Germany electronic money institution licence.

What you get

How we get you licensed and live

1. Scoping and proposal. We confirm the permissions, the own funds under Method D and any BaFin add-on in a written proposal, and plan the German-language file from the start.
2. Application pack. The application in German with every item the statute lists, from the three-year business plan and proof of capital available in Germany to the security strategy and manager files against each ground BaFin assesses.
3. Banking. The safeguarding account with a credit institution, or an insurance policy or guarantee from a provider authorised in Germany, and the operating accounts, opened alongside the application, with the capital held in Germany.
4. Regulator engagement. We answer BaFin’s questions so the application is complete well inside the twelve months the statute allows, through to the grant of the licence and its publication in the Federal Gazette.

Your team, banking and technology

You will need at least two managing directors, and an MLRO at management level with a deputy, both carrying out the role in Germany.

One programme, from scoping to launch. Speak to an expert about this licence.

Who needs the licence

A business issuing stored value in Germany or, through passporting, across the EU and EEA needs a BaFin licence for the e-money business. Germany is the EU’s largest market, and a German licence carries weight with banks and partners across the region. An EMI may provide every payment service under the same licence.

What BaFin requires

• Legal form and location. A legal person or commercial partnership with its head office in Germany, providing at least part of its services in Germany, with the initial capital available in Germany.
• Governance. At least two managing directors, one sufficing for small firms, each reliable and professionally suitable; significant shareholders assessed; effective risk management and internal controls; a money laundering officer at management level with a deputy, performing the role in Germany.
• Safeguarding. Funds kept separate and, if still held at the end of the business day following receipt, placed in a separate account with a credit institution or central bank or invested in secure low-risk assets after consulting BaFin; or an insurance policy or comparable guarantee from a provider authorised in Germany outside the group. BaFin may prescribe the method.
• Application pack. The application to BaFin with the items the statute lists: business model, three-year business plan with budget, proof of initial capital, safeguarding, governance and controls, incident and complaints procedures, business continuity, security strategy, organisation and outsourcing, shareholders, managers, auditors, articles and head office address. BaFin may attach conditions; the licence is published in the Federal Gazette.
• Capital. Initial capital of €350,000 available in Germany and own funds thereafter never below it, with Method D (2% of average outstanding e-money) for e-money and Methods A, B or C for unrelated payment services; BaFin may impose a 20% add-on.

Capital

The capital must be available in Germany before the licence is granted.

Timing

Regulator figures are quoted as published and converted to months. Our realistic timeline assumes a complete, well-prepared application.

Fees and costs

Passporting and scope

A German EMI passports throughout the EU and EEA by branch, agent or cross-border services. BaFin forwards complete notifications within one month and decides on registration within three months. There is no small EMI waiver; the only exemptions are the limited-network and telecommunications exemptions.

Why applications are delayed

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. We prepare each application against every ground.

Your bank accounts

An EMI needs a safeguarding account, an operating account and settlement accounts in the currencies it serves. We open each alongside the application, so you trade from authorisation. See banking and payment processing.

Common questions

References

1. Payment Services Supervision Act (ZAG), section 10: licence for payment services
2. ZAG section 11: licence for e-money business
3. ZAG section 12: grounds for refusal
4. ZAG section 17: safeguarding
5. ZAG section 38: passporting
6. Own funds regulation for ZAG institutions (ZIEV)

This guide is general information, not legal advice. Requirements and fees change, and the regulator’s own publications take precedence.