Dutch Crypto Custodians

MiCA Compliance Analysis - June 2025 Update

URGENT: Netherlands MiCA transitional period ends on June 30, 2025

Executive Summary

Current Status

  • Critical Deadline: June 30, 2025 marks the end of the Netherlands' MiCA transitional period
  • Licensed Companies: 6 companies have secured MiCA licenses from Dutch AFM
  • DNB Registered: Over 80 crypto service providers currently registered with DNB
  • Time Remaining: Less than 3 weeks for remaining companies to obtain licenses

Key Insights

Compliance Gap: Most DNB-registered companies have not yet secured MiCA licenses, creating significant market uncertainty.

Success Stories: Companies like Zebedee (ZBD), MoonPay, and BitStaete demonstrate that MiCA compliance is achievable.

Market Consolidation: MiCA regulations are likely to reduce the number of active crypto service providers in the Netherlands.

MiCA License Holders in the Netherlands

Zebedee Europe B.V. (ZBD)

Licensed

Bitcoin Lightning Network payment infrastructure focused on gaming and entertainment industries.

License Date: December 30, 2024

Services: Custody, Exchange, Transfer

MoonPay Europe B.V.

Licensed

Global crypto payment infrastructure provider enabling fiat-to-crypto transactions.

License Date: December 30, 2024

Services: Exchange, Transfer

BitStaete B.V.

Licensed

Digital asset management services for wealthy individuals and institutional clients.

License Date: December 30, 2024

Services: Portfolio Management

Hidden Road Partners

Licensed

Prime brokerage and clearing services for institutions across traditional and digital assets.

License Date: December 30, 2024

Services: Exchange, Execution

Vivid Money B.V.

Licensed

Digital banking platform with integrated cryptocurrency services.

License Date: May 1, 2025

Services: Custody, Order Transmission

AvianLabs Netherlands

Licensed

Crypto payment solutions with focus on cross-border transactions.

License Date: February 4, 2025

Services: Exchange, Transfer

Major Companies Analysis

Bitvavo B.V.

License Expected 2025

Current Status

  • • Largest EUR-spot exchange globally
  • • Currently applying for MiCA license with AFM
  • • ~50% market share in Dutch crypto market
  • • Strong financial position and compliance track record

Compliance Assessment

Readiness Score:

Very High - Expected to receive license before deadline

Knaken Cryptohandel B.V.

Actively Preparing

Current Status

  • • Proactively delisting non-MiCA compliant stablecoins
  • • Phased approach: USDT, XAUT, DAI, EURT removal
  • • Strong focus on regulatory compliance
  • • Local Dutch exchange with established user base

Compliance Assessment

Readiness Score:

High - Proactive compliance measures indicate strong preparation

International Players

Various Statuses
Coinbase Europe Ltd

Licensed in Ireland, can passport to Netherlands

EU Licensed
Crypto.com

Licensed in Malta, operating across EU

EU Licensed
Binance

No MiCA license yet, compliance uncertain

Uncertain

Complete Dutch Crypto Custodians Registry

Company Name Status Readiness Services Registration Date Notes
Zebedee Europe B.V. (ZBD) MiCA Licensed
Exchange, Custody, Transfer May 14, 2024 Bitcoin Lightning Network specialist
MoonPay Europe B.V. MiCA Licensed
Exchange, Transfer Dec 30, 2024 Global payment infrastructure
BitStaete B.V. MiCA Licensed
Portfolio Management Dec 30, 2024 Asset management for institutions
Hidden Road Partners CIV NL B.V. MiCA Licensed
Exchange, Execution Jun 26, 2023 Prime brokerage services
Vivid Money B.V. MiCA Licensed
Custody, Order Transmission May 1, 2025 Digital banking platform
AvianLabs Netherlands B.V. MiCA Licensed
Exchange, Transfer Mar 12, 2024 Cross-border payment solutions
Bitvavo B.V. License Expected
Exchange, Custody Nov 9, 2020 Largest EUR-spot exchange globally
Knaken Cryptohandel B.V. Actively Preparing
Exchange, Custody Mar 3, 2021 Delisting non-MiCA stablecoins
Coinbase Europe Limited EU Licensed (IE)
Exchange, Custody Sep 21, 2022 Licensed in Ireland, can passport
Crypto.com (Foris DAX) EU Licensed (MT)
Exchange, Custody Jul 27, 2023 Licensed in Malta, EU passport available
Bitstamp Europe S.A. EU Licensed (LU)
Exchange, Trading Platform Apr 28, 2021 Licensed in Luxembourg
Digital Currency Services B.V. (HappyCoins) Status Unknown
Exchange, Custody Nov 17, 2020 Local Dutch exchange
Phoenix Payments B.V. (Anycoin Direct) Status Unknown
Exchange, Custody Nov 4, 2020 Dutch crypto broker
Coin Meester B.V. (Bitcoin Meester) Status Unknown
Exchange, Custody Nov 13, 2020 Acquired by Kraken in 2024
Coinmerce B.V. Status Unknown
Exchange, Custody Nov 9, 2020 Local Dutch exchange
BTC Direct Europe B.V. Status Unknown
Exchange, Custody Nov 19, 2020 Bitcoin-focused exchange
Bitonic B.V. (Bl3p) Status Unknown
Exchange, Custody Nov 17, 2020 One of oldest Dutch exchanges

Note: This table includes major known companies. The complete DNB register contains over 80 registered entities.

MiCA Implementation Timeline

April 20, 2023

MiCA approved by European Parliament

June 29, 2023

MiCA enters into force

June 30, 2024

Stablecoin regulations become applicable

December 30, 2024

Full MiCA regulation comes into effect

January 2025

First MiCA licenses granted in Netherlands

June 30, 2025

Netherlands transitional period ends - CRITICAL DEADLINE

July 2026

EU-wide full compliance deadline

License Status Distribution

Compliance Readiness Assessment

MiCA Requirements Framework

Key Requirements for CASPs

  • EU Presence: Physical office and at least one EU-resident director
  • Capital Requirements: €50,000 to €150,000 based on services offered
  • Security Standards: Robust cybersecurity and risk management
  • AML/KYC: Enhanced customer due diligence procedures
  • Reporting: Regular compliance and financial reporting

Service Categories

Class 1 CASP (€50,000 capital)

  • • Custody and administration
  • • Order reception and transmission
  • • Crypto-asset advice

Class 2 CASP (€125,000 capital)

  • • All Class 1 services plus:
  • • Order execution
  • • Portfolio management

Class 3 CASP (€150,000 capital)

  • • All Class 2 services plus:
  • • Trading platform operation
  • • Crypto-asset placing

Strategic Recommendations

Immediate Actions

  • • Submit MiCA license application immediately
  • • Engage legal counsel specialized in MiCA
  • • Assess capital requirements and funding
  • • Review and update compliance procedures
  • • Consider partnership with licensed entities

Operational Preparation

  • • Establish EU physical presence
  • • Implement enhanced AML/KYC systems
  • • Develop comprehensive risk management
  • • Create regulatory reporting infrastructure
  • • Train staff on MiCA requirements

Long-term Strategy

  • • Leverage EU passport for expansion
  • • Develop MiCA-compliant product offerings
  • • Build strategic partnerships
  • • Monitor regulatory developments
  • • Consider M&A opportunities

Alternative Compliance Paths

Article 60 Exemption

Financial institutions already regulated under EU law (banks, investment firms) can notify regulators instead of applying for full CASP license.

White-label Solutions

Partner with licensed entities to offer services under their license while building your own compliance capabilities.