MiCA CASP authorisation in Germany (BaFin)

At a glance

Regulator: BaFin
Typical timeline: ~6 to 18 months depending on prior German footprint
Transitional deadline: Closed (12-month window ended around 30 December 2025)
Fees: Fee-bearing procedure (amount not published), charged even on withdrawal
CASPs authorised so far: ~53 (largest in the EU)
Pre-MiCA experience: KWG crypto-custody licence; simplified route for legacy holders

As of June 2026; figures drift and transitional dates trace to the ESMA grandfathering list. Capital is set EU-wide by service class (€50,000 / €125,000 / €150,000), not by country. Compare member states on the jurisdiction comparison and confirm exact dates on the deadlines page.

Why teams look at Germany

Germany has supervised crypto custody longer than most EU regulators. BaFin has overseen a dedicated crypto-custody business licence under the German Banking Act since 2020, so it came to MiCA’s crypto-asset service provider regime, applying from 30 December 2024, with real experience of key-management and client-asset risk. Germany designated BaFin as its CASP authority through national implementing legislation.

BaFin is rigorous and methodical, and timelines reflect that. Germany is the right home for a firm that wants a heavyweight regulator and is prepared for a documentation-heavy, custody-focused review.

This page is informational and does not replace legal, regulatory, or tax advice. Confirm current requirements, forms, fees, and timelines directly with BaFin before acting.

The authorisation route

A firm that is not already an EU-authorised financial entity applies to BaFin for authorisation as a CASP under Article 62. A firm already authorised under EU financial law can use the lighter Article 60 notification.

Under Article 63 BaFin has 25 working days to confirm completeness and then 40 working days to decide once the file is complete. BaFin’s expectation of detailed, well-evidenced submissions means assembling a complete file is the slow part, and rushing it tends to extend the process.

What BaFin expects

Local substance

A registered office in Germany and management effectively based there under Article 59(2). BaFin looks for genuine local decision-making, not a nameplate.

Custody and client assets

Germany’s custody-licensing history means BaFin scrutinises key management, segregation, reconciliation, and the Article 75 loss-liability story closely. This is often the deciding part of a German file.

Governance and fit-and-proper

Collective crypto-asset competence and sufficient time under Article 68, with detailed checks on directors and qualifying shareholders.

Prudential safeguards

Own funds, an insurance policy, a comparable guarantee, or a mix under Article 67, at the higher of the class minimum or one quarter of fixed overheads.

Capital and the Article 67 question

The minimum is 50,000 euro, 125,000 euro, or 150,000 euro depending on the services you are authorised for, or one quarter of the previous year’s fixed overheads if higher. If you are weighing insurance against capital, build the evidence first: see the CASP insurance evidence pack and own funds vs insurance.

Coming from a crypto-custody licence

Firms holding the German crypto-custody business licence do not convert automatically to a CASP authorisation. They transition onto MiCA through a process BaFin manages, and Germany shortened its transitional window relative to the MiCA maximum. If you rely on an existing German crypto licence, confirm the current cut-off date and the exact transition steps with BaFin.

Transitional dates have moved at the member-state level. Confirm any date against current BaFin guidance before planning around it.

Rigorous by reputation

Germany’s process rewards preparation. The firms that move fastest through BaFin arrive with a custody and controls narrative that would survive a technical review, clean substance, and prudential safeguards they can evidence rather than assert.

FAQ

Is a Germany CASP licence valid across the EU?

Yes. A CASP authorisation passports to all 27 member states under Article 65. You authorise in Germany and notify the host states before providing services there.

Does my existing crypto-custody licence carry over?

Not automatically. It transitions through a BaFin-managed process within a shortened window. Confirm the current cut-off and steps with BaFin.

How long does it really take?

The legal decision clock is 40 working days after the file is complete, plus a 25 working day completeness check. Given BaFin’s expectations, preparing a complete file usually takes several months.