AFM Update on Information Disclosure Requirements for CASPs Under MiCAR

Why It Matters

Transparent disclosures protect retail investors and ensure a level playing field as the EU’s crypto market matures. Failure to meet MiCAR standards could invite regulatory penalties and erode consumer trust across the sector.

Key Takeaways

• AFM finds most CASPs lack clear, non‑misleading advertising
• Risk warnings often generic, missing specific volatility disclosures
• Cost details buried in FAQs, not visible within one click
• Unregulated services like staking mixed with regulated offerings
• AFM urges cost calculators and distinct labeling of services

Pulse Analysis

The European Union’s Markets in Crypto‑Assets Regulation (MiCAR) represents the most comprehensive attempt to standardise crypto‑asset services across member states. By imposing uniform disclosure obligations, MiCAR aims to curb the information asymmetry that has historically plagued retail investors in the digital asset space. The Dutch Authority for the Financial Markets (AFM), as a national supervisor, plays a pivotal role in translating these EU‑wide rules into actionable oversight, ensuring that local and cross‑border CASPs adhere to the same transparency standards.

AFM’s April 2026 report paints a sobering picture: many platforms continue to rely on vague marketing language such as “safe trading” while offering only generic risk statements. Cost structures—deposit fees, withdrawal charges, and spread‑related expenses—are frequently hidden in terms and conditions or scattered across multiple pages, making them difficult for consumers to locate. Moreover, the blending of MiCAR‑regulated services with unregulated products like staking or crypto‑lending creates confusion about the level of investor protection, potentially exposing users to hidden liabilities.

To address these gaps, the AFM outlined five actionable recommendations, from prohibiting misleading adjectives to mandating one‑click access to fee breakdowns and encouraging the use of cost calculators. The regulator’s risk‑based supervisory approach means that non‑compliant Dutch CASPs will receive formal remediation letters, while persistent violations could trigger enforcement measures. International providers operating in the Dutch market will also be flagged to their home‑country supervisors. For crypto firms, aligning with these guidelines is not just a compliance exercise—it is a strategic imperative to build trust, avoid penalties, and position themselves competitively in a rapidly consolidating European crypto ecosystem.