Obtaining license for electronic money in Germany | Law&Trust International

License for electronic money in Germany

The procedure for registering an electronic money operator in the German financial sector is provided for in the Law on banking and requires the approval of the Federal Financial Supervisory Agency.

The law divides operators into credit and financial institutions (Article 1a), which differ in that the first ones can conduct credit operations, while the second ones can not.

In addition to the regular requirements in accordance with Article 25n of the Law, electronic money providers undergo a special procedure to verify compliance with the requirements of anti-money laundering policy.

The legal form excludes private entrepreneurship and complicates activities in the form of partnerships, under which each "reliable partner" should obtain individual license.

Thus, it is better to register the company that provides electronic payment services in the organizational and legal form of joint-stock company or limited liability company, necessarily with the head office in Germany.

Electronic money in Germany are considered as any medium with a monetary value, having electronic form, in the form of a requirement for an emitent issued in exchange for contribution of a cash amount for conducting payment and also accepted by other parties other than the emitent.

Therefore, the companies issuing them are subject to the Law on the Supervision of Payment Services. The license to provide payment services is included in the license for transactions with electronic money.

Licensing of such activities must be carried out on the basis of paragraph 1 of §8a of the Law on the Supervision of Payment Services.


In order to obtain license, the company is obliged to provide business model, business plan and financial plan for three years, indicating the sources of compliance with §13 of the Law on the Supervision of Payment Services, namely.

The Federal Agency

may issue permission only if the following mandatory requirements are fulfilled:


  • The applicant shall be a legal entity (§9, paragraph 1 of the Law on the Supervision of Payment Services).

  • The application should contain sufficient information and documents (§9, paragraph 2 of the Law on the Supervision of Payment Services).

  • Resources, required for business transactions, in particular sufficient initial capital, should be available (§9, paragraph 3 of the Law on the Supervision of Payment Services). For payment institutions that provide only electronic payment services, minimum amount of 50,000 euros is required.

  • Among the requirements for the authorized capital of the Law on the Supervision of Payment Services, there is the requirement in § 12a that the authorized capital shall be in reasonable proportion with the extent of services provided.

For this purpose, the Federal Agency, when considering the issue of granting authorization, applies three methods (methods "B" and "C" are mainly for operating enterprises), namely:

  • The authorized capital should be equal to 10% of planned expenditures for the first year of activity;

  • The scaling factor is applied to the extent of services provided, with a factor of about 0.5%, where, as a result of calculations, it is possible to end up with approximately 12% of gross income (in this case, the amount of the authorized capital can be agreed upon during consultations with the Federal Agency before providing business plan);

  • This method corresponds to method "B", but another scaling factor is used, as a result of which the need for capital is calculated from at least 80% of such percentage ratio as capital/turnover of previous periods (average proportions for three fiscal years, depending on fluctuations in working capital). In the model calculation according to this method, the regulator comes to the value of the authorized capital in the amount of 1 million 200 euros with the turnover of 47 million euros;

  • In the context of abovementioned, the requirement of article 57 (A and B) of Directive 2006/48/EC concerning the fact that the initial capital of the electronic money provider shall exceed 350,000 euros (the minimum was previously equal to 1 million euros) should be noted. Thus,it will not be lesser taking into account any calculations;

  • After the company obtains license (under the terms of ‘license’, there is an administrative service for permission to conduct activities valued up to 15 000 euros for the category of "electronic money and electronic settlements" as indicated in paragraphs (1) and (2) of the Law on the Supervision of Payment Services), on the basis of para. of the Regulations on Administrative Services of the Federal Financial Supervisory Agency, it shall be included into the Public Register of Authorized Electronic Money Institutions and can operate.

The cost of license is not final and definitive, and in case of expanding the range of activities, additional administrative services will be required for each of them.
Our principles are legality, confidentiality and reliability.
The services of the operator of electronic payment systems are advantageous and promising international business. If you want to quickly obtain license in order to provide non-bank financial services in Germany, feel free to contact Law&Trust International. Experience and professionalism of our company's specialists will guarantee your success in the market of electronic financial services.
Our main priority is your comfort. Therefore, we undertake all procedures provided for by the rules for obtaining license. And you receive service from us accomplished on a turnkey basis.

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