Fintech & payments regulation in Germany (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).

BaFin issues written authorisations under §10 ZAG (payment institutions) and §11 ZAG (e-money institutions); minimum initial capital ranges from €20,000 (money remittance) and €125,000 (full PI) to €350,000 (EMI). Ongoing prudential supervision is shared with the Deutsche Bundesbank.

Firms providing only account information services register under §34 ZAG; BaFin maintains the public register of PIs, EMIs and AISPs required by §§43–44 ZAG.

PSD2 access-to-account is transposed via the ZAG; licensed TPPs (PISP/AISP) with a QWAC certificate can access ASPSP APIs. German banks predominantly implement the Berlin Group NextGenPSD2 standard, complemented by Deutsche Kreditwirtschaft specifications.

Under EU Regulation 2024/886, all euro-area PSPs must receive SEPA Instant Credit Transfers since 9 January 2025 and send them since 9 October 2025, with mandatory Verification of Payee and fees no higher than standard SCT. In Germany, SCT Inst is settled via TIPS (operated by the ECB with Bundesbank participation) and EBA Clearing's RT1.

Germany's law transposing the EU Consumer Credit Directive (CCD II) was published in the Federal Gazette on 18 May 2026 and enters into force on 20 November 2026, extending consumer-credit rules to sub-€200 loans, interest-free loans and short-term BNPL. A dedicated Act on the Supervision of Sales Financing (AbsFinAG) creates a separate BaFin-supervised regime for retailers and platforms offering their own deferred-payment products.

MiCA has applied fully since 30 December 2024. Germany's accompanying Cryptomarkets Supervision Act (Kryptomärkteaufsichtsgesetz – KMAG), part of the Financial Market Digitisation Act (FinmadiG), was gazetted on 27 December 2024 and designates BaFin as the competent MiCA authority, with grandfathering for KWG-licensed crypto custodians running to 31 December 2025.