Skip to content
World Watch

Fintech & payments regulation in Germany (2026)

Fintech and digital payments in Germany: licensing regime.

Germany operates a mature, EU-harmonised licensing regime for digital payments and fintech. BaFin authorises payment institutions (PIs) under §10 ZAG and e-money institutions (EMIs) under §11 ZAG, and registers account information service providers (AISPs) under §34 ZAG, applying the EBA PSD2 authorisation guidelines. Open banking is implemented via PSD2/XS2A (Berlin Group NextGenPSD2 standard), instant payments are mandatory under the EU Instant Payments Regulation, and BNPL is being brought under supervision through the new AbsFinAG that transposes CCD II, entering into force on 20 November 2026.

Last verified Official sources first · MethodologyCompare Germany with other countriesAlso in Deutsch

Legal framework

Payment Services Supervision Act (Zahlungsdiensteaufsichtsgesetz – ZAG), transposing EU PSD2 and EMD2, administered by BaFin with operational supervision by the Deutsche Bundesbank; complemented by the EU Instant Payments Regulation, PSD2 open-banking rules, the new Sales Financing Supervision Act (AbsFinAG) for BNPL, and MiCA/KMAG for crypto-asset services.

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).

What an EMI license in Germany covers

  • Issuing electronic money and maintaining payment accounts
  • Executing payment transactions: credit transfers, direct debits and card payments
  • Issuing and/or acquiring payment instruments
  • Money remittance
  • Payment initiation services (PIS)
  • Account information services (AIS)

Step by step: getting an EMI license in Germany

  1. Incorporate in the member state and establish real local substance (registered office and part of the business conducted there).

  2. Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies.

  3. Deposit and evidence the €350,000 initial capital.

  4. Submit the application to the national competent authority.

  5. The authority has three months from a complete application to grant or refuse.

  6. On authorisation you are entered in the national and EBA registers, then passport into other EEA states before serving them.

Documents required in Germany

  • Programme of operations listing each payment service you will provide
  • Business plan with a three-year budget forecast
  • Evidence of the €350,000 initial capital
  • Governance arrangements and internal-control mechanisms
  • AML/CFT policy and appointment of a compliance officer
  • Safeguarding arrangements for client funds (segregated account or insurance)
  • Security policy, incident management and ICT resilience procedures
  • Fit-and-proper documentation for directors and qualifying shareholders
  • Description of any outsourcing, agents or distributors
  • Professional indemnity insurance where you provide PIS or AIS

Ongoing obligations in Germany

  • Maintain own funds under the applicable calculation method (A, B or C)
  • Safeguard client funds at all times, segregated or insured
  • Apply strong customer authentication (SCA) under PSD2
  • Run continuous AML/CFT monitoring and reporting
  • Report major operational and security incidents to the regulator
  • Submit annual audited accounts and periodic regulatory reporting

Key points: digital payments & fintech in Germany

  1. PI & EMI licensing under ZAG

    BaFin issues written authorisations under §10 ZAG (payment institutions) and §11 ZAG (e-money institutions); minimum initial capital ranges from €20,000 (money remittance) and €125,000 (full PI) to €350,000 (EMI). Ongoing prudential supervision is shared with the Deutsche Bundesbank.

    bafin.de bundesbank.de

  2. AISP registration & public register

    Firms providing only account information services register under §34 ZAG; BaFin maintains the public register of PIs, EMIs and AISPs required by §§43–44 ZAG.

    bafin.de bafin.de

  3. Open banking (PSD2 XS2A)

    PSD2 access-to-account is transposed via the ZAG; licensed TPPs (PISP/AISP) with a QWAC certificate can access ASPSP APIs. German banks predominantly implement the Berlin Group NextGenPSD2 standard, complemented by Deutsche Kreditwirtschaft specifications.

    bafin.de berlin-group.org

  4. Instant payments rail

    Under EU Regulation 2024/886, all euro-area PSPs must receive SEPA Instant Credit Transfers since 9 January 2025 and send them since 9 October 2025, with mandatory Verification of Payee and fees no higher than standard SCT. In Germany, SCT Inst is settled via TIPS (operated by the ECB with Bundesbank participation) and EBA Clearing's RT1.

    bundesbank.de suerf.org

  5. BNPL brought under supervision

    Germany's law transposing the EU Consumer Credit Directive (CCD II) was published in the Federal Gazette on 18 May 2026 and enters into force on 20 November 2026, extending consumer-credit rules to sub-€200 loans, interest-free loans and short-term BNPL. A dedicated Act on the Supervision of Sales Financing (AbsFinAG) creates a separate BaFin-supervised regime for retailers and platforms offering their own deferred-payment products.

    twobirds.com twobirds.com

  6. Crypto-asset services (MiCA/KMAG)

    MiCA has applied fully since 30 December 2024. Germany's accompanying Cryptomarkets Supervision Act (Kryptomärkteaufsichtsgesetz – KMAG), part of the Financial Market Digitisation Act (FinmadiG), was gazetted on 27 December 2024 and designates BaFin as the competent MiCA authority, with grandfathering for KWG-licensed crypto custodians running to 31 December 2025.

    bafin.de bafin.de

EMI license in Germany: FAQ

Do you need a license to run an e-money business in Germany?

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).

Which authority issues EMI licenses in Germany?

The Federal Financial Supervisory Authority (BaFin).

How much does an EMI license cost in Germany?

Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.

How long does it take to get an EMI license in Germany?

Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.

What documents do you need for an EMI license in Germany?

The application file centres on programme of operations listing each payment service you will provide; business plan with a three-year budget forecast; evidence of the €350,000 initial capital; governance arrangements and internal-control mechanisms; plus fit-and-proper evidence for directors and qualifying shareholders.

What is the application process for an EMI license in Germany?

Incorporate in the member state and establish real local substance (registered office and part of the business conducted there). Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies. The authority then assesses the file and, once authorised, you can begin operating.

Does an Germany EMI license work in other EU/EEA countries?

Yes: an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).

Timeline of decisions

  1. Law · official
    Act to Strengthen Financial Market Integrity (FISG) takes effect

    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

  2. Law · official
    Revised Payment Services Supervision Act (ZAG) implements PSD2

    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

  3. Law · official
    Second E-Money Directive transposed; e-money institution licence established

    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

Sources

  1. bafin.de/EN/Aufsicht/ZahlungsdienstePSD2/ZahlungsdienstePSD2_node_en.html
  2. bafin.de/EN/Aufsicht/ZahlungsdienstePSD2/ZulassungsverfahrenundLaufendeAufsich
  3. bafin.de/EN/unternehmen-maerkte/erlaubnis-registrierung/zahlungsdienste-zahlun
  4. bafin.de/EN/PublikationenDaten/Datenbanken/ZahlungsinstituteRegister/register_
  5. bundesbank.de/en/tasks/financial-supervision/individual-aspects/payment-institution
  6. bundesbank.de/en/tasks/payment-systems/tips/useful-information--937372
  7. berlin-group.org/psd2-access-to-bank-accounts
  8. twobirds.com/en/trending-topics/buy-now-pay-later-regulatory-tracker/germany
  9. bafin.de/EN/Aufsicht/MiCAR/MiCAR_node_en.html
  10. suerf.org/wp-content/uploads/2026/04/SUERF-Policy-Note-405_-Bergmann-Glowka.pdf
  11. twobirds.com/en/insights/2026/germany/bnpl-unter-aufsicht-was-das-neue-absfinag-fr
  12. bafin.de/EN/unternehmen-maerkte/erlaubnis-registrierung/geschaefte-krypto/kryp

Next for Germany: Digital Nomad & ResidencyVia other route

Next topic

Orientation, not legal advice: verify against the primary sources linked above. Last verified 12 Sept 2026. Methodology & how to cite · State of Technology Regulation 2026