Licence application for CASPs

Factsheet
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A Crypto Asset Service Provider (CASP) may also require an additional licence as a payment service provider  (PSD2) if it intends to provide certain payment services related to electronic money tokens (EMTs) as of 1 March 2026. In June 2025, the European Banking Authority (EBA) published its Opinion on the interplay between Directive (EU) 2015/2366 (PSD2) and Regulation (EU) 2023/1114 (MiCA) in relation to crypto-asset service providers that transact electronic money tokens, clarifying which activities fall within the scope of PSD2. 

Published: 20 November 2025

A transitional period applies until 1 March 2026, during which national supervisors will apply enforcement measures with restraint. After this period, a PSD2 licence will in principle be required, unless 1) the relevant activities are exempt under the Dutch Financial Supervision Act (Wet op het financieel toezicht, Wft) or 2) the CASP has entered into a partnership with a PSP.

A PSD2 licence or a partnership with a PSP is in any case required if a CASP:

  • provides crypto-asset transfer services involving EMTs, where the transfer is offered and executed on behalf of clients; 
  • provides custody and administration services involving EMTs, where the service and the custodial wallet, held in the name of one or more clients, enable the sending and receiving of EMTs to and from third parties making the service a payment service and the custodial wallet a payment account under PSD2.

The following activities are explicitly not within the scope of PSD2:

  • the exchange of crypto-assets for funds (including EMTs);
  • the exchange of crypto-assets for other crypto-assets;
  • the intermediation in the purchase of crypto-assets using EMTs.

We recommend that you assess in a timely manner whether your activities qualify as payment services subject to licensing, bearing in mind that licensing processes are typically lengthy. If this is the case, we advise you to contact markttoegang@dnb.nl for more information about the specific PSD2 licensing procedure for CASPs and inquire about the possibility of reusing information already submitted as part of the MiCAR application, which could reduce or eliminate the need to resubmit the same data.

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