Everything you need to launch your AFM licence application for a Multilateral Trading Facility. From regulatory gap analysis to application document drafting — built from real MTF licensing experience.
The AFM licensing process for an MTF typically takes 9–18 months and involves extensive documentation across governance, operations, technology, and compliance. This kit gives you the framework so you can focus on substance rather than structure.
Be the first to know when this kit launches.
30-minute onboarding call included. Questions? Get in touch.
Or discuss advisory support for your licensing project.
Obtaining an AFM licence to operate an MTF is one of the most complex regulatory processes in the Dutch financial sector. The application requires detailed documentation on governance, compliance, risk management, technology infrastructure, market surveillance, and participant rules — all to AFM's exacting standards.
Most firms either engage Big 4 consultancies at €200K+ or attempt to navigate the process internally with limited regulatory experience. Both approaches have significant drawbacks: over-spending or under-preparing. This starter kit provides a professional middle path — tested templates and frameworks that ensure you cover every requirement without starting from a blank page.
Pre-structured application documents covering all sections required by AFM. Includes guidance notes explaining what AFM expects to see in each section and common reasons for rejection or additional questions.
Organisational chart templates, board composition requirements, three-lines-of-defence model, key function holder role descriptions, and fit and proper assessment templates. Aligned with AFM and DNB expectations.
A modular compliance manual framework specifically designed for MTF operators. Covers market surveillance, participant oversight, trading halt procedures, fair and orderly trading obligations, and regulatory reporting.
Comprehensive checklist mapping every MiFID II/MiFIR requirement relevant to MTF operators. Identifies your current state, target state, and remediation actions. Directly usable as your project management tool.
Realistic project plan based on actual licensing timelines. Includes AFM review stages, common bottlenecks, parallel workstreams, and critical path analysis. Gantt-chart ready in Excel.
Template structure for your MTF rulebook covering participation criteria, trading rules, market-making obligations, settlement arrangements, and disciplinary procedures. Includes example clauses and AFM best practices.
This kit is designed for firms that are planning to apply for an AFM licence to operate an MTF or OTF, or firms that are in the early stages of their application and need to structure their documentation. It's equally relevant for fintech companies building new trading venues and established financial institutions launching new asset class platforms.
No. You will still need legal counsel for the formal application and AFM dialogue. This kit provides the operational and compliance documentation that sits alongside the legal submission. In practice, having these documents ready significantly reduces your legal spend.
Yes. The framework is largely the same, with specific sections flagged for MTF vs. OTF differences (particularly around discretion in matching and the scope of instruments traded).
Absolutely. We offer end-to-end MTF/OTF licensing advisory as a core service. The starter kit can serve as the foundation, with targeted advisory hours for firm-specific customisation and AFM dialogue preparation.
From concept to licence, the typical timeline is 12–18 months. The pre-application preparation (which this kit accelerates) typically takes 3–6 months. AFM's formal review process then takes an additional 6–12 months. Read our detailed guide on MTF licensing in the Netherlands.
Interactive preview of the licensing toolkit. Each component is provided as an editable Excel workbook with regulatory checklists and project planning templates.
| # | Document / Artifact | Regulatory Basis | Description | Status | Owner | Notes |
|---|---|---|---|---|---|---|
| 1 | Application form (AFM standard) | Wft Art. 2:96 | Completed AFM application form for MTF authorisation | [Select] | [Name] | |
| 2 | Legal entity documentation | Wft Art. 2:96(1) | Articles of association, KvK extract, UBO register | [Select] | [Name] | |
| 3 | Business plan | MiFID II Art. 18(2) | Strategic plan, revenue model, 3-year financial projections | [Select] | [Name] | |
| 4 | Governance framework | MiFID II Art. 18(1) | Organisational chart, board composition, key function holders | [Select] | [Name] | See Sheet 4 |
| 5 | Fit & proper documentation | Wft Art. 4:9-4:10 | CV, diplomas, VOG for each director and key function holder | [Select] | [Name] | |
| 6 | MTF Rule Book | MiFID II Art. 18(1), RTS 26 | Trading rules, membership criteria, dispute resolution | [Select] | [Name] | See Sheet 6 |
| 7 | IT architecture document | MiFID II Art. 18(5) | System design, matching engine specs, capacity planning | [Select] | [Name] | See Sheet 5 |
| 8 | Market surveillance plan | MAR Art. 16(1) | Detection logic, alert handling, STOR reporting process | [Select] | [Name] |
We use strictly necessary cookies to run this site. With your permission we also set statistics cookies (Google Analytics) and marketing cookies (Calendly scheduling). You can change this choice anytime via the footer. See our privacy statement and cookie statement.