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MiCAR governs NL stablecoins; DNB supervises EMT/ART issuers, AFM is CASP authority. NL chose a shortened transitional window ending 1 Jul 2025 (~12 months enforced as of mid-2026). Quantoz Payments authorised (EURQ/USDQ); bank-consortium euro stablecoin announced for 2026.
The defining structural fact is timing. The Netherlands chose a shortened MiCA transitional window ending 1 July 2025 — among the shortest in the EU, where most member states run to 1 July 2026 — after which CASPs and EMT issuers must be MiCA-authorised or passported. As of June 2026 NL has been enforcing MiCA compliance for nearly twelve months, making it a first-mover enforcement jurisdiction where unauthorised CASPs have faced a hard cut-off a full year ahead of the EU-wide deadline.
Authorised euro-EMT issuance is concentrating in the Dutch market. Quantoz Payments BV, a DNB-supervised EMI, holds MiCA EMT authorisation and issues EURQ (euro) and USDQ (US dollar), on Ethereum with multi-chain expansion. Coverage here is flagged as incomplete: Quantoz also reportedly issues a third euro EMT, EURD, per issuer sources, which is not captured in this cycle. Beyond Quantoz, nine major European banks including ING have announced plans to launch a MiCA-compliant euro-denominated stablecoin supervised by DNB, expected in 2026.
Outlook
W2 is escalating and confirmed. The forward watch items are the nine-bank consortium euro stablecoin launch in 2026 and continued enforcement post-cut-off. Two gaps qualify confidence: no post-July-2025 source citing actual DNB/AFM enforcement actions after the deadline, and the omitted EURD product. Stablecoin proliferation also carries FIM sanctions-evasion considerations that are out of WPM scope.
Stablecoins & Digital Money
The defining development for Dutch digital-money infrastructure this period is the joint AFM/DNB exploratory report, published 12 October 2026, finding that the current legal framework in the Netherlands does not yet provide a basis for securities issued, held and transferred exclusively as tokens. The regulators located the gap specifically in Dutch civil and securities law, the Burgerlijk Wetboek and the Wet giraal effectenverkeer, which together have no provision recognising a token itself as the sole legal basis of title and transfer for a security. This is a market-infrastructure and property-law finding rather than a MiCA-licensing restriction: it concerns whether Dutch private law can give full legal effect to a security that exists only as a token, not whether a crypto-asset service provider is authorised to deal in such instruments.
AFM and DNB warned explicitly of migration risk, the prospect that issuance and market-infrastructure activity could move to jurisdictions offering clearer legal bases for native tokenisation, and recommended a joint follow-up process involving government and market participants to address the gap. In the interim, market participants seeking to tokenise securities in the Netherlands must continue to rely on hybrid dual-registration arrangements, layering a token representation over a conventional legal title, which introduces reconciliation complexity that a single-layer legal basis would avoid. The joint nature of the AFM/DNB publication, a conduct regulator and a prudential regulator acting together, signals that this is being treated as a capital-markets infrastructure policy question affecting the broader digital-money and tokenised-asset landscape, not a narrow crypto-sector supervisory matter.
No other stablecoin or digital-money development specific to the Netherlands was identified this period.
Outlook
The AFM/DNB recommendation for a joint follow-up process has no confirmed timetable. Whether the Dutch government pursues a legislative amendment to the Burgerlijk Wetboek and Wet giraal effectenverkeer to give token-based securities a clear legal basis, or market participants continue relying on dual-registration structures indefinitely, is the central open question for digital-money market infrastructure in the Netherlands going forward.
Sources and findings (4)
- T1https://www.dnb.nl/en/sector-information/open-book-supervision/laws-and-eu-regulations/micar/retrieved
- T3https://eco.com/support/en/articles/14796308-mica-compliant-stablecoins-listretrieved
- T3https://www.plasma.to/learn/tools/stablecoin-regulation-map/netherlandsretrieved
- T3https://eco.com/support/en/articles/14796305-mica-explained-eu-s-crypto-regulationretrieved