains. Applies to holdings as of January 1 each year.

Box 3 Tax (Wealth Tax on Deemed Return)

How It Works: Tax authorities assume a fixed return on your assets. You pay income tax on this deemed return, not actual profit/loss. Based on total net worth (assets minus debts) on January 1.

Tax-Free Threshold (2025): €57,000 per person (€114,000 for couples). Only wealth ABOVE this threshold is taxed.

Deemed Return Rates (2025): Tiered system based on wealth brackets. Tier 1 (€57,000-€100,000): 6.04% deemed return. Tier 2 (€100,000-€1,000,000): 6.17% deemed return. Tier 3 (Above €1,000,000): 6.35% deemed return.

Income Tax Rate on Deemed Return: 36% flat rate on the deemed return.

Effective Tax Rates (2025): Tier 1: 2.17% of assets. Tier 2: 2.22% of assets. Tier 3: 2.29% of assets.

Calculation Example

Scenario: €200,000 in crypto on January 1, 2025. Single person. Tax-free threshold: €57,000. Taxable wealth: €143,000 (€200,000 - €57,000).

Breakdown: First €43,000 (up to €100,000 total) at 6.04% = €2,597 deemed return. Next €100,000 (€100,000-€200,000) at 6.17% = €6,170 deemed return. Total deemed return: €8,767. Tax at 36%: €3,156.

Result: Pay €3,156 tax on €200,000 crypto (1.58% effective rate). Regardless of whether you made or lost money in 2025.

Key Characteristics

Annual Snapshot: Only holdings on January 1 matter. Sell on January 2 - still taxed for full year. Buy on January 2 - not taxed until next year.

No Capital Gains Tax: Actual profits/losses irrelevant. Lose 50% of your crypto - still pay tax on deemed return. Gain 500% - only pay tax on deemed return (not actual gain).

Wealth Tax Nature: Tax on holding crypto, not on trading it. Similar to property tax or wealth tax. Encourages spending/investing rather than saving.

What Must Be Reported

All Crypto Holdings: Exchange balances, Hardware/software wallet holdings, Staking positions, DeFi positions, NFTs (if valuable).

Valuation: Fair market value in EUR on January 1. Use exchange rates from major platforms. Keep documentation of valuations.

Trading Activity

Crypto-to-Crypto Trades: NOT taxable events (no capital gains tax). Can trade freely without triggering tax. Only January 1 holdings matter.

Crypto-to-Fiat: NOT a separate taxable event. Already taxed via Box 3 wealth tax. No additional tax on conversion.

Frequent Trading: Does NOT change tax treatment. Professional traders still use Box 3 (with rare exceptions for businesses).

Mining and Staking

Mining Income: If professional/business activity - Box 1 income tax (progressive rates up to 49.5%). If hobby - generally Box 3 (deemed return on holdings).

Staking Rewards: Usually Box 3 treatment. Rewards increase your January 1 holdings next year. Value at receipt determines addition to wealth.

Business Income (Rare Exception)

When Box 1 Applies: Operating a crypto exchange or trading platform. Providing crypto services as a business. Systematic professional trading as primary income source.

Tax Treatment: Progressive income tax (Box 1): 36.97% up to €75,518, 49.5% above €75,518. Can deduct business expenses. VAT may apply to services.

Most Individual Traders: Remain in Box 3 even if trading frequently.

Proposed Changes and Legal Challenges

Supreme Court Ruling (2021): Current Box 3 system ruled unconstitutional. Deemed return does not reflect actual returns. Government ordered to fix system.

Transition Period: Temporary system in place while new system developed. Current rates (2025) are interim solution. Final reform expected in coming years.

Potential Future System: Move toward taxing actual returns instead of deemed returns. Would require tracking actual gains/losses. Implementation timeline uncertain.

Comparison to Other Countries

Unique Approach: Most countries tax capital gains (actual profits). Netherlands taxes wealth (deemed returns). Advantages: Simple (no need to track every trade), Predictable (know tax liability on January 1), Crypto-to-crypto trades tax-free. Disadvantages: Pay tax even if you lose money, High effective rate for low-return assets, Penalizes holding vs spending.

Key Advantages

Simple Administration: No need to track every transaction. Crypto-to-crypto trades unrestricted. Single annual calculation.

Tax-Free Threshold: First €57,000 (€114,000 couples) exempt. Small holders pay nothing.

Predictable: Know exact tax liability on January 1. No surprises during year.

Key Disadvantages

Pay Tax on Unrealized Gains: Tax even if you do not sell. Tax even if value drops during year.

Wealth Tax Nature: Discourages long-term holding. Annual ongoing cost.

High for Low-Return Assets: If crypto returns less than deemed rate, overpay tax. If crypto crashes, still owe tax.

Best Practices

Timing Matters: Consider selling before January 1 to reduce tax. Buy after January 1 to defer tax one year.

Documentation: Keep records of January 1 valuations. Screenshot exchange balances. Document wallet holdings.

Tax-Free Threshold: Utilize €57,000 exemption strategically. Couples can double to €114,000.

Consider Timing of Large Purchases: Buying €100,000 crypto on December 31 - taxed immediately. Buying on January 2 - not taxed for a year.

Recent Developments

Constitutional Challenge: System being reformed due to Supreme Court ruling. Interim rates apply for 2025. Monitor for updates on new system.

Banking Access for Crypto in Netherlands

Netherlands has historically had VERY DIFFICULT banking access for crypto, but the situation is gradually improving with MiCA implementation.

Historical Context (Pre-2025)

Major Challenge: Dutch banks among most hostile to crypto in Europe. Many banks refused crypto-related accounts. Account closures common for crypto users. "De-risking" strategy by traditional banks.

Reasons: Conservative banking culture. Strict AML/CFT interpretation. Reputational risk concerns. Regulatory uncertainty (pre-MiCA).

Current Situation (2025)

Gradual Improvement: MiCA providing regulatory clarity. AFM CASP licensing creating legitimacy. Some banks reconsidering policies. Still more difficult than Germany or France.

Traditional Banks: Generally Hostile

Major Banks Position: ING, Rabobank, ABN AMRO - historically very restrictive. Often refuse business accounts for crypto companies. Personal accounts may be closed if crypto activity detected. Enhanced scrutiny for crypto-related transfers.

Recent Developments: Some softening with MiCA implementation. Licensed CASPs have better (but not easy) access. Individual accounts less likely to be closed than before.

Crypto-Friendly Options

Bunq: Dutch neobank. Most crypto-friendly major Dutch bank. Accepts crypto exchange transfers. Personal and business accounts available. Easy account opening. Popular among crypto users. Website: https://www.bunq.com

Bitvavo: Dutch crypto exchange. Integrated banking features. EUR deposits/withdrawals. Not a full bank but provides banking interface. Licensed under old VASP regime, transitioning to MiCA.

Business Banking for Crypto Companies

Extreme Difficulty (Historically): Traditional Dutch banks very reluctant. Account opening can take 6-12+ months or be refused. Requires AFM CASP license as minimum. Even with license, many banks still refuse.

Requirements: AFM CASP license (essential). Comprehensive AML/CFT program. Business plan and financial projections. Proof of regulatory compliance. Ongoing transaction monitoring. Source of funds documentation.

Best Options for Businesses: Bunq (most accessible Dutch option). European alternatives (Lithuanian, Estonian EMIs). Cross-border options (German banks like Solarisbank). Consider multi-jurisdiction approach.

Individual Banking

Bunq: Best option for crypto users. Accepts crypto exchange transfers. Easy account opening. Reasonable fees.

Traditional Banks: Possible but risky. Do not mention crypto during account opening. Keep crypto activity separate if possible. Be prepared for questions about large transfers. Account closure risk exists.

What to Expect: Standard KYC (ID, proof of address). Source of funds questions for significant amounts. Enhanced scrutiny compared to other EU countries. Keep documentation of legitimate crypto sources.

Payment Processing

Merchant Services: Very difficult for crypto businesses. Most traditional processors refuse crypto merchants. Requires CASP license as minimum. Higher fees and stricter terms. Consider international payment processors.

Comparison to Other Jurisdictions

More Difficult Than: Germany (Solarisbank, Fidor available). France (Banque Delubac, BoursoBank). UK (Revolut, Monzo more accepting). Most other EU countries.

Similar To: Some conservative EU jurisdictions. Traditional banks in Southern Europe.

Better Than: Very few jurisdictions (Netherlands among most restrictive in developed world).

Why Netherlands Is Difficult

Conservative Banking Culture: Risk-averse approach. Prefer traditional businesses. Crypto seen as high-risk.

Strict AML Interpretation: Banks interpret AML rules very strictly. Crypto associated with money laundering risk. Enhanced due diligence burden.

Reputational Concerns: Banks worry about association with crypto. Media attention on crypto scams. Conservative customer base.

Recent Positive Trends (2024-2025)

MiCA Impact: Regulatory clarity improving bank confidence. AFM CASP licensing providing legitimacy. Some banks reconsidering blanket bans.

Bunq Expansion: Dutch neobank filling gap left by traditional banks. Growing crypto user base. Proving crypto banking can work.

European Integration: Easier to use banks from other EU countries. SEPA transfers work across borders. Can bank in Germany/France while operating in Netherlands.

Challenges Remaining

Traditional Banks Still Hostile: ING, Rabobank, ABN AMRO remain very restrictive. Business accounts extremely difficult. Even licensed CASPs struggle.

Account Closures: Still occur, though less frequent. Banks can close accounts without detailed explanation. Crypto users remain at risk.

Payment Processing: Very limited options for crypto merchants. Higher costs than traditional businesses. International solutions often necessary.

Best Practices

For Individuals: Use Bunq for crypto-related banking. Keep traditional bank account separate. Do not mention crypto to traditional banks. Document all crypto sources. Be prepared for enhanced scrutiny.

For Businesses: Obtain AFM CASP license first (essential). Target Bunq as primary option. Consider European alternatives (Lithuania, Estonia, Germany). Maintain multiple banking relationships. Prepare comprehensive AML/CFT documentation. Be transparent about business model. Consider international payment processors.

Key Takeaway

Netherlands remains one of the most difficult jurisdictions in Europe for crypto banking. Traditional banks (ING, Rabobank, ABN AMRO) are very restrictive. Bunq is the main crypto-friendly option for both individuals and businesses. MiCA implementation is gradually improving the situation, but progress is slow. Many Dutch crypto businesses use banks in other EU countries (Germany, Lithuania, Estonia) due to local difficulties. The situation is improving but remains challenging compared to most other developed countries.

Official Sources and References

Regulatory Authorities

AFM (Autoriteit Financiële Markten): Dutch Financial Markets Authority. CASP Requirements: https://www.afm.nl/en/sector/cryptopartijen/vereisten-en-vergunningen. Main website: https://www.afm.nl

DNB (De Nederlandsche Bank): Dutch Central Bank. AML/CFT Supervision: https://www.dnb.nl. Historical VASP registration (pre-MiCA).

Legal Framework

MiCA Regulation (EU): Regulation (EU) 2023/1114 on Markets in Crypto-Assets. Official EUR-Lex: https://eur-lex.europa.eu/eli/reg/2023/1114/oj

Tax Authority

Belastingdienst: Dutch Tax and Customs Administration. Main website: https://www.belastingdienst.nl. Box 3 information and guidance.

Tax Guides

Kraken Netherlands Tax Guide: https://www.kraken.com/learn/netherlands-crypto-tax-guide Koinly Netherlands Tax Guide: https://koinly.io/guides/crypto-tax-netherlands/ CoinTracking Netherlands Guide: https://cointracking.info/tax/netherlands/

Banking Resources

Bunq: Crypto-friendly Dutch neobank. https://www.bunq.com Bitvavo: Dutch crypto exchange with banking features. https://bitvavo.com

Industry Resources

Crypto-Friendly Banks Europe: https://thebanks.eu/articles/crypto-friendly-banks-in-Europe Bitcoin.fr Banking Guide: https://bitcoin.fr/banques-crypto-friendly/

Legal and Compliance

CMS Law - Netherlands Crypto Guide: https://cms.law/en/int/expert-guides/cms-expert-guide-to-crypto-regulation/netherlands Norton Rose Fulbright - Netherlands Crypto: https://www.nortonrosefulbright.com/en/knowledge/publications/netherlands-crypto

Last Updated

December 27, 2025