Digital Payments & Fintech · Germany
EMI license in Germany: e-money institution (EMI) requirements (2026)
Germany shaded by its digital payments & fintech status
Fintech and digital payments in Germany: licensing regime, under Payment Services Supervision Act (Zahlungsdiensteaufsichtsgesetz, ZAG) implementing PSD2, supervised by BaFin with the Deutsche Bundesbank; supplemented by the EU MiCA framework (transposed via FinmadiG/KMAG) for crypto-assets and the directly-applicable EU Instant Payments Regulation (2024/886)..
Germany operates a clear, mature licensing regime for digital payments and fintech, anchored in the ZAG (transposing the EU PSD2). BaFin, working with the Deutsche Bundesbank, authorises and supervises payment institutions and e-money institutions, and is the national competent authority for crypto-asset service providers under MiCA. Open banking, SEPA instant payments and BNPL are governed by directly-applicable EU rules plus national implementing measures, with BNPL supervision tightening as Germany transposes the second Consumer Credit Directive.
How to get an EMI license in Germany
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).
- Authority
- the Federal Financial Supervisory Authority (BaFin)
- License required
- authorisation as an Electronic Money Institution (EMI)
- Framework / law
- the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2)
- Minimum capital
- €350,000 initial capital for a full (Authorised) EMI; a lighter Small EMI regime exists below an average €5m of outstanding e-money
- Timeline
- roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete
- Cost
- application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs
- Passporting
- Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
EMI license in Germany: FAQ
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.
Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
Key points
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.
Timeline - major decisions & events
The EU Markets in Crypto-Assets Regulation (MiCAR) became fully applicable, and BaFin began issuing MiCA authorisations to crypto-asset service providers (CASPs), making MiCA the primary licensing regime for crypto activity in Germany. By late 2025 BaFin had registered more CASPs than any other member state.
BaFin ↗Enacted in response to the Wirecard collapse, the FISG gave BaFin expanded 'sovereign powers' to investigate listed companies directly, strengthened accounting enforcement, and tightened internal staff trading rules, a structural overhaul of German financial supervision affecting payments/fintech oversight.
BaFin ↗BaFin published a guidance notice clarifying the statutory definition of the new 'crypto custody business' under section 1(1a) KWG and how firms must apply for a licence, establishing detailed expectations (notably on IT security) for crypto custodians operating in Germany.
BaFin ↗Implementing the EU's 5th Anti-Money Laundering Directive, Germany added 'crypto custody business' to the German Banking Act (KWG) as a regulated financial service, requiring BaFin authorisation, making Germany an early mover in formally licensing crypto custodians.
BaFin ↗A new version of the Zahlungsdiensteaufsichtsgesetz (ZAG) transposed PSD2 into German law, introducing licensing/registration for new payment services such as payment initiation and account information services and requiring BaFin authorisation for payment and e-money institutions under sections 10, 11 and 34 ZAG.
BaFin ↗Germany implemented the Second E-Money Directive (2009/110/EC) by amending the ZAG, creating the dedicated 'e-money institution' licence (now section 11 ZAG) under which BaFin authorises firms to issue e-money and provide all payment services.
Deutsche Bundesbank ↗Germany - other topics
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