The adoption of blockchain technology and asset tokenization is advancing at a rapid pace, but the real engine driving its global development is the existence of a clear, consistent and innovation-friendly legal framework.
Some countries have already established themselves as regulatory benchmarks, establishing specific rules for cryptoassets, DLT infrastructures and issuance of legally backed tokens. In this article we show you the relevant information about blockchain regulation in the Netherlands, which you can use as a guide if you are looking to operate internationally or evaluate different strategic locations.
Current legislation on blockchain and virtual assets in the Netherlands
MiCA Regulation (Markets in Crypto-Assets Regulation)
Establishes the EU’s first comprehensive legal framework for regulating cryptoasset issuers and service providers (CASPs). Covers stablecoins, utility tokens, electronic money tokens (EMTs), asset referenced tokens (ARTs), and custody or exchange platforms. Requires prior authorization, governance requirements, solvency, transparency, and user protection.
MiFID II (Markets in Financial Instruments Directive II)
European Directive that regulates the markets of traditional financial instruments and also applies to cryptoassets considered as financial instruments (e.g. security tokens). It establishes rules on transparency, investor protection, advisory services, order execution and prudential requirements for investment firms.
Prevention of Money Laundering Act (Wwft)
The Wwft implements the AMLD5 Directive in the Netherlands, requiring cryptoasset service providers to register with the DNB and comply with anti-money laundering and terrorist financing prevention obligations. This includes customer identity verification (KYC), transaction monitoring and suspicious transaction reporting. Failure to comply can lead to severe penalties or deregistration. The Wwft applies to both domestic and foreign entities operating in the country.
Cryptoasset Sandbox and DLT Pilot Regime in the Netherlands
The Netherlands is actively involved in blockchain innovation initiatives. The AFM and DNB maintain a joint Innovation Hub that allows fintech and blockchain companies to obtain informal guidance before applying for licenses. At the European level, the Netherlands participates in the European Blockchain Regulatory Sandbox (the European Commission’s financial regulatory sandbox for blockchain projects) and in the EU DLT Pilot Scheme (Regulation 2022/858) for market infrastructures.
The EBSI (European Blockchain Services Infrastructure) is a different initiative: a pan-European public infrastructure for cross-border government digital services such as verification of educational credentials or official documents, not a financial sandbox.
Tokenization makes it possible to digitally represent real-world assets via blockchain, but for it to have legal value, a regulatory framework recognizing this operation is essential. The Netherlands adopts its own approach, establishing specific rules for the issuance, custody or trading of tokens. In this block we explain how asset tokenization is regulated from a legal point of view, taking an advanced jurisdiction such as the Netherlands as an example.
Regulation of asset tokenization in the Netherlands
The Netherlands allows tokenization of financial assets under the framework of the MiCA Regulation and the MiFID II Directive. Tokens representing financial instruments – such as stocks, bonds or fund shares – are subject to the same rules as their traditional equivalents, including authorization, governance and disclosure requirements overseen by the Authority for Financial Markets (AFM). Any public offering of tokens considered securities must have a prospectus approved by the AFM, in accordance with European regulations.
Tokenization of non-financial assets, such as real estate or art, is not specifically regulated, but may involve compliance with tax, civil or consumer protection regulations, depending on their structure. The MiCA Regulation also regulates the issuance and trading of utility tokens and stablecoins, provided they are not considered financial instruments, which provides a general framework applicable to various tokenization models.
The Netherlands does not have a dedicated regulatory sandbox for tokenization projects, but the AFM and DNB maintain a joint Innovation Hub that provides informal regulatory guidance to fintech and blockchain companies.
Regulatory bodies and authorities for digital assets in the Netherlands
Authority for Financial Markets (AFM)
The AFM is the entity responsible for the supervision of the financial markets in the Netherlands and plays a central role in the application of the MiCA Regulation. It licenses CASPs, reviews whitepapers and prospectuses for security token issues (STOs), and ensures transparency and investor protection. It also regulates advertising related to cryptoassets and assesses the risks associated with utility tokens. It collaborates with ESMA and other European regulators to ensure consistent supervision across the European Economic Area.
Netherlands Central Bank (DNB)
DNB oversees the financial stability of the country and, under the Dutch “twin peaks” model that divides supervision between AFM and DNB, exercises prudential supervision of CASPs (including the assessment of acquisitions of qualifying holdings) and is the competent authority to supervise issuers of stablecoins (ARTs and EMTs), ensuring compliance with the reserve, liquidity and governance requirements set forth in MiCA.
The registration of VASPs managed by DNB was terminated on June 30, 2025 with the end of the transitional period; since then, all CASP activities require full authorization under MiCA. It also participates in the regulation of DeFi and institutional blockchain initiatives, and collaborates in European studies on CBDC.
Financial Intelligence Unit of the Netherlands (FIU-NL)
FIU-NL is responsible for receiving, analyzing and reporting suspicious transactions related to financial crimes, including those linked to crypto-assets. CASPs authorized under MiCA are required to notify FIU-NL of activities that may be related to money laundering or terrorist financing. The FIU collaborates with national and international authorities to prevent abuses in the digital financial system. Its analysis helps to detect illicit networks and emerging risk patterns in the use of digital assets.
Launching a business based on digital assets requires more than just technology: it is also necessary to comply with legal requirements such as licensing, registration and regulatory obligations. These conditions ensure that the business model is viable and sustainable over time, and that it meets transparency and fraud prevention standards. In this section we explore what licenses are typically required and what compliance criteria blockchain companies operating in the Netherlands must follow.
What licenses and requirements are needed to trade cryptoassets in the Netherlands?
CASP License (MiCA)
CASP licensing is mandatory under the MiCA Regulation for exchanges, custodians and issuers of ART and EMT tokens operating in the Netherlands or the EU. The Netherlands chose the shortest transitional period in the EU: 6 months, which expired on June 30, 2025. VASPs registered with DNB could continue to operate during that transitional period, but had to be licensed or authorized by the AFM by June 30, 2025.
Since that date, any CASP operating in the Netherlands without a license from the AFM (or without a passport from another member state) is operating illegally. License applications are addressed to the AFM, which coordinates with the DNB for the assessment of prudential requirements. The AFM grants or denies prior administrative authorization for CASPs, after consultation and collaboration with the Dutch Central Bank, especially when dealing with issuers of stablecoins (electronic money tokens, EMTs, and asset referenced tokens, ARTs), where the Dutch Central Bank assumes a specific supervisory role.
Investment Firm License (ESI)
If a Dutch platform offers crypto derivatives (such as futures, options, CFDs or other financial products whose underlying is a cryptocurrency), those products are considered financial instruments under European and Dutch law. Therefore, the trader needs an investment firm license under MiFID II to be able to offer them legally.
AML/KYC Compliance
All crypto companies in the Netherlands must comply with the Wwft Act (Wet ter voorkoming van witwassen en financieren van terrorisme), which transposes the AMLD5 into Dutch law.
This includes the application of KYC processes, transaction monitoring, identification of beneficial owners and reporting of suspicious activities to FIU-NL. The AFM oversees CASPs’ compliance with conduct of business obligations – including AML – as an essential condition for obtaining and maintaining the MiCA license. DNB supervises prudential requirements. The FIU-NL is the financial intelligence unit receiving suspicious transaction reports, but is not the licensing supervisory authority.
Other regulatory requirements
Crypto companies in the Netherlands must comply with the DORA Regulation, in addition to minimum capital requirements and annual technical audits. DORA requires ICT risk management systems, cybersecurity, business continuity and regular digital resilience testing. It also mandates oversight of external technology providers and training of staff in digital security. Compliance with DORA is mandatory to maintain the MiCA license.
Are you exploring developing your blockchain project in the Netherlands?
At Metlabs we help companies like yours and offer comprehensive support in the development of blockchain projects and tokenization of assets such as real estate, carbon credits, commodities, intellectual property, financial instruments, franchises and more, fully aligned with blockchain regulation in the Netherlands and international regulatory standards.
Contact us and find out how we can help you meeting all your business model needs, from technical validation and structuring to design, development and implementation of custom blockchain solutions, ready to scale from day one.