Improvement Points for Information Provision by CASPs

SUPERVISION REPORT Improvement Points for Information Provision by CASPs In brief – The AFM observes that crypto-asset service providers (CASPs) are taking steps to improve their advertising statements and cost information, but shortcomings remain. In particular, the balanced identification of risks, the prevention of misleading information, and the clear presentation of costs are still lacking. Based on the research, the AFM is taking appropriate measures towards the involved CASPs. To help the market move forward, the supervisor presents five concrete improvement points, supplemented with good and bad practice examples. All CASPs active in the Netherlands are urged to improve their information provision. The AFM will monitor this on a risk-based basis and may take enforcement action if necessary. APRIL | 2026

© AFM 2026 | Improvement Points for Information Provision by CASPs 2 Executive Summary The crypto market is growing rapidly and attracting a broad and diverse group of consumers. Since the end of 2024, clear requirements under the Markets in Crypto-Assets Regulation (MiCAR) have applied to advertising statements and information provision by crypto-asset service providers (CASPs). Correct, clear, and non-misleading information is essential to enable consumers to make well-informed choices. In 2025, the AFM published an initial study on CASP advertising and cost information. Since then, parts of the sector have taken steps, but follow-up research shows that several CASPs still need to make substantial improvements. The AFM considers it important to provide general insight into the findings and points of attention from this research. This report presents the results. Objective of the Research The AFM takes information provision in advertising statements and transparency regarding costs extremely seriously. This research contributes to a level playing field within the EU and protects consumers from misleading, incomplete, or hard-to-find information and unnecessary risks. Where improvement is possible, the AFM shares concrete examples to further support the sector. The AFM takes this into account when assessing CASP license applications and applies risk-based supervision, both in ongoing supervision and thematic research. What did the AFM do? In the research, the AFM assessed whether CASP advertising statements and cost information comply with Article 66 of MiCAR. In doing so, the AFM looks, among other things, at the quality of the information provision. For correct, clear, and non-misleading information provision, the AFM expects that the information is at least factually correct, accessible, understandable, and balanced for the target audience. The AFM also assesses whether the information misleads the client. Furthermore, the AFM looks at the accessibility and completeness of cost information. Where relevant, the AFM incorporates previously published guidance and additional Level 3 guidance (guidelines, Q&As, statements, etc.) into its assessment. The Level 1 provisions of MiCAR resemble those in the Markets in Financial Instruments Directive (MiFID II), but do not contain all the detailed Level 2 rules applicable under MiFID II. Although these are separate legal frameworks, the AFM will, where relevant and appropriate, also look at the similarities. Key Findings The AFM observes that CASPs are using the previously provided guidance on advertising and information provision, but shortcomings remain. The AFM notes, among other things:

1. Misleading or unclear advertising statements, for example terms like 'safe trading' without clarification, or advertising 'commission-free' or 'free' trading in crypto-assets without clearly stating possible additional costs and/or restrictions.
2. Insufficient balanced risk identification, while volatility and complex products actually call for clear warnings.
3. Cost information that is not or is difficult to find, for example hidden in general terms and conditions or only accessible via external search engines.
4. No clear and complete presentation of costs, including the absence of standard cost items such as deposit and withdrawal fees and ongoing costs, and the failure to specify the specific rates.
5. Risk of confusion regarding services inside and outside supervision, for example when staking or lending is offered alongside regulated services.

© AFM 2026 | Improvement Points for Information Provision by CASPs 3 The research focused on crypto advertising published between August and October 2025 and publicly accessible cost information from 33 CASPs that obtained a MiCAR license in 2024 or 2025. This selection includes both CASPs licensed in the Netherlands and CASPs licensed in other EU member states. The AFM notes that both Dutch and international CASPs still need to take significant steps to meet MiCAR standards for information provision. The AFM identified shortcomings regarding advertising standards for fourteen parties. Regarding cost information, shortcomings were identified for nineteen parties. The involved Dutch CASPs will soon receive a supervisory letter, and for international CASPs, the relevant national supervisors will be informed. For completeness, the AFM notes that not all CASPs had advertising statements in the period under review. Several CASPs were cautious with marketing activities due to the necessary mitigating measures after the transition period expired on 30 June 2025. What will the AFM do? The AFM acts proactively, risk-based, and where necessary, enforcement-oriented. The involved parties will receive individual feedback and must remedy shortcomings. The AFM: • continues to strictly monitor compliance with MiCAR; • enforces when violations persist; • informs ESMA and national supervisors about the findings; • continues thematic supervision and continues to publish good practices; • tackles persons offering crypto-asset services without a license and prevents market abuse. Guidance for Improvement The AFM expects all CASPs active in the Netherlands to immediately align their information provision with MiCAR. To support the sector in this, the AFM identifies five concrete improvement points, supplemented with good and bad practices:

1. Avoid misleading statements and ensure information is clearly substantiated
2. Identify risks in a balanced manner
3. Ensure cost information is easily accessible
4. Be clear and transparent about costs towards consumers
5. Pay attention to clear information provision regarding services inside and outside supervision With these improvement points, the AFM provides insight into how it handles open norms in its supervision. The AFM expects CASPs to use this document as a reference framework for their information provision. In practice, the AFM always conducts a case-specific assessment. Whether information is correct, clear, and non-misleading depends on the context (both substantive and presentational) and can vary per case.

© AFM 2026 | Improvement Points for Information Provision by CASPs 4 Table of Contents Introduction 5 Key Improvement Points for CASPs 6

1. Avoid misleading statements and ensure information is clearly substantiated 7
2. Identify risks in a balanced manner 8
3. Ensure cost information is easily accessible 10
4. Be clear and transparent about costs towards consumers 11
5. Pay attention to clear information provision regarding services inside and outside supervision 13 Conclusion 15

© AFM 2026 | Improvement Points for Information Provision by CASPs 5 Introduction More and more consumers and companies are using crypto-asset services, but growth generally outpaces understanding of the associated risks. Products are often complex, providers operate internationally, and information for users is not always complete or understandable. This makes it difficult to see who is responsible for what and what protection applies. With the introduction of European rules for CASPs, more clarity is emerging. The rules in MiCAR form an important step, but do not solve everything. The quality of service varies greatly between providers, as does the way risks are managed and information is shared. This makes the market vulnerable to misleading practices, just as consumer participation continues to increase. This report maps the key risks for CASPs regarding information provision and what is needed to make the market safer and more transparent. The following chapters contain guidance for improvement and provide insight into the AFM's deployment in the coming period.

© AFM 2026 | Improvement Points for Information Provision by CASPs 6 Key Improvement Points for CASPs The popularity of trading in crypto and the significant risks involved mean the AFM critically examines proper compliance with information provision requirements. Under European rules in MiCAR, CASPs must ensure their information is correct, clear, and non-misleading. This applies to all forms of communication, such as advertising and website information. They must also properly warn customers about the risks associated with trading in crypto. Furthermore, MiCAR requires that information on fees and costs receives a prominent place on the website. Clear information about risks and costs helps consumers better understand what they are doing and what consequences it may have, enabling them to make well-considered choices. Follow-up research by the AFM shows that improvements are still needed at several CASPs. Therefore, the AFM identifies five points where CASPs can sharpen their information provision, supported by good and bad practices¹. The five key improvement points are:

1. Avoid misleading statements and ensure information is clearly substantiated
2. Identify risks in a balanced manner
3. Ensure cost information is easily accessible
4. Be clear and transparent about costs towards consumers
5. Pay attention to clear information provision regarding services inside and outside supervision ¹ The examples are inspired by statements from the research and have been aggregated and anonymized. In practice, the AFM always conducts a case-specific assessment.

© AFM 2026 | Improvement Points for Information Provision by CASPs 7

1. Avoid misleading statements and ensure information is clearly substantiated Advertising statements and information provision on the website usually give a consumer a first impression of the CASP and its services. It is therefore essential that statements made by CASPs are correct, clear, and non-misleading, so that clients are not misled regarding the real or perceived benefits of crypto-assets. Misleading statements or unsubstantiated information can mislead a client. Additional AFM clarification regarding this expectation • Clients can be misled when risks are downplayed in advertising statements or when information is unbalanced. This is the case if an advertising statement refers to 'safe trading' or 'saving in crypto' without further explanation or context regarding what is meant. This makes an advertising statement unbalanced and therefore not clear and/or misleading. Given the volatility of crypto-assets, the AFM expects risks to be clearly identified and not downplayed. Terms such as 'safe', 'highly trusted', or 'saving' in combination with crypto can therefore quickly be seen as not clear and/or misleading. The use of the term 'saving' requires extra care, as this term in the Netherlands is strongly associated with bank deposits covered by the deposit guarantee scheme. It is important to avoid suggesting a comparable level of protection. • The AFM also encountered some advertising statements where costs were presented in an unclear and/or misleading manner. The standard in Article 66(2) of MiCAR implies that information, including in advertising statements, must be correct, clear, and non-misleading. Information is unclear and/or misleading if terms such as 'commission-free', 'free', or 'no costs apply' are used without clearly stating possible other additional costs and/or restrictions. When using such terms, it must be made clear whether and how other costs, including implicit costs such as spreads or risk margins built into the price, may still apply. Any restrictions on such promotions must also be stated. When temporary promotions are mentioned, a clear explanation of the conditions such as limited durations or required trading volumes is expected, so that the client understands under which circumstances costs may still arise. In addition, the AFM considers it important that promotions are based on a realistic perspective, so that clients are not misled into certain actions when it is unfeasible or hardly feasible for them to take advantage of the promotion (e.g., unrealistically high trading volumes or rewards that must be achieved). • Various statements highlight high or exceptional returns. In line with Article 66(2) of MiCAR, the AFM expects such mentions to be correct, clear, and non-misleading. This means, for example, that the chosen period must be representative and that selective time periods should not be used that present a more favorable picture. • In cases where certain comparisons are made between different CASPs and the services they offer, the AFM expects such a comparison to be presented correctly, clearly, and non-misleadingly. This means, for example, that it is made clear on what the comparison is based and that not only elements are presented that benefit the CASP preparing the comparison, which could mislead the consumer. It is also important to make clear why certain CASPs were selected for the comparison and others were not, and why these CASPs form a balanced and representative comparison group. Finally, the presented information from the comparison must always be correct, i.e., current and accurate, not outdated or missing elements.

© AFM 2026 | Improvement Points for Information Provision by CASPs 8 2. Identify risks in a balanced manner When not all necessary information is presented, a client may get an unbalanced view of the CASP or the offered crypto-assets or crypto-asset services. Claims that only highlight the benefits of the CASP, a crypto-asset, or a crypto-asset service can be unclear and/or misleading. The AFM expects CASPs to, in line with Article 66 of MiCAR², identify the risks associated with transactions in crypto-assets in a correct, clear, and non-misleading manner, and not to mislead their clients, intentionally or through negligence, regarding the real or perceived benefits of crypto-assets. The AFM assesses, among other things, that the information is balanced and does not mislead the client. For correct, clear, and non-misleading information provision, the AFM expects that at least warnings are given for these risks when pointing out (possible) benefits of a crypto-asset and/or crypto-asset service. Additional AFM clarification regarding this expectation • The given risk warning must provide a correct, clear, and non-misleading indication of the risks associated with transactions in crypto-assets. The AFM considers a passage such as 'investing/trading in crypto-assets involves/entails risks' too general to clarify the risks associated with crypto-asset transactions. A way to meet the standard³ could be, according to the AFM, to clearly state what the respective risk is, for example, that you can lose your investment. • The requirements in Article 66 of MiCAR apply to all types of information provision, including advertising statements. The AFM notes that many of the identified shortcomings in the research relate to internet banners and Google Ads. If such statements point out (possible) benefits of a crypto-asset and/or crypto-asset service, CASPs must also identify the risks in a correct, clear, and non-misleading manner. These requirements also apply when a specific service or feature is promoted to existing clients (e.g., via in-app or email communication). When promoting additional high-risk crypto-assets or services that are in principle outside the scope of MiCAR (e.g., staking, lending, or Decentralized Finance), the AFM expects CASPs, due to their regulated status, to handle warnings regarding associated risks with extra care. In this context, the AFM expects CASPs to clearly state what falls under supervision and what does not, and to adhere to the requirements set out in the published ESMA statement on this matter (see further clarification under improvement point 5). • For completeness, the AFM emphasizes that it is important that the warning is proportionate to the context of the advertising statement. Whether a warning is correct, clear, and non-misleading depends on the context (both substantive and presentational) and can vary per advertising statement. The AFM expects the warning to be accurate and always provide a correct and clear indication of the respective risks. To communicate risks in a correct, clear, and non-misleading manner, it is important to use a layout that ensures the clarity of the indication of the respective risks in question. It is appropriate to use a font size that is at least equal to the font size predominantly used in the provided information or advertising statement. ² Article 66, paragraphs 2 and 3, MiCAR ³ Article 66, paragraph 2, MiCAR

© AFM 2026 | Improvement Points for Information Provision by CASPs 9 Good practice: Clients are informed in a balanced manner throughout the entire client journey The AFM observed several cases where CASPs warned clients about the risks associated with crypto-asset transactions in all relevant phases of the client journey. In this way, a consumer can make a well-considered decision to purchase a specific product or service. This reduces the risk of misleading practices. Bad practice: Clients are not clearly warned about the risks, for example because the risk warning is too general or inconspicuous In various statements, CASPs gave too general a risk warning, without a clear indication of the respective risk. For balanced information provision, it is important to clarify the respective risk so that clients become aware of the risks they are taking. Furthermore, the AFM observed several cases where an inconspicuous color or a very small font size was used for the risk warning. This increases the chance that clients do not notice the risk warning, which increases the risk of unbalanced information provision.

© AFM 2026 | Improvement Points for Information Provision by CASPs 10 3. Ensure cost information is easily accessible Article 66(4) of MiCAR requires CASPs to make their fee, cost, and compensation policy publicly available in a prominent place on their website. The AFM understands this to mean that such information is easily accessible on the website. It is important that a consumer can easily find their way to the relevant information and that information is not hidden in a place on the website where a consumer would not reasonably expect to look for it. Additional AFM clarification regarding this expectation • The AFM observes in some cases that cost information is not displayed on a single page, but spread across the website. This can result in inaccessible information. For a prominent place, it is important that all relevant information is easily findable. This is less likely when information belonging together is not directly on the same page and is not linked to each other, for example by a clear reference. • The AFM is also of the opinion that knowledge academies, 'frequently asked questions', support centers, and General Terms and Conditions are not prominent places for publicly making a fee, cost, and compensation policy