Crypto-asset service provider licence (Germany)
The Crypto-asset service provider licence (Zulassung als Anbieter von Kryptowerte-Dienstleistungen nach Art. 59 MiCAR / KMAG) is issued by Federal Financial Supervisory Authority (BaFin) under Crypto Markets Supervision Act (Kryptomärkteaufsichtsgesetz - KMAG). It can be passported to the other EU/EEA states by notification. The official register lists 81 current holders. The legal decision period is 40 working days from receipt of a complete application. Ownership changes need the regulator's approval before completion.
At a glance
| Official name | Crypto-asset service provider licence1 |
|---|---|
| Local name | Zulassung als Anbieter von Kryptowerte-Dienstleistungen nach Art. 59 MiCAR / KMAG |
| Also known as | CASP · KMAG licence · Zulassung als Anbieter von Kryptowerte-Dienstleistungen · BaFin CASP licence · German crypto licence |
| Issued by | Federal Financial Supervisory Authority |
| Jurisdiction | Germany |
| Licence family | Crypto-asset service provider (MiCA CASP) |
| Legal basis | Crypto Markets Supervision Act (Kryptomärkteaufsichtsgesetz - KMAG)2 Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA)1 |
| Passporting | EU/EEA passport available |
| Application fee | nach Zeitaufwand (billed based on staff time spent)3 |
| Annual fee | Annual cost allocation levy (Umlage) under FinDAG4 |
| Statutory decision time | 40 working days from receipt of a complete application1 |
| Public register | official register5 |
| Current holders | 815 |
What it lets you do, and where
What does a German CASP licence let you do, and where can you serve clients?
A German CASP licence lets you provide crypto-asset services EU-wide under Article 65 MiCAR passporting, without separate host-state authorisations. The home authority communicates within 10 working days; you may start on receipt of that communication or at the latest on the 15th calendar day after submitting your notification.127
Activities it covers
| Custody and administration of crypto-assets | Safekeeping or controlling crypto-assets, or the means of access to them such as private keys, on behalf of clients. |
|---|---|
| Operating a crypto-asset trading platform | Managing a multilateral system that brings together buying and selling interests in crypto-assets so that contracts are concluded. |
| Exchange of crypto-assets for funds | Buying or selling crypto-assets against fiat money using the provider's own capital. |
| Exchange of crypto-assets for other crypto-assets | Concluding contracts with clients to swap one crypto-asset for another using the provider's own capital. |
| Execution of orders for crypto-assets on behalf of clients | Concluding agreements to buy or sell crypto-assets on behalf of clients, including subscribing to offers. |
| Placing of crypto-assets | Marketing crypto-assets to purchasers on behalf of or for the account of the offeror or a related party. |
| Reception and transmission of orders for crypto-assets | Receiving a client's order to buy or sell crypto-assets and passing it to a third party for execution. |
| Advice on crypto-assets | Giving personalised recommendations to a client about transactions in crypto-assets or the use of crypto-asset services. |
| Portfolio management of crypto-assets | Managing portfolios that include crypto-assets on a discretionary, client-by-client basis under a mandate. |
| Transfer services for crypto-assets | Moving crypto-assets on behalf of a client from one distributed-ledger address or account to another. |
Where it is valid
Do you need it, and is Germany the right choice?
What is a German MiCA CASP licence and do you actually need one?
A German MiCA CASP licence is an authorisation under Article 59 of Regulation (EU) 2023/1114 and the German Crypto Markets Supervision Act (KMAG), required before providing crypto-asset services commercially in Germany. Providing crypto-asset services without it is a criminal offence under Section 46 KMAG, punishable by up to five years' imprisonment or a fine.1628
Is a German CASP licence right for your model, and what are the alternatives?
BaFin's supervisory reputation works as a quality seal, but it comes with rigorous, critical vetting of applications. Credit institutions and investment firms already authorised can use the simplified Article 60 MiCAR notification route instead of a full CASP application.291
Can one German CASP licence cover the whole EU, and how does passporting work?
Yes. Under Article 65 MiCAR, a German CASP can provide services in other Member States after notifying BaFin, without separate national licences. BaFin passes the information to host authorities within 10 working days, and the provider may start on receipt of that communication or at the latest on the 15th calendar day after its notification.30
Authorised credit institutions and investment firms notify crypto services under Article 60 MiCAR without a full CASP application. Issuing EMTs requires authorisation as an EMI or credit institution under MiCA Article 48 and German ZAG.131
A BaFin expert confirmed rigorous application standards and noted that not every applicant succeeded in getting licensed. ESMA conducted a fast-track peer review of the MFSA's authorisation and early supervision of a CASP, finding the authorisation should have been more thorough and given sufficient time.2932
It depends on how decentralised the service is. MiCAR Recital 22 excludes crypto-asset services provided in a fully decentralised manner without any intermediary from the Regulation's scope. Activities performed, provided or controlled directly or indirectly, including partly decentralised ones, are covered. The recital does not address front-ends or custodial multi-sigs.25
Yes, where the loss results from an incident attributable to the custodian. Article 75(8) MiCAR holds crypto custodians liable for loss of crypto-assets or means of access in that case. ESMA's Second Consultation Paper interprets Article 75(8) as exempting CASPs only for permissionless DLT they do not control or manage (no contractual arrangement).133
What it really takes
How much capital do you really need for a German CASP licence?
Minimum permanent capital (Annex IV MiCAR) is €50,000 for Class 1 (reception/transmission, advice, execution and placing of orders), €125,000 for Class 2 (adding custody/administration and exchange) and €150,000 for Class 3 (adding operation of a trading platform). Article 67 requires prudential safeguards at all times equal to the higher of that amount or one quarter of the preceding year's fixed overheads; firms under one year old use projected first-12-month overheads. Safeguards may be own funds (CET1 items) or other forms.16261
Who do you have to hire for a German CASP licence, and where must they live?
You need at least two managers, who must be reliable (no relevant criminal convictions) and have knowledge of financial services, crypto or IT. The firm must also have a compliance function and a money laundering officer.16
In which language must the application and documents be filed with BaFin?
Under Section 23 VwVfG German is the official administrative language. Section 4j FinDAG allows application documents to be submitted in English, subject to BaFin requesting translations.1011
Application contents are set by MiCAR, Commission Delegated Regulation (EU) 2025/305 (information to include) and Implementing Regulation (EU) 2025/306 (standard forms and templates). Applications are submitted to BaFin Referat ZK 4 with a duplicate to the Deutsche Bundesbank.7
The legal framework
11 related regimes and guidance documents
| Level | Document | What it does here |
|---|---|---|
| Guidance | BaFin-Merkblatt: Kryptowerte-Dienstleistungen nach MiCAR (Stand: 03.01.2025) | Official administrative circular detailing the 10 crypto-asset services under MiCA, domestic activity criteria, pre-application dialogue, and application channels |
| Guidance | ESMA Supervisory Briefing on the Authorisation of Crypto-Asset Service Providers under MiCA (ESMA35-43-3932) | Supervisory convergence guidance applied by BaFin for reviewing CASP dossiers, setting the standard 4-week window for providing missing application information |
| Guidance | Joint Guidelines on the suitability assessment of the members of the management body of CASPs and of shareholders and members with qualifying holdings (EBA/GL/2024/11 - ESMA35-36-3023) | Provides assessment criteria and checklists for management fit-and-proper and shareholder repute under MiCA Art. 63(11) |
| Related regime | Digital Operational Resilience Act | Mandates ICT risk management, incident classification and reporting, digital operational resilience testing, and third-party ICT risk oversight for CASPs |
| Related regime | Transfer of Funds Regulation (travel rule) | Obliges CASPs to obtain, verify, record, and transmit originator and beneficiary data for crypto-asset transfers |
| Related regime | Fourth Anti-Money Laundering Directive (as amended by the fifth, 2018/843) | EU baseline directive establishing AML/CFT compliance systems, customer due diligence, beneficial ownership transparency, and suspicious activity reporting |
| Related regime | Anti-Money Laundering Regulation (single rulebook) partly in force | Directly applicable EU single rulebook replacing national transpositions for obliged entities including CASPs from 10 July 2027 |
| Related regime | Directive 2014/65/EU on markets in financial instruments | Defines the financial instruments regulatory perimeter excluding security tokens from MiCA CASP scope and serves as benchmark for CASP services under Art. 60 MiCA |
| Related regime | Capital Requirements Regulation | Defines Common Equity Tier 1 (CET1) capital components referenced by MiCA Art. 67 for calculating CASP own funds requirements |
| Related regime | Gesetz über das Aufspüren von Gewinnen aus schweren Straftaten (Geldwäschegesetz - GwG) | Designates BaFin as AML supervisor for CASPs (§ 50 Nr. 1 lit. b), requires customer due diligence, appointment of AML compliance officer, internal risk analysis, and FIU reporting |
| Related regime | Gesetz über das Kreditwesen (Kreditwesengesetz - KWG) | Defines the boundary between banking/financial services, qualified crypto custody of tokenized securities (§ 1 Abs. 1a Satz 2 Nr. 6 KWG), and MiCA CASP services |
The procedure under the law
| Step | What the law says | Legal reference |
|---|---|---|
| How to file | Applications go to BaFin: the Merkblatt states it does not replace a case-specific authorisation request to BaFin. BaFin's legally effective channel is qes-posteingang@bafin.de, and it accepts electronic documents with legal effect; general contact is poststelle@bafin.de, Graurheindorfer Straße 108, 53117 Bonn (or Postfach 1253, 53002 Bonn). Questions may go to the Bundesbank (kpz-zk.hv-bbb@bundesbank.de). No passage cites a provision prescribing the channel.789 | KMAG § 11 Abs. 3; FinDAG § 4h, § 4j; VwVfG § 3a; MiCA Art. 62; Commission Implementing Regulation (EU) 2025/306 Art. 1 |
| Language | German is BaFin's official language. If you submit documents in English, you must follow the guidance on the individual authorisation or registration requirements and the provisions on translation in the FinDAG. Application documents must be complete and meet the statutory requirements and formal rules (e.g. for CVs of managing directors or register extracts). Where an agent acts on your behalf, the original version of the power of attorney must be included.101112 | |
| What the application contains | The application uses the standard form and templates in the Annex to Commission Implementing Regulation (EU) 2025/306, which sets out the information to be included in a CASP authorisation application. The required information is specified in Commission Delegated Regulation (EU) 2025/305 (RTS to Article 62(5) MiCAR), and the forms/templates in the ITS to Article 62(6) MiCAR. BaFin also requires DORA documentation evidence in the application.1371415 | Regulation (EU) 2023/1114 Art. 62(1)-(4); Commission Delegated Regulation (EU) 2025/305 Art. 1-15; Commission Implementing Regulation (EU) 2025/306 Annex; KMAG § 11; Regulation (EU) 2022/2554 (DORA) |
| Decision clock | BaFin checks completeness within 25 working days of receipt and decides within 40 working days of a complete application. The period is suspended while the applicant supplies requested information, up to 20 working days.16 | |
| Fees set by law | Under the FinDAGebV fee schedule (Anlage, Section 32), the fee for CASP authorisation under Art. 59(1)(a) of Regulation (EU) 2023/1114 (No. 32.1.2) is charged by time spent, as are authorisation extensions (No. 32.2.1) and notifications under Art. 59(1)(b)/Art. 60 (No. 32.2.4). Hourly rates under AGebV Anlage 1 Teil A are EUR 50.73-93.61. No annual fee is stated.31718 | Finanzdienstleistungsaufsichtsgebührenverordnung (FinDAGebV) § 1 Abs. 1 Nr. 40, § 2 Abs. 1 i.V.m. Anlage (Gebührenverzeichnis) Abschnitt 32 Ziffer 32.1.2 und § 3; Allgemeine Gebührenverordnung (AGebV) Anlage 1 Teil A |
| Grounds for refusal | Refusal of CASP authorisation is mandatory where there are objective and demonstrable grounds, listed in paragraph 10 of the MiCA CASP authorisation provision: (a) the management body threatens effective, sound and prudent management, business continuity, client interests or market integrity, or exposes the applicant to serious money-laundering/terrorist-financing risk; (b) management body members fail the Article 68(1) criteria; (c) qualifying holders fail the Article 68(2) good repute criteria; (d) any requirement of this Title is or is likely to be unmet. Paragraph 8 adds refusal where third-country law on close links blocks supervision.1920 | |
| Appeal | Under § 70 (1) VwGO, an objection (Widerspruch) against the act must be filed within one month of its notification to the affected person, in writing, electronically or on the record, with the authority that issued it; filing with the authority that will decide the objection also meets the deadline.212223 | Verwaltungsgerichtsordnung (VwGO) §§ 68, 70 Abs. 1 (1 month for Widerspruch), § 74 Abs. 1 (1 month for Klage after Widerspruchsbescheid); KMAG § 5 (objections and actions against BaFin supervisory orders have no suspensive effect) |
| Validity | None of the governing texts held for this licence (Crypto Markets Supervision Act; Crypto Markets Supervision Act; Markets in Crypto-Assets Regulation; Markets in Crypto-Assets Regulation; German Banking Act; German Banking Act; German Capital Investment Code; German Capital Investment Code; Electronic Securities Act; Electronic Securities Act; Act on the Supervision of Investment Firms (Investment Firms Act); Act on the Supervision of Investment Firms (Investment Firms Act); Payment Services Supervision Act; Payment Services Supervision Act; Regulation (EU) No 575/2013) contains a provision on a fixed term or expiry of the licence.24 | |
| Change of control | A proposed acquisition of a qualifying holding in a crypto-asset service provider must be notified in writing to the competent authority in advance. The authority must acknowledge receipt within 2 working days and then has 60 working days from that acknowledgement to assess the proposed acquisition. It may ask for further information up to the 50th working day; the assessment is then suspended until that information arrives, for no more than 20 working days, and may be extended by up to 30 working days.125 | |
| Reapplying after a refusal | None of the governing texts held for this licence (Crypto Markets Supervision Act; Crypto Markets Supervision Act; Markets in Crypto-Assets Regulation; Markets in Crypto-Assets Regulation; German Banking Act; German Banking Act; German Capital Investment Code; German Capital Investment Code; Electronic Securities Act; Electronic Securities Act; Act on the Supervision of Investment Firms (Investment Firms Act); Act on the Supervision of Investment Firms (Investment Firms Act); Payment Services Supervision Act; Payment Services Supervision Act; Regulation (EU) No 575/2013) contains a provision on a waiting period before a new application after refusal or withdrawal. | |
| Serving other countries | Yes: passporting applies. Under MiCA Article 65, an authorised CASP intending to serve clients in more than one Member State submits to its home competent authority (BaFin) a list of target Member States, the services to be provided cross-border, the planned start date, and any other activities outside MiCA. BaFin communicates this to host authorities, ESMA and EBA within 10 working days. Services may start on receipt of that communication, or at the latest on the 15th calendar day after submission.726 |
How long it takes
How long does a German MiCA CASP licence actually take?
A completeness check takes 25 working days for Article 62(1) applications, and the decision period that follows is 40 working days. Under the pre-MiCA KWG crypto custody regime, parliamentary inquiries revealed an average review duration of 482 days.2734
How long may BaFin take by law, and what stops the statutory clock?
BaFin must decide within 40 working days of a complete application and notify the applicant within 5 working days. It applies ESMA's four-week deadline recommendation for curing incomplete filings and rejects applications that remain incomplete.277
Statutory: 40 working days from receipt of a complete application1. Observed: not published. The statutory clock usually starts only when the regulator treats the application as complete, and pauses while it waits for answers to its questions.
What it costs
What does a German CASP licence cost in total?
BaFin fees run from €10,000 to €50,000 depending on licence type, and legal and advisory costs from €50,000 to €200,000. Compliance infrastructure and ongoing personnel and IT costs come on top. Own funds are separate: €50,000, €125,000 or €150,000 by class, and at least one quarter of the previous year's fixed overheads. BaFin is funded by fees and levies under Part 5 of FinDAG.1635
Approval odds and who can own it
What are the real approval odds for a German CASP licence, and why do applications fail?
BaFin's public database lists 81 entities under category 175 (crypto-asset service providers). BaFin has confirmed that in past years not every applicant obtained a licence, given its rigorous review standards.529
BaFin tests an applicant for a German CASP licence on management, capital and compliance. In the application process it assesses the reliability and professional qualification of managers, proof of capital, and the applicant's AML/KYC compliance.16
How many MiCA CASP licences has BaFin actually granted?
In BaFin's public database, 81 institutions are listed under category 175 (Kryptowertedienstleister). Separately, ESMA interim register data compiled in late June 2026 showed Germany leading the EU/EEA with 57 authorised CASPs out of 243 in total.536
After you get the licence
DORA (EU 2022/2554) took effect on 17 January 2025 and imposes mandatory ICT risk management on all supervised financial entities. Issuing EMTs requires an EMI or credit institution licence under the Payment Services Supervision Act (ZAG).3731
Will you get a bank account and payment processing as a German CASP?
Client fiat funds must be held in segregated safeguarding accounts with credit institutions, as required by Article 70 MiCAR. Section 1(1) sentence 2 no. 1 KWG defines deposit-taking as accepting third-party funds as deposits or other unconditionally repayable funds from the public.138
Germany's national grandfathering transitional regime for existing crypto-asset service providers expired on 31 December 2025 (§ 50 KMAG). ESMA requires iXBRL/XBRL format for crypto-asset white papers under the MiCA taxonomy, applicable from 23 December 2025.1639
Can you appeal a BaFin refusal, to whom and by when?
Yes. Under MiCA Article 113, Member States must ensure that decisions by competent authorities are properly reasoned and subject to the right of appeal before a court. The same right applies where no decision is taken within six months of submitting a complete authorisation application.1
The licence is granted for an indefinite period under Article 59 MiCAR, with no recurring renewal requirement. Prior notification is required under Article 83 MiCAR and KMAG for changes of control exceeding 10%, 20%, 30%, or 50% and for management appointments.240
Is your old German crypto custody or trading permission still valid, what happened after the transitional deadline?
No. Under Section 50(2) No. 3 KMAG, permissions treated as continuing under the transitional regime expired at the latest on 31 December 2025. ESMA's grandfathering overview lists Germany's transitional period as 12 months under Article 143(3) MiCA.4142
Buying a company that already holds it
Prior notification with an objection period. Acquiring or increasing a qualifying holding reaching or crossing 10%, 20%, 30%, or 50% of capital or voting rights, or gaining control of a credit institution, payment institution, or investment firm, requires prior written notification to BaFin and the Deutsche Bundesbank. BaFin conducts an assessment of acquirer reliability, professional competence, financial soundness, and money laundering risks within 60 working days from receipt of a complete filing, interruptible once by up to 20 working days (or 30 working days if non-EEA) to request additional information, under Section 2c KWG, applied mutatis mutandis to payment and e-money institutions via Section 14 ZAG and to investment firms via Section 24 WpIG.6
CASP in other countries
| Country | Licence | Regulator | Min. capital | Application fee | Statutory time |
|---|---|---|---|---|---|
| Cyprus | Notification by financial entities providing crypto-asset servicesNotification by financial entities providing crypto-asset services under MiCAR Article 60 | CySEC | n/a | EUR 10,000 | ~1.8 mo |
| Cyprus | Crypto-Asset Service Provider (CASP) authorisationCrypto-Asset Service Provider (CASP) authorisation under MiCAR Article 63 | CySEC | EUR 50,000 | EUR 5,000 | ~1.8 mo |
| Czech Republic | Crypto-Asset Service Provider authorisationCrypto-Asset Service Provider authorisation under MiCA and Act No. 31/2025 Coll. | CNB | EUR 50,000 | CZK 20,000 | ~3 mo |
| Estonia | Authorisation to operate as a crypto-asset service providerAuthorisation to operate as a crypto-asset service provider under MiCA | FI | n/a | EUR 3,000 | ~3.9 mo |
| France | Crypto-asset service provider authorizationCrypto-asset service provider authorization under EU MiCA Regulation | AMF | n/a | n/a | ~1.8 mo |
| Germany | Crypto-asset service provider licence | BaFin | n/a | n/a | ~1.8 mo |
| Ireland | Crypto-Asset Service Provider Authorisation | CBI | n/a | n/a | ~1.8 mo |
| Italy | Crypto-asset service provider (CASP) authorization | CONSOB | n/a | EUR 20,000 | ~1.8 mo |
| Latvia | Crypto-asset service provider licenceCrypto-asset service provider licence under MiCA | LB | EUR 50,000 | EUR 2,500 | ~3 mo |
| Lithuania | Crypto-asset service provider licence | LB | EUR 50,000 | EUR 2,425 | ~3 mo |
| Luxembourg | Crypto-asset service provider authorisationCrypto-asset service provider authorisation under MiCA Regulation | CSSF | n/a | EUR 30,000 | ~1.8 mo |
| Malta | Crypto-Asset Service Provider authorisationCrypto-Asset Service Provider authorisation under Regulation (EU) 2023/1114 | MFSA | EUR 50,000 | EUR 10,000 | ~1.8 mo |
| Netherlands | Crypto-Asset Service Provider (CASP) authorisationCrypto-Asset Service Provider (CASP) authorisation under Regulation (EU) 2023/1114 (MiCA) | AFM | EUR 50,000 | EUR 200 | ~3 mo |
| Poland | Crypto-Asset Service Provider authorizationCrypto-Asset Service Provider authorization under MiCA | KNF | EUR 50,000 | n/a | ~3 mo |
| Slovakia | Crypto-asset service provider licenceCrypto-asset service provider licence under MiCA | NBS | EUR 50,000 | EUR 1,700 | ~3 mo |
| Spain | Crypto-asset service provider authorization | CNMV | n/a | n/a | ~1.8 mo |
Values come from each licence's page, where every figure has its source.
Laws behind it
- Markets in Crypto-Assets Regulation: Regulation (EU) 2023/1114
Frequently asked questions
What is a German MiCA CASP licence and do you actually need one?
A German MiCA CASP licence is an authorisation under Article 59 of Regulation (EU) 2023/1114 and the German Crypto Markets Supervision Act (KMAG), required before providing crypto-asset services commercially in Germany.
How much capital do you really need for a German CASP licence?
Minimum permanent capital (Annex IV MiCAR) is €50,000 for Class 1 (reception/transmission, advice, execution and placing of orders), €125,000 for Class 2 (adding custody/administration and exchange) and €150,000 for Class 3 (adding operation of a trading platform).
How long does a German MiCA CASP licence actually take?
A completeness check takes 25 working days for Article 62(1) applications, and the decision period that follows is 40 working days.
What does a German CASP licence cost in total?
BaFin fees run from €10,000 to €50,000 depending on licence type, and legal and advisory costs from €50,000 to €200,000.
What are the real approval odds for a German CASP licence, and why do applications fail?
BaFin's public database lists 81 entities under category 175 (crypto-asset service providers).
What does a German CASP licence let you do, and where can you serve clients?
A German CASP licence lets you provide crypto-asset services EU-wide under Article 65 MiCAR passporting, without separate host-state authorisations.
Will you get a bank account and payment processing as a German CASP?
Client fiat funds must be held in segregated safeguarding accounts with credit institutions, as required by Article 70 MiCAR.
Who do you have to hire for a German CASP licence, and where must they live?
You need at least two managers, who must be reliable (no relevant criminal convictions) and have knowledge of financial services, crypto or IT.
Is a German CASP licence right for your model, and what are the alternatives?
BaFin's supervisory reputation works as a quality seal, but it comes with rigorous, critical vetting of applications.
In which language must the application and documents be filed with BaFin?
Under Section 23 VwVfG German is the official administrative language.
Sources
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