Marc Verdonk
Partner Blockchain & Digital Assets and CTO

Marc has been with Deloitte since 2002 and has worked with clients across industry and around the world to help them embrace a more digital future with confidence. He is the responsible partner for the Dutch Blockchain & Digital Assets team and the CTO and Innovation leader of Strategy, Risk and Transformation Advisory in Europe.

Marc is an experienced leader that operates on the forefront of technology and innovation in a professional services context. He has the ability to connect business and technology on C-level by making complex things understandable in the fields of data, blockchain, artificial intelligence and quantum risk.

Kim Schneider
Senior Manager Blockchain & Digital Assets

Kim is leading the Enterprise Blockchain and Digital Assets transition in the Netherlands as a Senior Manager. Before joining Deloitte in January 2022, Kim worked for 10 years in the financial industry, gaining extensive experience in relationship management, financing, and digital transformations.

Over the past 10 years, she has specialized as a thought leader in blockchain, working with multiple companies across different industries. Being able to bring technical insights and business together, Kim co-created with clients to generate new business models and use-cases. She has an entrepreneurial mindset and gets energized of bringing people, technology and businesses together.

Phillip de Groot
Senior Consultant Blockchain & Digital Assets

Phillip is a consultant at Deloitte, specializing in blockchain and digital assets with a strong focus on stablecoins and their role in payments and treasury. With a background in supply chain management, Phillip brings a practical, operations-driven perspective to financial innovation, particularly in cross-border payments, cash management, and capital efficiency.

Over the past years, Phillip has worked with international clients to explore how stablecoins can address real-world frictions in the financial system, such as from improving payment speed and transparency to enabling more flexible cash repatriation strategies. Their work focuses on translating complex technological developments into actionable business solutions, helping organizations navigate regulatory, operational, and strategic considerations.

The Netherlands: a balanced jurisdiction for institutional blockchain adoption

Introduction

The Netherlands has emerged as a uniquely balanced jurisdiction in Europe’s rapidly evolving blockchain and digital assets landscape. Unlike jurisdictions that have pursued either aggressive deregulation or cautious restriction, the Netherlands has charted a sensible middle course. A license in the Netherlands carries particular weight in Europe. It demonstrates that a firm has met the standards of a respected regulator while gaining access to EU-wide passporting rights, which provides stakeholders with confidence in the firm’s regulatory compliance.

The serious reputation of the Dutch Financial Authority (AFM) and the Dutch Central Bank (DNB) and by adopting the MiCAR regulation without significant gold-plating, the Netherlands has attracted mature institutions. The result is a jurisdiction increasingly recognized as a gateway for crypto natives and traditional finance institutions seeking to adopt blockchain technology, particularly through stablecoins and tokenization.

The Markets in Crypto-Assets Regulation (MiCAR), which came into force across the EU in June 2023,¹https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica provided a baseline framework for all member states. However, the implementation in the Netherlands, including its approach to licensing timelines, regulatory pragmatism, has positioned it as a leading destination for institutional blockchain adoption. An example of this is the stablecoin issuer Qivalis, founded by a consortium of banks, that has been established in Amsterdam, the Netherlands. This article explores the regulatory landscape, market developments, and institutional positioning that make the Netherlands an attractive jurisdiction for banks, asset managers, and infrastructure providers navigating the convergence of traditional finance and blockchain technology.

Regulatory framework: clarity with rationality

MiCAR introduced the first comprehensive EU-wide framework for crypto assets, electronic money tokens (EMTs), and asset-referenced tokens (ARTs), as well as the provision of ten core services around crypto assets, including custody, exchange, and settlement services. The AFM and DNB have positioned themselves as authorities that are both rigorous and responsive, creating an environment where firms can navigate compliance with confidence.²https://www.o2k.tech/blog/update-mica-benelux In first principle the AFM supervises the service offerings, whilst DNB supervises the issuance of these assets.

This positioning is reflected in the ESMA register of Crypto Asset Service Providers (CASPs).³https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica#InterimMiCARegister As of May 2026, the Netherlands ranks second in the EU with 25 licensed CASPs, behind only Germany with 53 licenses. The Netherlands has attracted a substantial portion of Europe’s regulated crypto infrastructure despite having a smaller population and financial sector than Germany, suggesting that regulatory approach and execution capability matter as much as market size.

The Netherlands chose a 6-month grandfathering period for existing crypto service providers, shorter than Germany’s 12 months or France’s 18 months. The 6-month timeline (ending June 30, 2025) forced firms operating under legacy national frameworks to achieve full MiCAR compliance and secure a new license within this timeline. This created what regulators call a “cliff edge” risk: firms that did not complete their applications in time faced the prospect of ceasing operations.

However, this tighter timeline produced an unexpected benefit. By forcing firms to license early, the AFM essentially accelerated the acquisition of EU-wide passporting rights. A Dutch-licensed CASP can operate across all EU member states with a single license, a capability that firms in jurisdictions with longer grandfathering periods did not yet possess. Dutch licensed firms gained competitive advantage as they were allowed and started offering their services in other EU member states earlier than other EU CASPs.

Recognizing the tightness of the timeline, the AFM and DNB implemented pragmatic measures to support compliance. The AFM offered informal feedback on applications before the official assessment clock starts, allowing firms to identify and fix structural issues early. From July 2024, the DNB began assessing draft applications, giving firms a “running start” while final ESMA interpretations were still being finalized. The DNB has signaled a cooperative approach to compliance, preferring to work with firms actively engaged in the licensing process rather than imposing immediate punitive measures for minor administrative delays. This combination of a tight timeline and support created a distinctive regulatory environment: firms faced clear deadlines and high expectations, but had access to regulators willing to help them navigate the path to compliance.

Market developments: from pilots to live operations

The regulatory environment outlined above creates the conditions for institutional blockchain adoption. While the full potential of blockchain technology lies in the convergence of three critical elements; identity (embedded compliance), ownership (tokenized assets), and payments (programmable money), the current institutional adoption takes mostly place at the payments layer. Stablecoins represent this entry point.

They provide the rails for instant, transparent settlement that traditional finance struggles to deliver. Stablecoins thus represent a critical application of blockchain technology for institutional adoption. Under MiCAR, stablecoins are classified as Electronic Money Tokens (EMTs) if they are denominated in a single fiat currency, issued by a licensed entity, and backed 1:1 by reserves. This classification provides legal certainty: EMTs are treated as regulated financial instruments with clear reserve and collateral requirements, redemption rights, and ongoing supervision.

On the crypto native side there is Quantoz. This Dutch fintech, became the first stablecoin issuer⁴https://www.quantoz.com/about ⁵https://www.quantoz.com/blog/interview-non-us-stablecoin-issuers-gaining-appeal-amid-trade-wars-says-quantoz-payments-ceo-arnoud-star-busmann licensed by the DNB as an Electronic Money Institution (EMI), which is necessary in order to issue an EMT. Its EURD token is designed as a programmable “digital euro” for instant, zero-fee machine-to-machine and B2B payments. Quantoz has since launched EURQ and USDQ, both MiCAR-compliant euro and US dollar stablecoins on the Ethereum, Algorand and Polygon blockchains. In doing so they provide infrastructure for institutional-grade liquidity and cross-border settlement.

On the other hand, Qivalis, founded by a consortium of 12 banks, headquartered in Amsterdam, represents a banking-led approach to stablecoin development. The consortium aims to launch a MiCAR-compliant euro stablecoin (QvEUR) by the second half of 2026,⁶https://www.bbva.com/en/innovation/bbva-joins-banking-consortium-to-issue-european-stablecoin/ bringing together traditional banking institutions to create a bank-backed alternative for on-chain settlement. This contrasts with Quantoz’s crypto-native fintech model. Beyond traditional stablecoins, financial institutions in Netherlands are also exploring “deposit tokens”. These are euro-denominated tokens used to settle fractional ownership of real-world assets. As part of the first cohort of the European Blockchain Sandbox (EBS), ABN AMRO and Rabobank are collaborating in a consortium led by 2Tokens to develop deposit tokens that facilitate on-chain settlement for tokenized renewable energy assets managed by Assetblocks.⁷ledgerinsights.com/ebl-electronic-bills-of-lading-fit-alliance/ ⁸https://www.2tokens.org/blog/dlt-sandbox

Infrastructure and service providers

The maturity of the Dutch blockchain infrastructure ecosystem can be seen in the diversity and sophistication of service providers that now operate in the jurisdiction.

Exchanges and Trading Venues

Bitvavo, the largest Dutch exchange with over 2 million users,⁹https://bitvavo.com/en recently secured a MiCA license from the AFM, enabling it to passport its services across the EU. Finst, an Amsterdam-based exchange focused on low fees and transparency, obtained a full MiCA license in mid-2025. D2X provides institutional-only trading in crypto futures and options with collateral-efficient mechanisms. NPEX, a licensed Dutch security exchange, is partnering with Dusk Network to launch DuskTrade, a blockchain-powered venue for over €300 million in tokenized securities.¹⁰https://www.binance.com/en/square/post/35796800277842

Institutional Custodians

Amdax, the first crypto service provider registered with the DNB (2020)¹¹https://www.amdax.com/nl/nieuws/amdax-ontvangt-dnb-registratie, holds a MiCA license and provides institutional-grade custody, staking, and wealth management. Bitonic, one of the oldest Bitcoin-only brokers in the Netherlands (established 2012), focuses on high-security Bitcoin custody. ZeroHash, a B2B infrastructure provider, enables major fintechs and payment processors (including Stripe and Mastercard) to offer regulated crypto services from its Dutch hub.

Blockchain Protocol Developers

Amsterdam has become a global hub for blockchain infrastructure development. ZkSync (Matter Labs), headquartered in Amsterdam, is scaling Ethereum via the Elastic Chain, a modular network of interconnected zero-knowledge rollups designed for high-speed, low-cost institutional use. Dusk Network, also based in Amsterdam, develops privacy-preserving blockchain infrastructure specifically for regulated tokenization and financial applications, featuring built-in compliance hooks for regulators.

This ecosystem, spanning exchanges, custodians, and protocol developers, provides the “plumbing” necessary for institutional blockchain adoption. The presence of both regulated financial infrastructure and cutting-edge technical development creates a unique advantage: institutions can access both compliance-ready services and technological innovation from a single jurisdiction.

Tokenization and institutional adoption

Tokenization, the process of representing financial assets as digital tokens on a blockchain, has moved from pilot phase to live operations in the Netherlands. This transition reflects both technological maturity and institutional participation in blockchain-based settlement.

ABN AMRO is using public blockchains for regulated securities issuance. In September 2023, the bank issued a €5 million green bond on the Polygon network for real estate firm Vesteda,¹²https://www.abnamro.com/en/news/abn-amro-registers-first-digital-green-bond-on-the-public-blockchain using the ERC-3643 standard to embed compliance rules directly into the tokens. The bank has also issued digital bonds on the Stellar network for SMEs (such as APOC Aviation, raising €450,000¹³https://www.ledgerinsights.com/abn-amro-tokenized-bond-blockchain/) and, in late 2024, issued its inaugural tokenized commercial paper on a private blockchain operated by Clearstream, with Rabobank participating as an investor¹⁴https://www.clearstream.com/clearstream-en/newsroom/241023-4151802. In early 2025, ABN AMRO completed a proof-of-concept for on-chain trading of tokenized securities against stablecoins¹⁵https://21x.eu/abn-amro-conducts-successful-on-chain-trade-of-tokenized-assets-against-stablecoins-in-preparation-for-the-launch-of-21x/, demonstrating the technical feasibility of stablecoin-settled markets.

Rabobank has focused on improving efficiency and settlement speed in institutional markets. The bank has executed multiple real-time commercial paper transactions using the Corda blockchain, ¹⁶https://financialit.net/news/blockchain/rabobank-successfully-completes-preproduction-trial-runs-commercial-paper-issuance reducing settlement times from the traditional two-day lag to under 30 minutes. As part of the European Blockchain Sandbox, Rabobank is exploring deposit tokens to enable fractional ownership of renewable energy assets, addressing both the tokenization opportunity and the broader energy transition agenda¹⁷https://blockchain-observatory.ec.europa.eu/european-blockchain-sandbox-announces-selected-projects-first-cohort_en?prefLang=nl.

ING has taken a different approach, focusing on the technical infrastructure that underpins tokenization. The bank’s research team is globally recognized for developing zero-knowledge proof solutions that allow institutions to verify data without exposing sensitive transaction details¹⁸https://www.boomish.org/blogs/what-are-zero-knowledge-proofs ¹⁹https://www.fintechfutures.com/blockchain-crypto-digital-assets/ing-releases-zero-knowledge-set-membership-blockchain-solution. Beyond these technical contributions, ING is also a founding member of Qivalis, the bank consortium developing a MiCAR-compliant euro stablecoin²⁰https://ing.com/news/2026/money-doesnt-work-nine-to-five-anymore.html.

These projects demonstrate that tokenization in the Netherlands is live. The involvement of major Dutch banks, ABN AMRO, Rabobank, and ING, signals institutional commitment to blockchain-based settlement and tokenization. While these three banks represent significant players in the Dutch financial system, they are not the only institutions exploring tokenization. The broader ecosystem includes smaller banks, fintech firms, and specialized service providers also developing blockchain capabilities. Institutions are executing live transactions, managing real assets, and building the infrastructure for a multi-rail settlement environment.

Opportunities and challenges

The Netherlands’ position as a balanced jurisdiction creates opportunities, though not without challenges to navigate through.

The implementation of MiCAR, combined with the early licensing timeline, has positioned Dutch firms to achieve EU-wide passporting sooner than competitors in other jurisdictions. This creates a window of competitive advantage for service providers and institutions in the Netherlands²¹https://www.onetrading.com/blog/micar-across-the-eu-why-early-adoption-is-a-competitive-edge. The presence of major banks, custodians, and protocol developers creates a complete ecosystem for institutional blockchain adoption. Firms looking to build blockchain capabilities can access both regulatory expertise and technical knowhow from a single jurisdiction, a rare combination in Europe.

The Netherlands is emerging as a hub for stablecoin development, from Quantoz’s regulated EMTs to Qivalis’ bank-backed euro stablecoin. However, there is also real challenges. While MiCAR provides a baseline, regulatory interpretation continues to evolve. ESMA guidance, national authority decisions, and potential future amendments can create ongoing uncertainty. Firms must remain agile in how they approach compliance. Germany’s larger financial sector and 53 licensed CASPs represent significant competition, and Luxembourg, Malta, and other jurisdictions are also positioning themselves as blockchain hubs.

Outlook and conclu­sion: the path forward (2026–2028)

The path forward

As stablecoins mature and tokenization becomes more adopted, Dutch banks are likely to deepen their involvement in three areas: (1) stablecoin issuance and distribution, (2) tokenized asset custody and settlement, and (3) programmable money infrastructure for corporate treasury and intercompany flows. The regulatory clarity provided by MiCAR and the enforcement of the ruleset by the AFM and DNB create conditions for this evolution. The regulatory landscape will continue to evolve through 2026 and beyond. ESMA is expected to issue further guidance on stablecoin reserve requirements and DeFi regulation.

The period 2026–2028 is likely to see accelerated institutional adoption of blockchain technology in the Netherlands. Qivalis’ launch of QvEUR and the broader adoption of MiCAR-compliant stablecoins will create new settlement rails for institutional transactions. Live tokenization projects will move from pilots to production, with increasing volumes of bonds and commercial paper settling on blockchain networks. Banks and treasurers will use stablecoins and tokenized assets to automate settlement and optimize liquidity management.

Underlying these developments is a fundamental shift in how institutions think about money and settlement. The concept of “cash on chain”, stablecoins and tokenized money operating natively on blockchain networks, is becoming central to institutional blockchain adoption. This shift requires the convergence of three critical elements: issuers (creating the stablecoins and tokenized assets), service providers and banks (providing the infrastructure and custody), and treasurers and institutional users (creating demand for faster, more transparent settlement).

The Netherlands is well-positioned to facilitate this convergence. With parties providing issuance, major banks and CASPs offering infrastructure, and growing institutional interest from corporate treasurers, the conditions for “cash on chain” adoption are aligning. Once this foundational layer is established, the tokenization of broader financial instruments, such as bonds, commercial paper, and eventually most financial assets, becomes operationally feasible.

Conclusion

The Netherlands has established itself as a balanced jurisdiction for institutional blockchain adoption. The 6-month grandfathering period, initially perceived as a constraint, became a strategic advantage, accelerating EU-wide passporting rights. The AFM and DNB’s approach, has created an environment where serious institutional players can navigate compliance with confidence.

Market developments demonstrate that institutional adoption is here. The banking consortium behind Qivalis show institutions actively building blockchain capabilities. The infrastructure ecosystem, regulated exchanges, institutional custodians, and protocol developers, provides the foundation for blockchain to become operationally embedded in institutional finance. As blockchain becomes increasingly central to payments and settlement, the Netherlands’ might be positioned as a leading destination for institutional blockchain adoption in Europe. The next phase will be defined by the ability of institutions to integrate blockchain into existing operations and build the infrastructure for “cash on chain.” The Netherlands is uniquely positioned to lead in this transition.