Cryptocurrency Custody Regulations in the Netherlands

The Netherlands regulates cryptocurrency custodial services primarily through the Markets in Crypto-Assets Regulation (MiCAR) and the Dutch Money Laundering and Anti-Terrorist Financing Act (Wwft), with oversight split between the Dutch Authority for the Financial Markets (AFM) and De Nederlandsche Bank (DNB).[2][6]

Custodial License Requirements

Custodian wallet providers must obtain a MiCAR license from the AFM to legally offer custodial services.[2][8] The AFM began accepting MiCAR license applications in April 2024, with licenses becoming effective from December 30, 2024.[4] A 12-month transitional period allowed existing crypto asset service providers (CASPs) to operate under previous regulations while seeking MiCAR licensure, which ended June 30, 2025.[4]

To register as a custodian wallet provider, companies must submit practical and substantive information demonstrating compliance with the Wwft and the Sanctions Act (Sanctiewet 1977), including fitness and propriety assessments for policymakers.[1]

Regulatory Oversight Structure

The AFM handles licensing and supervisory requirements for CASPs under MiCAR, while the DNB maintains responsibility for anti-money laundering and counter-terrorist financing compliance under the Wwft and manages the register of crypto service providers.[6] The DNB also oversees prudential supervision of crypto firms and stablecoin issuers.[2]

Notable Gaps in Search Results

The search results do not provide specific information regarding:

• Segregation of client assets rules - regulations on how custodians must segregate customer funds
• Insurance or bonding requirements - mandatory coverage for custodial losses
• Cold storage mandates - specific requirements for offline asset storage
• Qualified custodian definitions - formal criteria defining eligible custodial entities

The sources indicate that while the Netherlands has adopted MiCAR for licensing purposes, detailed operational requirements for these specific custody safeguards are not addressed in the available materials. For comprehensive guidance on these technical requirements, you would need to consult the full MiCAR regulation text or contact the AFM directly, as the search results focus primarily on registration and anti-money laundering requirements rather than asset protection specifications.