Lithuania vs Netherlands: CASP authorisation compared
The Dutch took six months where most of Europe took eighteen, and still ended up with the third largest register on the continent. That combination says more than any fee table would.
Six months is the shortest transitional period MiCA permits a Member State to set. The Netherlands chose it, alongside Latvia, Hungary, Poland, Slovenia and Finland. Of that group it is the only one with a large register at the end, which tells you the Dutch population was already supervised, already documented and already expecting this.
| Criterion | Lithuania | Netherlands |
|---|---|---|
| Regulator | Bank of Lithuania | Netherlands Authority for the Financial Markets (AFM) |
| Legal framework | MiCA, with Lithuanian implementing law | MiCA. Dutch crypto firms were registered with the central bank under AML law before it. |
| Old regime transitional period | Ended 31 December 2025 | 6 months from 30 December 2024, the shortest tier, shared with Latvia, Hungary, Poland, Slovenia and Finland. |
| Application fee | Not located on the regulator’s pages. Consultancy sites circulate a figure; no Lithuanian instrument found to support it. | Not stated on the AFM page read. |
| Supervisory fee | Not located on the regulator’s pages. | Not stated on the AFM page read. |
| Language of application | Not stated on the pages read. | Not stated on the AFM page read. |
| How it is submitted | Not stated on the pages read. | Not stated on the AFM page read. Enquiries go to the AFM crypto address. |
| Pre-application support | No published pre-application stage found on the pages read. | No published pre-application stage on the page read. |
| Completeness check | 25 working days (MiCA Article 63(2)) | 25 working days (MiCA Article 63(2)) |
| Decision period | 40 working days from a complete application (MiCA Article 63(9)) | 40 working days from a complete application (MiCA Article 63(9)) |
| Clock suspension | Up to 20 working days (MiCA Article 63(12)) | Up to 20 working days (MiCA Article 63(12)) |
| Domestic authorisations granted | Four Article 63 authorisations, plus two entities providing services under Article 60(4): six entries in the ESMA register | 29 in the ESMA register, all under Article 63. Third largest in the EEA. |
What is identical, because MiCA harmonises it
The service list, the Annex IV capital classes, the Article 67 fixed-overheads test, the application contents, the establishment conditions, the governance requirements, the refusal grounds and the passporting mechanism are the same in both. The full list, stated once.
A short deadline is a filter, and it worked in one direction
Latvia, Hungary, Poland, Slovenia, Finland and the Netherlands all took six months. Poland ended with no authority to apply to at all. Latvia has ten authorisations. The Netherlands has 29.
The difference is what the firms were doing before. Dutch crypto businesses had been registered with the central bank under anti-money-laundering law since 2020, a regime widely described as onerous at the time. Whatever else that cost the sector, it meant that when six months was all anyone got, the firms that remained had the documentation and the supervisory relationship to move quickly. Lithuania's twelve months were spent by a smaller population starting from an AML registration of a much lighter kind.
What the Dutch register is made of
Infrastructure, mostly. On-ramps, payments rails, prime brokerage and venues rather than advisory businesses:
- MoonPay Europe B.V.
- One Trading Exchange B.V.
- Hidden Road Partners CIV NL B.V.
- Zebedee Europe B.V.
- Vivid Money B.V.
- Acheron Europe B.V.
Counted from the register, 72% hold a custody permission and 72% may provide transfer services, but only 34% may execute orders and just 3% may advise on crypto-assets, the lowest advisory share of any jurisdiction compared on this site and a quarter of the European average of 13%. Portfolio management sits at 14%.
Against that, three of the 29 hold a trading-platform permission. That is 10%, against a European average of 6%, and in absolute terms it matches Malta from a register a third smaller. Lithuania, France, Estonia and Poland have none between them.
Where Lithuania is closer than the totals suggest
Both registers are custody-first and neither is advisory: every Lithuanian CASP holds a custody permission against 72% of Dutch ones, and neither has a single advisory or portfolio permission worth speaking of. On shape, if not on scale, these two are the most alike of any pair on this site. The gap is 29 against six, and three venues against none.
Who Lithuania suits better
- Custody and transfer models that do not need venue precedent, where the profile matches and the cost base does not.
- Applicants who would find a 29-firm caseload under a well-resourced authority more crowded than useful.
- Firms already connected to Lithuania through payments or e-money supervision.
Who the Netherlands suits better
- Trading venues. Three Dutch CASPs run one and the AFM has assessed each, which is precedent no Baltic authority can offer.
- Payment and on-ramp infrastructure, which is what most of the Dutch register does and what its supervisor is therefore used to reading.
- Firms that were already registered with the Dutch central bank, whose documentation and supervisory history are in the right country.
What this comparison cannot tell you
The AFM page explains who it supervises and under which articles. It does not publish a fee, so none is stated here. The observable difference is not price but population: the Netherlands has venues and infrastructure, Lithuania has custody, and the transitional periods that produced those registers were twelve months and six.
What this page could not verify
- AFM: full text, read 15 September 2026. It sets out supervisory scope under Articles 60 and 63 and states no fee, so Dutch fees are absent rather than estimated.
- ESMA register: full text, file last updated 31 August 2026. Every share quoted here is counted from it.
- The account of why 29 firms converted in six months is an inference from the prior Dutch registration regime, not a statement by the AFM.
Primary sources
- Read 2026-09-11 Bank of Lithuania: transitional period ends 31 December 2025
- Read 2026-09-11 Bank of Lithuania: fourth CASP authorisation granted
- Read 2026-09-15 · full text ESMA: interim MiCA register of crypto-asset service providers (CASPS.csv, last updated 31 August 2026)
- Read 2026-09-15 · full text ESMA: list of grandfathering periods decided by Member States under Article 143(3)
- Read 2026-09-15 · full text AFM: crypto companies, supervision of CASPs
Questions
How long was the Dutch transitional period?
Six months from 30 December 2024, the shortest tier MiCA allows, shared with Latvia, Hungary, Poland, Slovenia and Finland. Lithuania took twelve and France, Malta, Cyprus and Estonia took eighteen. Dutch firms had half the time of most of Europe to convert.
How many CASPs are authorised in the Netherlands?
The ESMA register listed 29 entries with the Netherlands Authority for the Financial Markets as competent authority when it was read on 15 September 2026, all under Article 63. That is the third largest population in the European Economic Area, achieved on the shortest transitional period of any large jurisdiction.
Who supervises crypto firms in the Netherlands?
The AFM. It states that it handles both licence applications from crypto-asset service providers under Article 63 of MiCA and notifications from other financial institutions under Article 60. Before MiCA, Dutch crypto firms were registered with the central bank under anti-money-laundering law rather than licensed.
Is the Netherlands a good place for a crypto trading venue?
It has the highest concentration of them among the jurisdictions compared here. Three of 29 Dutch CASPs hold a trading-platform permission, which is 10% against a European average of 6%. In absolute terms that ties with Malta, from a smaller register. Lithuania has none.
Regulatory references on this page were read against the primary text on 15 September 2026. Every figure is held in the source register with the document it came from.