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Licence guide

Germany payment institution licence.

Payment institutions that want a home licence in the EU’s largest market, and the standing a BaFin authorisation gives with European banks, choose Germany as their base.

Published 16 October 2026 · Last reviewed 17 October 2026
BaFinRegulator
€20,000–€125,000Initial capital
By time spentLicence fee
6 to 8 monthsOur realistic timeline
EU and EEAPassporting

Firms we have licensed.

Selected engagements from more than 250 licences obtained since 2013, for payment, e-money and cryptoasset firms.

Since 2013Advising global payment firms
60+Countries licensed in
250+Licences obtained globally
Clients
ClearBankVolkswagenMacmillan Cancer SupportRoyal College of MusicStaysureOval MoneyEMQCentus
nexpayPayment Institution

Obtained Nexpay’s FCA Authorised Payment Institution licence.

dzingElectronic Money Institution

Obtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.

Payment Institution

Obtained Orbital’s FCA Authorised Payment Institution licence.

What you get

6 to 8 monthsLicence granted

Our realistic timeline from submission to decision.

Day oneReady to trade

Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.

Your teamKey people in place

We assemble your team: two managing directors and an MLRO in Germany.

Same dayWritten proposal

The licence, the requirements, the cost and the timing for your business.

How we get you licensed and live

  1. Scoping and proposal. We confirm the payment services, the capital by service and the own funds method, Method B by default, in a written proposal, and plan the German-language file from the start.
  2. Application pack. The German-language application with the items the statute lists, including the three-year business plan with budget, proof of capital available in Germany, liability insurance for payment initiation or account information, and the manager and shareholder files.
  3. Banking. The safeguarding and operating accounts, and settlement accounts in the currencies you serve, opened alongside the application, with the initial capital paid in to an account in Germany.
  4. Regulator engagement. Each BaFin request is answered with the evidence assembled, keeping the file complete well within the twelve-month limit, until the licence, its conditions and its publication in the Federal Gazette.

Your team, banking and technology

You will need at least two managing directors, or one for a small firm, and an MLRO at management level working in Germany.

Key peopleWe assemble your team: two managing directors and an MLRO in Germany.
BankingSafeguarding, operating and settlement accounts, card acquiring and payment processing, opened alongside the application.
TechnologyWhite-label technology for accounts, payments, wallets and card programmes, ready to go live with the licence.

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

The licence in detail

Requirements, capital, timing, fees and common questions, drawn from the regulator’s own publications.

Key takeaways
  • A German payment institution provides any of the payment services across the EU and EEA under the Payment Services Supervision Act.
  • Initial capital is €125,000 for account and card services, €50,000 for payment initiation and €20,000 for money remittance, available in Germany.
  • Ongoing own funds default to Method B on payment volume, with BaFin able to require another method.
  • Three months from a complete application by statute; twelve months to complete the application.
  • At least two managing directors and a money laundering officer in Germany.
  • There is no small payment institution regime in Germany; account information providers register without capital but with liability insurance.

Who needs the licence

A business providing a payment service in Germany or, through passporting, in the EU and EEA needs a BaFin licence. A business that will also hold customer balances applies for an EMI licence instead.

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 by service available in Germany, and own funds thereafter never below it; Method B on monthly payment volume is the default, with Method A on fixed overheads and Method C on a relevant indicator as alternatives BaFin may require.
  • Liability insurance. For payment initiation and account information services.

Capital

RequirementAmount
Account, card and other services (1–5)€125,000
Payment initiation only€50,000
Money remittance only€20,000
Account information onlyRegistration; no capital, liability insurance required
Ongoing own fundsMethod B by default

Method B applies a factor of 0.5 for money remittance only and 1.0 otherwise.

Timing

FigureValueSource
Statutory decision period3 months from a complete application; an application not completed within 12 months is rejectedPayment Services Supervision Act (ZAG), section 10
Application preparation6 to 8 weeksFrom instruction to submission, including banking in parallel
Our realistic timeline6 to 8 months after submissionOur own figure, from the regulator’s published data and our applications

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

Fees and costs

ItemAmountNotes
Licence feeBy time spentUnder the federal fee schedule
Annual supervision allocationBy cost allocationBaFin recovers supervision costs from institutions
Initial capital€20,000 to €125,000Available in Germany
Professional feesFixedQuoted after scoping

Passporting and scope

A German payment institution passports throughout the EU and EEA by branch, agent or cross-border services, with BaFin forwarding notifications within one month and deciding on registration within three months. There is no small PI waiver.

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

A payment institution 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

How long does BaFin take to license a payment institution?

Three months from a complete application by statute; we plan for six to eight months after submission.

What capital does a German PI need?

€125,000 for account, card and most services; €50,000 for payment initiation only; €20,000 for money remittance only; all available in Germany.

Is there a small PI regime in Germany?

No. Germany did not adopt the small payment institution option; only limited-network and telecommunications exemptions apply.

Who must be in Germany?

The head office, at least two managing directors and the money laundering officer performing the role in Germany.

Which own funds method applies?

Method B on monthly payment volume by default; BaFin may require Method A or C.

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)

About Buckingham Capital Consulting

A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm builds licensed payment, e-money, crypto and stablecoin businesses: the licence, the team, the technology, the bank accounts and card issuing.

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

How we work.

  • Senior-ledThe same senior team handles your application from the first call to approval, including every question the regulator raises.
  • Same dayA reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.
  • ConfidentialYour plans, your application and any listing stay private. Clients are named only with their agreement.
  • Live workspaceDocuments, regulator questions, messages and progress in a shared client workspace, visible to your team at every stage.

Why firms choose BCC.

  • OperatorsWe have run regulated payment businesses, held regulator-approved roles and licensed payment firms in more than 60 countries since 2013.
  • One teamOne in-house team runs the whole programme, from the application to the day you go live.
  • ArrangedBank and safeguarding accounts, card issuing and payment processing, arranged directly through our relationships with banks, card schemes, issuers and processors.

Apply for this licence.

The licence, your team, banking and technology, delivered as one programme.