EMI license in Germany: e-money institution (EMI) requirements (2026)

Yes. To provide electronic-money or payment services in Germany you need authorisation as an Electronic Money Institution (EMI), supervised by the Federal Financial Supervisory Authority (BaFin), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).

The Federal Financial Supervisory Authority (BaFin).

Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.

Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.

The application file centres on programme of operations listing each payment service you will provide; business plan with a three-year budget forecast; evidence of the €350,000 initial capital; governance arrangements and internal-control mechanisms; plus fit-and-proper evidence for directors and qualifying shareholders.

Incorporate in the member state and establish real local substance (registered office and part of the business conducted there). Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies. The authority then assesses the file and, once authorised, you can begin operating.

Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).

Providing payment services commercially or conducting e-money business requires prior written authorisation from BaFin under the ZAG (sections 10/11), with differentiated initial-capital and prudential requirements; BaFin maintains a public register of licensed payment and e-money institutions.

BaFin (Federal Financial Supervisory Authority) is the licensing and supervisory authority, operating in cooperation with the Deutsche Bundesbank, which handles much of the operational supervision and payment-systems oversight.

Under PSD2 (transposed via the ZAG), payers may use licensed third-party providers; account-servicing PSPs must provide a dedicated PSD2-compliant API for payment initiation, account information and funds-confirmation. PSD3/PSR are pending at EU level.

Under the directly-applicable EU Instant Payments Regulation (2024/886), euro-area PSPs in Germany have had to receive SCT Inst since 9 Jan 2025 and send since 9 Oct 2025, with mandatory Verification of Payee and fee parity with standard SEPA transfers.

BaFin is the national competent authority for crypto-asset service providers under MiCA, transposed nationally by the Financial Market Digitalisation Act (FinmadiG) and Crypto Markets Supervision Act (KMAG); Germany used a shortened (~12-month) grandfathering window, fully transitioning to MiCA by end-2025.

BNPL is being brought into scope by the EU second Consumer Credit Directive (2023/2225); Germany's draft implementing bill was presented on 3 Sep 2025 and is expected to enter into force on 20 Nov 2026, with narrow exemptions and a new BaFin registration regime (AbsFinAG) for certain deferred-payment offerings.