A BaFin licence carries weight with banks and partners across Europe, which is why e-money issuers that want the EU’s largest market as their home choose Germany.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
Our realistic timeline from submission, set against the regulator’s own published figures.
Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.
Candidates introduced for two managing directors and an MLRO in Germany, each assessed against the regulator’s standard.
A reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.
You will need at least two managing directors, and an MLRO at management level with a deputy, both carrying out the role in Germany.
One engagement and one timetable, from scoping to launch. Speak to an expert about the people, the banking and the technology for this licence.
The regulator’s requirements, capital, timing, fees and the questions firms ask, from the regulator’s own publications.
A business issuing stored value in Germany or, through passporting, across the EU and EEA needs a BaFin licence for the e-money business. Germany is the EU’s largest market, and a German licence carries weight with banks and partners across the region. An EMI may provide every payment service under the same licence.
| Requirement | Amount |
|---|---|
| Initial capital | €350,000 |
| Ongoing own funds (Method D) | At least 2% of average outstanding e-money |
| Unrelated payment services | Method A, B or C |
| BaFin add-on | Up to 20% |
The capital must be available in Germany before the licence is granted.
| Figure | Value | Source |
|---|---|---|
| Statutory decision period | 3 months from a complete application; an application not completed within 12 months is rejected | Payment Services Supervision Act (ZAG), section 11 |
| Application preparation | 6 to 8 weeks | From instruction to submission, including banking in parallel |
| Our realistic timeline | 6 to 8 months after submission | The firm’s own figure, from the regulator’s published data and its own applications |
Figures published by the regulator are quoted as published and converted to months. The realistic timeline is the firm’s own, for a complete, well-prepared application.
| Item | Amount | Notes |
|---|---|---|
| Licence fee | By time spent | Under the federal fee schedule |
| Annual supervision allocation | By cost allocation | BaFin recovers supervision costs from institutions |
| Initial capital | €350,000 | Available in Germany |
| Professional fees | Fixed, in writing | Quoted after scoping |
A German EMI passports throughout the EU and EEA by branch, agent or cross-border services. BaFin forwards complete notifications within one month and decides on registration within three months. There is no small EMI waiver; the only exemptions are the limited-network and telecommunications exemptions.
BaFin publishes no list of causes of delay; the statute lists the grounds for refusal: an incomplete application, capital not available in Germany, unreliable or unqualified managers or shareholders, inadequate controls, a group structure that impairs supervision, a head office outside Germany and unproven safeguarding. Applications are prepared against each ground.
An EMI needs a safeguarding account that satisfies the regulator’s requirements, an operating account and settlement accounts in the currencies it serves. The firm arranges each through institutions that serve regulated firms in Germany and across the EU, during the application, so the firm trades on authorisation. See banking and payment processing.
Three months from a complete application by statute, and an application not completed within twelve months is rejected. The firm plans for six to eight months after submission.
€350,000 available in Germany before the licence, and own funds thereafter of at least 2% of average outstanding e-money.
At least two, each reliable and professionally suitable; one may suffice for a small institution.
No. Germany did not adopt the small EMI option.
The application is made to a German authority and the file is prepared in German; the firm prepares it.
A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm advises on authorisation, compliance, safeguarding, banking and transactions, and builds the white-label payment and card technology its clients launch on.
A written proposal on cost, timing and requirements, the same day: speak to an expert.
This guide is general information for firms considering authorisation and is reviewed against the regulator’s published requirements. It is not legal advice; requirements and fees change, and the regulator’s current publications take precedence.
The requirements, the cost and the timing for your business, in a written proposal the same day.