MiCAR licensing and supervisory support for crypto-asset service providers
A MiCAR licence stands or falls on a file that holds together and an AML framework that survives scrutiny. We guide crypto-asset service providers from readiness scan to authorisation — led by someone who has been through it from the inside, in three member states.
What is MiCAR?
MiCAR — the Markets in Crypto-Assets Regulation, Regulation (EU) 2023/1114 — is the European framework for crypto-assets and crypto-asset services. It makes authorisation mandatory for crypto-asset service providers and sets requirements for governance, capital, safekeeping of client assets, disclosure, complaints handling and market abuse. Because it is a regulation, MiCAR applies directly: there is no national statute in between giving you room to interpret.
Two supervisors, two files
| Supervisor | What they look at |
|---|---|
| AFM | Leading role in authorising CASPs, conduct supervision and market abuse supervision. This is where the weight of the application sits. |
| DNB | Prudential supervision of CASPs, assessment of qualifying holdings, and the lead on issuance of asset-referenced and e-money tokens — alongside the integrity supervision you already know from the AML regime. |
Practical consequence: an application written only for the AFM stalls on the prudential and integrity elements. We build the file for both desks from the start.
Where applications actually stall
- A thin AML framework. MiCAR does not replace anti-money laundering obligations — it sits on top of them. A client acceptance policy that does not match the real risks of your product is the most common finding.
- Policy that does not match practice. Documents that read well but do not describe what the system actually does; the supervisor tests precisely that alignment.
- Safekeeping of client assets. Segregation of own and client funds, key management and liability on loss — evidenced technically and legally.
- Fit and proper. Directors who are under-prepared for the interview, or a board without demonstrable AML expertise.
- Incomplete submission. The assessment clock only starts on a complete application; every supplement adds weeks.
What we do
Readiness scan
Two weeks. Your current set-up against the MiCAR requirements, with what is missing, what it costs and in which order it has to happen.
Application file
Policies, procedures, business plan, ICT and continuity documentation and the full AML/CFT framework — in the form the supervisor expects.
Board preparation
Fit and proper: file preparation, evidence of expertise, and a realistic rehearsal for the interview.
Question rounds
We draft and track the answers to the supervisor's letters, so deadlines are met and answers stay consistent with the file.
Examinations
Already under examination or facing a remediation deadline? We support the response, the remediation plan and the progress reporting.
Cross-border
Notification and passporting to other member states, with attention to the differences in expectation between the Netherlands, France and Poland.
Why us
Tarik Binnekade, senior advisor and MLRO at ZandKade Compliance, carried responsibility for the AML/CFT framework of regulated crypto-asset service providers in the Netherlands, France and Poland, and handled both supervisory examinations and MiCAR licence readiness. That is a different starting point from a firm that has read the regulation: he knows which questions arrive, in what order, and which answer invites a follow-up.
What it costs
- MiCAR readiness scan: from € 3,950 excluding VAT, two weeks. Includes a gap overview, prioritisation and a cost estimate.
- Full licensing support: from € 12,500 excluding VAT, quoted per phase so you can change course after each one.
- Examination and remediation support: on a day rate or a fixed price per remediation plan.
If the 2027 EU regulation is also on your agenda, combine this with the AMLR gap analysis — it saves a second documentation round.
Frequently asked questions
What is MiCAR?
MiCAR stands for Markets in Crypto-Assets Regulation: Regulation (EU) 2023/1114. It is the European framework for crypto-assets, stablecoin issuers and crypto-asset service providers. MiCAR makes authorisation mandatory for crypto-asset service providers in the EU and sets requirements for governance, capital, safekeeping of client assets, disclosure and market abuse. Being a regulation, it applies directly — there is no national law in between to reinterpret it.
Who grants the MiCAR licence in the Netherlands?
In the Netherlands the AFM has the leading role in authorising crypto-asset service providers (CASPs) and in conduct supervision, including market abuse. DNB carries out prudential supervision of CASPs, assesses qualifying holdings, and leads on the issuance of asset-referenced tokens and e-money tokens. In practice you deal with two supervisors and two files.
What is a CASP?
A CASP (crypto-asset service provider) is an undertaking that professionally provides one or more crypto-asset services: custody and administration on behalf of clients, operation of a trading platform, exchange of crypto-assets for funds or for other crypto-assets, execution of orders, placing, reception and transmission of orders, advice, portfolio management, or transfer services.
How long does a MiCAR licence application take?
Expect six to twelve months from start to authorisation. The statutory assessment period only begins once the application is complete; in practice most of the time goes into completing the file and answering the questions that follow. Preparation — policies, governance, AML framework, ICT and custody arrangements — usually takes three to six months before submission makes sense.
Can I passport a Dutch MiCAR licence across the EU?
Yes. MiCAR provides for a European passport: with authorisation in one member state you can, after notification, provide services in others. That does not mean you will be treated identically everywhere — national supervisors differ in what they expect around AML, complaints handling and marketing communications. We have seen those differences from the inside in the Netherlands, France and Poland.
Does MiCAR replace anti-money laundering obligations?
No. MiCAR governs market access, conduct and prudential requirements; the AML regime applies alongside it. As a crypto-asset service provider you are an obliged entity under the Dutch AML Act and, from 10 July 2027, under the EU Anti-Money Laundering Regulation, which applies directly. A licence file with a weak AML framework is where applications tend to stall.
What does MiCAR licensing support cost?
A readiness scan comparing your current set-up against the MiCAR requirements starts at € 3,950 excluding VAT, with a two-week turnaround. Full support for the licence file — policies, governance, AML framework, application forms and the supervisor's rounds of questions — starts at € 12,500 excluding VAT and is quoted per phase.
Sources
- Regulation (EU) 2023/1114 (MiCAR) — EUR-Lex
- CASP licence — AFM
- Supervision of crypto firms — AFM
- MiCAR — De Nederlandsche Bank
- Vergunningaanvraag voor CASPs — De Nederlandsche Bank
- Regulation (EU) 2024/1624 (AMLR) — EUR-Lex
- European Securities and Markets Authority (ESMA)
Related
Unsure whether you need authorisation at all? That is a thirty-minute conversation, not a proposal process. We walk your services past the MiCAR definitions and tell you whether — and for what — you need a licence. Book a call.