Payment institutions that want a home licence in the EU’s largest market, and the standing a BaFin authorisation gives with European banks, choose Germany as their base.
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, or one for a small firm, and an MLRO at management level working 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 providing a payment service in Germany or, through passporting, in the EU and EEA needs a BaFin licence. A business that will also hold customer balances applies for an EMI licence instead.
| Requirement | Amount |
|---|---|
| Account, card and other services (1–5) | €125,000 |
| Payment initiation only | €50,000 |
| Money remittance only | €20,000 |
| Account information only | Registration; no capital, liability insurance required |
| Ongoing own funds | Method B by default |
Method B applies a factor of 0.5 for money remittance only and 1.0 otherwise.
| 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 10 |
| 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 | €20,000 to €125,000 | Available in Germany |
| Professional fees | Fixed, in writing | Quoted after scoping |
A German payment institution passports throughout the EU and EEA by branch, agent or cross-border services, with BaFin forwarding notifications within one month and deciding on registration within three months. There is no small PI waiver.
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.
A payment institution 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; the firm plans for six to eight months after submission.
€125,000 for account, card and most services; €50,000 for payment initiation only; €20,000 for money remittance only; all available in Germany.
No. Germany did not adopt the small payment institution option; only limited-network and telecommunications exemptions apply.
The head office, at least two managing directors and the money laundering officer performing the role in Germany.
Method B on monthly payment volume by default; BaFin may require Method A or C.
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.