Coming Q3 2026

MTF Licensing Starter Kit

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.

€3,500
Excl. VAT · Expected Q3 2026

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  • AFM application document templates
  • Organisational chart & governance templates
  • Compliance manual skeleton
  • Regulatory gap assessment checklist
  • Project timeline template
  • Rulebook structure and outline
  • 30 minutes onboarding call included

Why this kit exists

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.

What's included

AFM Application Document Templates

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 & Governance Framework

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.

Compliance Manual Skeleton

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.

Regulatory Gap Assessment Checklist

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.

Project Timeline & Milestone Template

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.

Rulebook Structure & Outline

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.

Who this is for

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.

Frequently asked questions

Does this replace legal counsel for the AFM application?

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.

Is this relevant for OTF licensing as well?

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).

Can I combine this with advisory support?

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.

What's the typical timeline for an MTF licence application?

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.

Planning an MTF launch?

Whether you're exploring the concept or already in dialogue with AFM — let's talk about how we can accelerate your licensing process.

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