Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the BaFin decision, including banking and payment rails.
Get an EMI license in Germany.
The heavyweight route: a BaFin E-Geld-Institut authorisation under the ZAG carries more counterparty weight than any other payments licence in the EU, and opens Europe's largest economy. We build the German-language file and defend it through both supervisors.
27 yrs
on the international marketon the market
60+
in-house specialistsspecialists
400+
Licenses obtainedlicenses obtained
Updated
Germany in brief
The most credible stamp in European payments.
Germany licenses e-money institutions under the Zahlungsdiensteaufsichtsgesetz (ZAG) - the Payment Services Supervision Act - with BaFin granting the authorisation and the Deutsche Bundesbank sharing ongoing supervision. The formalities are exactly what you would expect: the application is filed in writing with BaFin (with the Bundesbank copied in), the file is prepared against BaFin's own published document tables, initial capital for an E-Geld-Institut is €350,000, and safeguarding must satisfy sections 17 and 18 of the ZAG before a single euro of client money moves. Payment-institution licences sit alongside at €20,000-€125,000 depending on services, and account information services need only registration.
The statutory clock is three months from a complete application, but German completeness is a higher bar than anywhere else in the EU, the file is in German, and realistic end-to-end timelines run 12-18 months. What you get for the effort is the licence banks, corporates and Mittelstand partners treat as near-bank grade, a public ZAG register entry, and passporting into every EU/EEA state from the largest payments market in Europe. With PSD3 and the PSR close to formal adoption, we structure German files to convert cleanly into the unified payment-institution regime.
The heavyweight route: BaFin authorises E-Geld-Institute under the ZAG - €350,000 capital, safeguarding per §§ 17-18, dual supervision with the Bundesbank.
Three months statutory, 12-18 realistic, file in German - priced against near-bank credibility and Europe's largest payments market.
The two routes
E-Geld-Institut - or the payment-institution tier.
BaFin authorises both under the ZAG: the full e-money institution at €350,000, and payment-institution licences from €20,000. With account information services on a registration-only track. We fix the scope first, then build once.
Full EMI at €350,000 - or PI tiers from €20,000 with registration-only AIS.
01 - E-GELD-INSTITUT (EMI)
E-money institution
The flagship ZAG authorisation: e-money issuance plus the full payment-services list, €350,000 initial capital, safeguarding under §§ 17-18 ZAG and EU/EEA passporting from Germany.
The flagship ZAG authorisation: e-money issuance plus the full payment-services list, €350,000 initial capital, safeguarding under §§ 17-18 ZAG and EU/EEA passporting from Germany.
- ✓E-money issuance and distribution
- ✓Full PSD2 payment-services list
- ✓€350,000 initial capital · own funds ongoing
- ✓Safeguarding per §§ 17-18 ZAG
- ✓EU/EEA passport on notification
- ✓Public ZAG register entry
02 - ZAHLUNGSINSTITUT · AIS ROUTES
Registration-only AIS trackPayment institution routes
Payment-institution licences run €20,000-€125,000 by service. Remittance to acquiring, and account information services require registration rather than full authorisation.
PI licences €20k-€125k by service; AIS registration without a capital floor; same ZAG register.
- ✓PI licences - €20k / €50k / €125k by service
- ✓Money remittance, acquiring, transfers
- ✓AIS - registration, no capital floor
- ✓Same ZAG supervision and register
- ✓Upgrade path to the EMI
- ✓Passportable across the EU/EEA
Costs and timelines are confirmed for your case before any work begins. BaFin charges fees per the statutory fee schedule plus the annual supervisory levy; capital, safeguarding and substance costs are itemised in your quote.
Why Germany
Weight, not speed - and worth it.
Nobody picks Germany for a fast licence. You pick it for what the stamp does afterwards: banking relationships, enterprise clients and the largest payments market in Europe.
✓
The BaFin stamp
A German ZAG authorisation is treated as near-bank grade by counterparties across Europe. Banking partners, enterprise clients and investors price the diligence BaFin already did for them.Near-bank grade for counterparties.
✓
Europe's largest market
The EU's biggest economy and payments volume pool. Issuing, acquiring and embedded-finance partnerships with German industry are the licence's real yield.Issuing, acquiring, embedded finance.
✓
Dual supervision
BaFin authorises; the Bundesbank shares ongoing supervision. Two institutions behind your register entry. Institutional depth no single-desk regulator matches.BaFin + Bundesbank behind the entry.
✓
Published expectations
BaFin publishes the application document tables, the register is public under §§ 43-44 ZAG, and the framework is statute, not discretion. Demanding, but knowable.Document tables and a public register.
✓
Embedded-finance economy
German industry is systematically outsourcing payments. White-label issuing, marketplace flows, B2B rails. A domestic licence puts you inside those procurement conversations.Inside German industry's procurement.
✓
PSD3-ready files
With PSD3/PSR close to adoption, e-money folds into the unified payment-institution regime. We structure German files to convert rather than be rebuilt.Built to convert, not rebuild.
How it compares
How Germany differs from other routes.
Germany trades speed and cost for counterparty weight and market size. The side-by-side comparison is below.
Germany vs other jurisdictions
| Feature |  Germany | Other jurisdictions |
|---|---|---|
| Regulatory regime | ZAG - BaFin + Bundesbank | Same directives, single desks |
| Counterparty weight | Near-bank grade | Varies by supervisor |
| Language of the file | German | Usually English |
| Timeline | 12-18 months realistic | 6-12 at specialised desks |
Regulatory regime
GermanyZAG - BaFin + Bundesbank
Other jurisdictionsSame directives, single desks
Counterparty weight
GermanyNear-bank grade
Other jurisdictionsVaries by supervisor
Language of the file
GermanyGerman
Other jurisdictionsUsually English
Timeline
Germany12-18 months realistic
Other jurisdictions6-12 at specialised desks
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Germany | EMI (BaFin) | ~30-33% effective | German file, dual supervision |
 Lithuania | EMI (Bank of Lithuania) | 17% CIT (2026) | CENTROlink, specialised desk |
 Ireland | EMI (CBI) | 12.5% CIT trading | Engagement-led, 12+ months |
 Malta | EMI (MFSA) | ~5% effective | English file, slower queue |
GermanyLicense typeEMI (BaFin)
Taxation~30-33% effective
RequirementsGerman file, dual supervision
LithuaniaLicense typeEMI (Bank of Lithuania)
Taxation17% CIT (2026)
RequirementsCENTROlink, specialised desk
IrelandLicense typeEMI (CBI)
Taxation12.5% CIT trading
RequirementsEngagement-led, 12+ months
MaltaLicense typeEMI (MFSA)
Taxation~5% effective
RequirementsEnglish file, slower queue
Before you apply
Requirements for the BaFin authorisation.Requirements for the authorisation.
BaFin publishes the application's document tables. The craft is assembling a file that survives two supervisors' scrutiny in German. The checklist below is what a passing application contains.
01
German entity. A GmbH or AG with its head office and management in Germany.
02
Initial capital - €350,000 for the EMI, evidenced and paid in; €20,000-€125,000 for PI tiers.
03
Two qualified managing directors. Fit and proper Geschäftsleiter with payments experience, vetted individually.
04
Programme of operations. Services, volumes, three-year financials and unit economics both supervisors can interrogate.
05
Transparent ownership. Holders of qualifying participations disclosed and assessed to UBO level.
06
Safeguarding. Client-fund segregation or insurance satisfying §§ 17-18 ZAG, with documented reconciliation.
07
AML/CFT framework. GwG-compliant KYC, monitoring and FIU reporting with a resident MLRO.
08
IT and security documentation. Architecture, DORA-grade resilience and incident procedures.
09
Internal governance. Control functions, outsourcing register and conflicts procedures.
10
German-language file. The application and annexes drafted and defended in German.
01
German GmbH/AG, managed locally.
02
€350,000 capital (EMI).
03
Two fit & proper Geschäftsleiter.
04
Interrogable programme of operations.
05
Ownership transparent to UBOs.
06
Safeguarding per §§ 17-18 ZAG.
07
GwG AML with resident MLRO.
08
DORA-grade IT documentation.
09
Governance and outsourcing register.
10
Full file in German.
Reflects the ZAG, BaFin's published application tables and the German Fees Regulation as of 2026.ZAG + BaFin application tables, as of 2026.
How it works
From first call to the ZAG register.
01
Route and strategy
EMI, PI tier or AIS registration. We fix the scope, capital and timeline in writing before any drafting.EMI, PI or AIS - in writing.
02
German company and people
GmbH formation, capital evidence and the two Geschäftsleiter both supervisors will vet.GmbH, capital, two directors.
03
The application file
Programme, safeguarding, AML and IT documentation per BaFin's tables. Complete and in German before filing, because completeness is the timeline.Complete, in German, before filing.
04
BaFin & Bundesbank review
Three months statutory from complete, question rounds answered in German - 12-18 months realistic end to end.3 months statutory; 12-18 realistic.
05
Authorisation and launch
The ZAG register entry, passport notifications and the reporting calendar. Live in Europe's largest market.Register entry, passports, reporting.
Quick facts
RegulatorBaFin + Bundesbank
EMI capital€350,000
PI tiers€20k / €50k / €125k
AISRegistration only
Statutory review3 months from complete
Realistic timeline12-18 months
File languageGerman
PassportEU/EEA on notification
The German bar is completeness in German, twice over. Arriving complete is the entire game, and our job.
On the ground in Germany
Run from our Frankfurt office.
Prifinance - Germany
Frankfurt · Germany
Frankfurt, Germany
01
German company formation
GmbH or AG incorporation, capital placement and the corporate layer BaFin expects. Structured for the licence from day one.GmbH + capital, structured for the file.
02
The ZAG file - in German
Programme of operations, safeguarding design, AML pack and IT documentation drafted against BaFin's published tables, in German, and defended through both supervisors' question rounds.Drafted natively, defended in rounds.
03
BaFin & Bundesbank interaction
Filing, completeness management and every supplementary round handled for you. With local counsel where German court-certified documents are required.BaFin and Bundesbank, handled.
04
Substance and staffing
Resident Geschäftsleiter search, MLRO and compliance hiring, office and banking setup. Real German substance, assembled to survive supervision.Directors, MLRO, office - real substance.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
London
United Kingdom
7 Bell Yard
Dubai
UAE
33 Level, Al Saqr Business Tower
Madeira
Portugal
Rua da Alegria 31, 1F
Budapest
Hungary
Korányi Sándor u. 4
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in Germany.
Germany is not a low-tax play: roughly 30-33% effective corporate burden, with the municipal trade-tax seat the one real lever. What it buys is treaty depth and the home market itself.
Corporate tax ~15.8%
15% corporation tax plus the 5.5% solidarity surcharge. The federal layer on an EMI's fee and float income.15% + 5.5% solidarity surcharge.
Trade tax ~14-17%
The municipal layer varies meaningfully by seat. Berlin, Frankfurt and Munich differ, so the registered office is a modelling decision, not an afterthought.Municipal. The seat matters.
~30-33% effective total
The combined burden puts Germany at the top of the EU range. Priced against direct access to the largest payments market in Europe.Top of the EU range, biggest market.
VAT-exempt payment services
Payment and e-money services are VAT-exempt financial services; the 19% standard rate touches only ordinary supplies.19% only on ordinary supplies.
Dividends 26.375%
25% withholding plus solidarity surcharge, reduced by treaties and eliminated intra-EU under the Parent-Subsidiary Directive for qualifying holdings.Treaty and EU-directive relief.
Treaty network 90+
One of the deepest treaty networks in the world. Group structures above the German entity model cleanly.Deepest network in Europe.
Tax summary
Corporation tax15% + 5.5% soli
Trade tax~14-17% municipal
Effective total~30-33%
VAT on payment servicesExempt
Standard VAT19%
Dividend withholding26.375% · treaty/EU relief
Tax treaties90+
*Figures as of 2026. Trade tax varies by municipality. We model the seat before you commit.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: German GmbH, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, authorised institution.
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Germany · BaFin
Launch your payment project in Germany with expert support.
Full-service assistance - from GmbH registration to the ZAG authorisation, passporting and ongoing compliance.
Get a consultation →Free legal opinion
Is Germany the right fit for your project?
Our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.
Written assessment within 2-5 business days
Request a free conclusion →FAQ
The German EMI licence: quick answers.
What licence does an e-money business need in Germany?+
An E-Geld-Institut authorisation from BaFin under the ZAG - €350,000 initial capital, safeguarding per §§ 17-18 and EU/EEA passporting. Payment-institution licences (€20,000-€125,000) and registration-only account information services sit alongside.
Who supervises - BaFin or the Bundesbank?+
Both. BaFin grants the authorisation and leads; the Deutsche Bundesbank shares ongoing supervision. The application itself is filed with BaFin with the Bundesbank copied in - two institutions read your file.
How long does licensing take?+
Three months statutory from a complete application, but German completeness is the EU's highest bar and the file is in German. Realistic end-to-end: 12-18 months. Completeness is our job.
Is the application really in German?+
Yes - the file, annexes and question rounds run in German. We draft natively rather than translating afterwards; it is one of the main reasons founders bring us the mandate.
What does it cost?+
BaFin charges fees under the statutory fee schedule plus an annual supervisory levy after authorisation. The real investment is capital (€350,000), substance and the file - all itemised in your quote before we start.
What substance is expected?+
A German GmbH or AG managed from Germany, two fit-and-proper Geschäftsleiter, a resident MLRO reporting under the GwG, real safeguarding arrangements and DORA-grade systems documentation.
How are payment companies taxed?+
Roughly 30-33% effective: 15% corporation tax plus solidarity surcharge and municipal trade tax of ~14-17% depending on seat. Payment services are VAT-exempt; dividends carry 26.375% withholding with treaty and EU relief.
Does the licence passport across the EU?+
Yes - the ZAG authorisation passports to every EU/EEA state on notification, from the largest home market in the Union.
What changes under PSD3?+
PSD3 and the PSR - provisionally agreed in November 2025 and close to formal adoption - fold e-money institutions into a unified payment-institution regime. Files we build now are structured to convert.
Why Germany rather than Lithuania?+
Different products. Lithuania sells speed, CENTROlink and startup economics; Germany sells counterparty weight and the German market itself. Enterprise-facing and embedded-finance models often need the BaFin stamp - many groups eventually hold both.
What licence is needed?+
BaFin E-Geld-Institut - €350k; PI €20k-€125k.
Who supervises?+
BaFin authorises; Bundesbank co-supervises.
How long?+
3 months statutory; 12-18 realistic.
German file?+
Yes - we draft natively.
Cost?+
Statutory fees + levy; capital is the investment.
Substance?+
Two directors, MLRO, real German ops.
Taxes?+
~30-33% effective; VAT-exempt services.
Passport?+
EU/EEA on notification.
PSD3?+
Agreed Nov 2025 - files convert.
Vs Lithuania?+
Speed there; weight and market here.
Client notes
Google4.7★★★★★
Founders who wanted it done right.
Google4.7★★★★★
“As a software development crew at FewMoreTaps OÜ, we've had the pleasure of working with Prifinance on some key financial moves.First of all, navigating the world of corporate banking and finance can be a maze, but Prifinance made it feel like a walk in the park. They helped us set up a corporate bank account without the hassle of jumping on a plane or drowning in paperwork. Everything was done remotely, smoothly…”
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Google
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Get a free legal opinion on your project - our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.Free legal opinion: which German route fits your project and what it will cost.
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of BaFin, the Deutsche Bundesbank or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.