Digital Payments & Fintech - Germany

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.