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title: "Germany Crypto Regulation Monitor | cryptoassets.gi"
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description: "Germany crypto asset regulation: 9 categories, 59 sourced findings, updated 2026-11-03. Licensing, token classification, stablecoins, tax treatment."
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# Germany Crypto & Digital Asset Regulation

schema crypto-v2.0.0
trajectory: not yet assessed regulated overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/germany/), [World Payments](https://payments.gi/jurisdictions/germany/)

Last updated 2026-11-03 · 9 categories · 59 sourced
findings · 72 sources in the cumulative register

Download report (PDF) Expand all

Evidence re-verified: 2026-11-03 · Position last changed: 2026-11-03 · Record history & provenance ▾ Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26

[Open in Co-Pilot ↗](/reports/?type=copilot&j=GERMANY)[Build Report](/reports/?j=GERMANY)[Compare](/compare/?j=GERMANY)

Framework posture Regulated 8 of 9 modules populated · AI-synthesised · Tier-1/2 verified

Lead supervisory authority Boerse Stuttgart Digital Primary statutory & supervisory perimeter

Next milestone (> 2026-10-26) 2026-Q4 MiCA review: ESMA supervisory-scope narrowing and DeFi-liability proposal

Module coverage & confidence 8 / 9 modules assessed 0 Confirmed · 8 Probable · 0 Uncertain · 1 Not yet assessed

9 Categories

0 Moved this cycle 0 Key judgments 1 Open gaps 59 Findings

6 Tier-1 sources

Confidence mix 9 unpopulated
(sums to 9 rendered categories; click to filter)

No categories moved this cycle.

Law made at European Economic Area (Bloc) level that applies in Germany is covered once, on the [European Economic Area (Bloc)](/jurisdictions/european-economic-area-bloc/) page. This page covers Germany’s own layer: implementation, national authorities, national options and local enforcement.

## Jurisdiction lead brief

###### Latest update · 23 October 2026

#### Lead Signal

Germany's crypto-asset licensing landscape moved on two fronts this period, both stemming from the European Union's Markets in Crypto-Assets Regulation framework rather than from any German-specific legislative change. On 9 October 2026, EU finance ministers reached agreement, reported in trade press on 21 to 22 October, to confine direct supervision by the European Securities and Markets Authority to only the largest crypto-asset service providers, an estimated 10 to 15 firms out of roughly 360 registered across the EU. The remaining providers, including Germany's cohort of approximately 100 BaFin-supervised firms, the largest national cohort in the bloc, remain under national supervision rather than transitioning to EU-level oversight in the near term.

This outcome preserves BaFin's existing supervisory role over the great majority of German crypto-asset service providers, avoiding what would otherwise have been a significant near-term transfer of supervisory burden and relationship management to the EU level. For firms already authorised under the Markets in Crypto-Assets Regulation and supervised by BaFin, the agreement means continuity of their existing national supervisory relationship rather than an imminent shift to a new regulator.

#### Other Developments

BaFin amended its warning against a series of near-identical unauthorised crypto-asset-service websites. On 20 October 2026, the regulator updated a consumer warning first issued earlier in the year, continuing to flag a repeating pattern of near-identical websites suspected of offering crypto-asset services without the required licence or authorisation, with customer data reportedly passed to unsupervised trading-platform operators. This is a continuation of an existing enforcement posture against unlicensed solicitation rather than a new typology, and reflects BaFin's ongoing consumer-protection role alongside its licensing function.

A French-authorities proposal on DeFi liability was put to the European Commission. Reported alongside the ESMA supervisory-scope agreement, a proposal from French authorities would introduce liability for centralised crypto-asset service providers in certain scenarios where client losses occur through access to decentralised finance protocols. The underlying consultation closed on 30 September 2026, and the proposal remains at a preliminary stage with no binding effect yet on German-authorised CASPs.

#### Cross-Monitor Connections

The ESMA supervisory-scope agreement is a structural development in the EU's crypto-asset regulatory architecture, and its effect of leaving the bulk of German CASPs under BaFin rather than EU-level supervision has implications for how national AML and financial-crime oversight of the sector will continue to function in the near term, since supervisory continuity at the national level also means continuity of the existing reporting and cooperation channels between BaFin and other German authorities. The unauthorised-website warning similarly intersects with broader unlicensed-financial-activity enforcement patterns that recur across sectors beyond crypto specifically.

#### Outlook

The confinement of direct ESMA supervision to the largest CASPs is reported as an agreement rather than as finalised legislative text, so the precise scope and implementation mechanism remain to be settled through the ongoing Markets in Crypto-Assets Regulation review process, expected to develop further toward the end of 2026. Germany's roughly 100 BaFin-supervised CASPs should, on present indications, expect continuity of national supervision rather than an imminent transition, though the DeFi-liability proposal remains a thread worth tracking as the Commission's consultation process progresses.

4 earlier updates not shown here.

###### Standing brief · as of 2 August 2026

Written before the update above. Where they differ, the update is the more recent position.

#### Lead Signal

Germany's crypto regulatory perimeter completed a meaningful phase transition this cycle. The Kryptomarkteaufsichtsgesetz shortened Germany's own national MiCA/KWG grandfathering window to twelve months, with national transitional authorisations closing on 31 December 2025 -- six months ahead of the EU-wide Article 143(3) backstop of 1 July 2026. That earlier German closure operated separately from the EU-wide deadline: it was the later EU-wide backstop, not Germany's own closure, that forced firms relying on other member states' transitional windows -- most visibly Binance, which entered 1 July 2026 without MiCA authorisation after withdrawing its Greek license application and warned EU customers of service suspensions. Germany itself enters this period from a position of strength: BaFin has authorised 57 CASPs under MiCA as of mid-2026, more than double the next-placed member states (France and the Netherlands, 26 each), reflecting an already-mature national licensing pipeline built on the pre-existing KWG custody regime. The net effect is a German market fully inside the harmonised EU regime while a major global competitor is currently locked out of it -- a competitive-dynamics signal as much as a compliance one.

#### Other Developments

BaFin's licensing activity continues to broaden the range of regulated crypto business models available in Germany. Boerse Stuttgart Digital, which received an early MiCA CASP authorisation in January 2025, has since expanded into institutional staking through its BaFin-licensed subsidiary Blocknox. BitGo Europe now bundles custody, staking and trading under a single license, following a pattern already set by Coinbase and Kraken. DZ Bank's meinKrypto retail platform has launched on an explicitly execution-only, non-advisory basis, distinguishing self-directed retail trading from the bank's advised investment services -- a conduct-of-business distinction consumer protection supervisors are likely to watch as mainstream banks move into retail crypto distribution.

On the stablecoin side, AllUnity's EURAU launched in mid-2025 as a BaFin-licensed e-money token backed by a consortium of European bank reserve custodians with routine proof-of-reserve disclosures. The issuer's own framing of EURAU as the 'first' MiCA-compliant euro stablecoin, however, rests on a single news account of the issuer's own hedged claim rather than independent confirmation from BaFin or EBA registers, and that specific framing has accordingly been downgraded to Probable confidence pending primary-source verification -- the reserve-custody arrangement itself is better evidenced and unaffected by the downgrade.

Enforcement activity remains visible on both the licensing and AML fronts: BaFin seized 13 unlicensed crypto ATMs across 35 locations, confiscating close to EUR 250,000 in cash, on the basis that unlicensed euro-crypto exchange constitutes banking business requiring a BaFin license and posed money-laundering risk; separately, BaFin publicly warned that the exchange Rtcoin was not authorised to operate in Germany. On tax treatment, Germany's 2022 BMF nationwide guidance -- exempting individual BTC/ETH disposals from capital gains tax after a one-year holding period, and confirming that staking or lending does not reset that holding-period clock -- remains the operative reference point, though no post-2022 update has been independently confirmed for the 2026 tax year, and an older 2014-era BMF position on VAT treatment of commercial bitcoin sales remains unreconciled with the EU's Hedqvist precedent.

#### Cross-Monitor Connections

Two overlap threads are worth tracking outside this monitor. On the financial-integrity side, Germany's CASP population sits fully inside the EU Travel Rule regime under Regulation (EU) 2023/1113, with MiCA-authorised CASPs subject to the same AML/CFT supervision as credit and financial institutions; Germany's 2022 FATF Mutual Evaluation found good institutional understanding of ML/TF risk among larger VASPs and banks, while also flagging room for BaFin to take a more proactive supervisory posture toward unlicensed money/value transfer providers, including hawala-type operators. Germany's AWG sanctions-freezing framework, which prohibits making funds or economic resources available to designated persons as soon as an EU sanctions listing is published, sits alongside this AML architecture.

On the world-payments side, MiCA passporting allows any BaFin-authorised CASP to operate across all 27 EU member states from a single German authorisation, and AllUnity's EURAU is explicitly positioned to serve regulated instant cross-border euro payments for financial institutions, fintechs and corporates -- a use case that, if practical adoption grows, would put a BaFin-licensed euro-denominated instrument directly into cross-border payment-rail conversations that world-payments monitoring already tracks.

#### Outlook

The most consequential open question is not domestic to Germany but EU-wide: how the Article 143(3) backstop plays out for firms like Binance across the remaining member states, and whether the resulting authorisation vacuum reshapes market share among BaFin-licensed incumbents such as Boerse Stuttgart Digital, Bitpanda, Bullish Europe, BitGo Europe and DZ Bank. Domestically, several evidentiary gaps remain open for the next cycle: whether BaFin has articulated a clearer licensing posture for DeFi protocols and node/validator operation outside the CASP perimeter; whether the BMF has updated its nationwide tax guidance since 2022, particularly for the 2026 tax year; and whether EURAU's 'first-of-kind' issuance claim can be corroborated against BaFin's or EBA's own registers rather than resting on issuer-supplied framing. Until those points are independently confirmed, this record remains held pending further evidentiary work rather than published at full confidence.

Read full brief · 1374 words

Key regulatory facts for Germany Regulatory Dimension Germany Standing Position

Jurisdiction Germany (DE)

Regulatory Scope Crypto & Digital Asset Regulation (9 modules, 59 sourced findings)

Crypto Licensing Germany implements MiCA via FinmadiG and KMAG, bridging prior national VASP licensing to the MiCA CASP regime under BaFin; the standard 18-month CASP transition window was compressed to a hard 12-month/31 December...

Token Classification Germany follows the MiCA taxonomy: asset-referenced tokens (ARTs), e-money tokens (EMTs), and other crypto-assets, with BaFin as the national competent authority applying EU-level classification guidance including...

On-Chain Activity Regime Germany permits regulated staking and custody activity through BaFin-licensed entities under the KWG crypto custody regime and, since December 2024, under MiCA's CASP ancillary-services framework.

Stablecoin Regime BaFin authorises ART/EMT issuance under MiCA and has taken active enforcement action against non-compliant stablecoin issuers, including the EU's first MiCA-related cease-and-desist action (March 2025); Ethena Labs...

Primary Instruments Cited Boerse Stuttgart Digital, Germany (BaFin), MiCA transitional regime (EU-wide), BaFin, Binance

Last Confirmed / Updated 2026-11-03 (72 sources in cumulative register)

9 of 9 categories

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### Germany: C1 Crypto LicensingGreenEnacted in forceModule confidence: Probable▾

Germany implements MiCA via FinmadiG and KMAG, bridging prior national VASP licensing to the MiCA CASP regime under BaFin; the standard 18-month CASP transition window was compressed to a hard 12-month/31 December 2025 deadline, stricter than most EU peers.

Open gap — crypto-int-1 ZAG/KMAG instrument-layer search for crypto-specific amendments was not run this cycle beyond the MiCAR CASP authorisation guidance check; a more targeted search of BaFin's crypto-licensing register would improve coverage. no under-indexing note recorded

Horizon · 2026-Q4 (± six months) MiCA review: ESMA supervisory-scope narrowing and DeFi-liability proposal Consultation · Tier 2 source

#### Crypto Licensing

Germany operates a fully-applying MiCA licensing regime layered onto a pre-existing national supervisory architecture, and BaFin's activity level under that regime is now a distinguishing feature of the German market rather than merely a compliance milestone. As of mid-2026, BaFin had granted CASP authorisation to 57 firms, more than double the count in France or the Netherlands (26 each), reflecting a pipeline built up over the preceding eighteen months of MiCA implementation and reinforced by BaFin's long institutional experience running the pre-MiCA KWG crypto-custody licensing regime. That KWG regime was itself demanding in practice: an earlier rollout of custodian licensing saw BaFin receive 25 custodian applications and approve only four in the early going, establishing a reputation for rigorous vetting that appears to have carried through into MiCA-era CASP authorisation.

The most significant licensing-perimeter development this cycle concerns the interaction between Germany's own national transitional arrangements and the EU-wide MiCA transitional backstop. Under the Kryptomarkteaufsichtsgesetz (KMAG) section 50(2) No. 3, Germany shortened its own national MiCA/KWG grandfathering window to twelve months, closing national transitional authorisations on 31 December 2025. This is a full six months earlier than the EU-wide Article 143(3) backstop of 1 July 2026, under which member states could permit existing licensed or registered providers to continue operating under national law at the latest until that later date. The distinction matters because it was the EU-wide 1 July 2026 backstop -- not Germany's own earlier national closure -- that forced firms relying on transitional windows in other member states to wind down EU-facing activity absent MiCA authorisation. Binance is the clearest illustration: having withdrawn its Greek MiCA license application, Binance entered 1 July 2026 without MiCA authorisation and told customers in several EU countries it would suspend some services. Germany's own transitional population had already been resolved six months earlier under the national KMAG deadline, meaning the domestic German market was not directly exposed to the same July 2026 cliff-edge that affected Binance's EU-wide footprint.

BaFin's licensing reach now extends across a widening range of institutional entrants. Boerse Stuttgart Digital secured an early MiCA CASP authorisation in January 2025, permitting EU-wide passported crypto-asset services. BitGo Europe, DZ Bank and other domestic and international firms have followed with their own authorisations, several bundling custody, staking, and trading activity under a single license rather than segregating these into separate permissions. Enforcement activity under the licensing perimeter has also continued: BaFin's characterisation of euro-crypto exchange as banking activity requiring a license underpinned its seizure of 13 unlicensed crypto ATMs across 35 locations, on the basis that the operators lacked the required permission.

#### Outlook

The licensing narrative for Germany going into the next cycle turns less on domestic developments -- the German national transitional window is now closed and the MiCA authorisation base is mature and comparatively large -- and more on how the EU-wide Article 143(3) backstop reshapes the competitive landscape among CASPs operating cross-border into Germany via passporting. Whether Binance or other unauthorised global exchanges secure MiCA authorisation elsewhere in the EU and re-enter the German market via passporting, and whether BaFin's authorisation pace continues to outstrip peer regulators, are the two developments most likely to move this module's traffic-light assessment in either direction.

Read full sub-brief · 536 words Periodic update · new data 2026-10-23

#### Crypto Licensing

Germany's crypto-asset licensing regime operates under the EU's Markets in Crypto-Assets Regulation, with BaFin as the national supervisory authority for the great majority of registered crypto-asset service providers. The most significant development this period is not a German-specific rule change but an agreement reached by EU finance ministers on 9 October 2026, reported in trade press on 21 to 22 October, to confine direct supervision by the European Securities and Markets Authority to only the largest crypto-asset service providers, estimated at 10 to 15 firms out of around 360 registered across the European Economic Area. This leaves the remaining providers, including Germany's approximately 100 BaFin-supervised firms, the largest national cohort anywhere in the bloc, under continued national rather than EU-level supervision.

The practical effect for German-authorised crypto-asset service providers is continuity: the agreement, while still at the stage of a political agreement rather than finalised legislative text, indicates that the overwhelming majority of German firms will retain BaFin as their direct supervisor for the foreseeable future rather than transitioning to a centralised EU regulator. This preserves existing supervisory relationships and the associated reporting, inspection and enforcement channels that have developed under BaFin's national administration of the Markets in Crypto-Assets Regulation to date.

Alongside the supervisory-scope agreement, BaFin on 20 October 2026 amended an existing consumer warning concerning a series of near-identical websites suspected of offering crypto-asset services without the required licence or authorisation, with customer data reportedly passed on to unsupervised trading-platform operators. This action continues BaFin's standing enforcement posture against unlicensed solicitation and does not reflect any change to the licensing framework itself, but it illustrates the regulator's parallel role in policing the boundary between licensed and unlicensed crypto-asset activity even as the supervisory architecture above licensed firms is adjusted at the EU level.

A further, more preliminary development reported alongside the ESMA agreement is a proposal from French authorities, put to the European Commission following a consultation that closed on 30 September 2026, that would introduce liability for centralised crypto-asset service providers in certain scenarios involving client losses connected to decentralised finance protocol access. This proposal remains at a consultation-adjacent stage and has no binding effect on German-authorised providers at this time, but it is a thread within the broader Markets in Crypto-Assets Regulation review process that could, if adopted, extend the liability perimeter for licensed CASPs operating in Germany and elsewhere.

#### Outlook

The ESMA supervisory-scope agreement remains a political agreement rather than adopted legislative text, so its precise mechanics, including the threshold for designating a firm as among the largest providers subject to direct EU supervision, are still to be settled through the ongoing review process. For the near term, Germany's licensing landscape should be read as stable in its national-supervision character, with BaFin continuing to administer the Markets in Crypto-Assets Regulation for the bulk of registered firms. The DeFi-liability proposal and the broader review process are worth tracking as they develop toward the end of 2026, though neither has yet produced a binding change to the licensing regime German CASPs operate under.

4 earlier distinct update(s) Periodic update · new data 2026-10-18

#### Crypto Licensing

BaFin's refusal of futurum bank AG's MiCAR crypto-asset service provider (CASP) authorisation application is the material licensing event of this cycle for Germany. The application, filed 27 June 2025, was refused in a decision disclosed on 6 October 2026, more than fifteen months after filing. Notably, the public record for this refusal currently rests entirely on Bitcoin Group SE's own mandatory ad-hoc disclosure as futurum bank's parent; no BaFin-published primary enforcement or decision notice has been independently located for this specific refusal as of this cycle. This is an evidentiary gap worth flagging explicitly: the fact of the refusal is well-attested through a regulated issuer's own disclosure obligations, but the detailed grounds for refusal are not yet independently confirmed from the regulator's own published record.

The refusal ends the toleration (Duldung) arrangement under which futurum bank had continued to provide crypto-asset services, chiefly via the Bitcoin.de platform, while its authorisation application remained pending. This toleration mechanism itself reflects a specific feature of Germany's implementation of the MiCA transition: Germany shortened its own national grandfathering period under MiCA Article 143(3) to end on 31 December 2025, six months ahead of the EU's outer limit of 1 July 2026, after which unauthorised provision of CASP services becomes unlawful in Germany. Exact citation to the specific national legislative provision fixing this earlier date (within the KMAG/FinmadiG package) has not been independently verified against the statutory text this cycle, and this remains sourced to a secondary legal-commentary source rather than the primary instrument itself.

The underlying licensing framework itself remains unchanged and well-settled: crypto-asset services in Germany require either BaFin authorisation under MiCAR Article 59 or a valid notification under Article 60 for entities already authorised in an equivalent regulated capacity elsewhere. This is a standing EU-wide standard applied consistently through BaFin's own published guidance, and nothing in this cycle's events alters that baseline. What has changed is the demonstrated consequence of that framework reaching the end of a national transition period: a platform carrying more than 1.1 million registered users has now had its toleration arrangement withdrawn following an unsuccessful authorisation application, converting what had been a theoretical end-of-transition risk into an observed regulatory outcome.

#### Outlook

Two specific procedural developments would materially change how this refusal should be read going forward. First, whether futurum bank has lodged, or lodges, a formal appeal (Widerspruch) against the refusal within the one-month window typically available under German administrative procedure; this was not established as of this cycle. Second, whether BaFin publishes its own primary notice regarding the refusal and its grounds, which would substantially strengthen an evidentiary record that currently depends on a single corporate disclosure. Absent either development, the refusal's precise legal and factual basis remains less transparent than its commercial consequences would suggest is warranted.

Periodic update · new data 2026-10-04

#### Crypto Licensing

Germany's national transitional arrangement for crypto-asset service providers has closed. Under KMAG Section 50, the national grandfathering protection ('Bestandsschutz') available to pre-MiCA crypto-asset service providers expired at the latest on 31 December 2025, a date set deliberately ahead of the EU-wide outer limit of 1 July 2026 permitted under MiCA Art 143(3). This means that, as of this cycle, any crypto-asset service provider continuing to operate in Germany must hold either a full MiCA CASP authorisation issued by BaFin or a valid passport obtained from another EU or EEA member state; there is no longer a national fallback legal basis available to firms that have not completed one of those two routes.

The authorisation regime itself carries a tiered capital structure under MiCA Art 59, as implemented by BaFin. Class 1 authorisation, covering the most basic crypto-asset services, requires minimum own-funds capital of EUR 50,000. Class 2 authorisation, which extends to custody and administration of crypto-assets on behalf of clients and to exchange services, requires EUR 125,000. Class 3 authorisation, which extends further to the operation of a trading platform for crypto-assets, requires EUR 150,000. This graduated structure ties the capital requirement directly to the risk and complexity of the licensed activity, with custody and trading-platform operation treated as materially higher-risk than basic Class 1 services.

Secondary reporting associates Germany's earlier-than-EU-mandated transitional cutoff with a resulting concentration of CASP authorisations: Germany is reported to hold the largest population of MiCA CASP authorisations in the EEA as of September 2026. The precise figure is not settled; cited counts range from approximately 53 to approximately 91 depending on the source and date consulted, and neither figure has been checked against the European Securities and Markets Authority's own CASP register this cycle. This divergence should be read as a research-completeness gap rather than as evidence of instability in the underlying licensing framework itself, which appears to be functioning as a mature, in-force regime rather than one still working through transitional ambiguity.

On enforcement, BaFin holds broad powers under KMAG, including the ability to prohibit unauthorised business activity, to order searches of business premises, to order the wind-down of non-compliant operations, and to impose administrative fines. These powers position BaFin as a supervisor with meaningful operational reach over the authorised population, consistent with a mature licensing regime rather than one still reliant primarily on registration and light-touch oversight. However, the exact maximum fine amounts available under the consolidated KMAG statute text were not confirmed against primary legislative sources this cycle; this is an open verification item rather than a finding that penalty ceilings are absent or unclear in the statute itself.

Taken as a whole, Germany's crypto-licensing architecture presents as functioning and in force, with an active and apparently disproportionately large authorisation pipeline relative to its EEA peers, following a deliberately compressed national transitional timeline. The principal residual uncertainty is empirical rather than legal: how many authorisations have actually been granted, and whether BaFin's enforcement powers, while clearly defined in scope, have been exercised against the newly authorised population in a way that would establish a visible supervisory track record.

#### Outlook

The clearest near-term resolution path is a direct cross-check of Germany's CASP authorisation count against the European Securities and Markets Authority's own register, which would settle the approximately 53 versus approximately 91 divergence without requiring any change to the underlying legal analysis. On enforcement, the absence of confirmed penalty-ceiling figures from primary KMAG text is a gap worth closing in a future cycle, particularly given BaFin's otherwise broad confirmed enforcement toolkit. No legislative change to the licensing framework itself is indicated by the available material this cycle; Germany's transitional period has closed, and the regime should now be assessed as an established, in-force authorisation and supervision framework rather than one still in flux.

Periodic update · new data 2026-09-28

#### Crypto Licensing

Providing custody and administration of crypto-assets for clients on a commercial basis in Germany requires CASP authorisation under Article 59 of the Markets in Crypto-Assets Regulation (MiCAR), or a transitional permission under Section 32 of the Kreditwesengesetz (KWG), per BaFin's guidance notice on crypto-asset services under MiCAR, a confirmed-confidence finding drawn directly from BaFin's own published guidance. The pre-MiCA German crypto-custody licence under KWG Section 1(1a) (Kryptoverwahrgeschäft) is transitional under MiCA's grandfathering framework; Germany appears to have shortened its national grandfathering window relative to the EU-wide default, although secondary sources diverge on the precise cut-off date and this has not been resolved against a primary BaFin or KMAG transitional-provision citation this cycle, a genuine and flagged evidentiary gap rather than a resolved fact.

Germany's MiCA CASP authorisation count reached 79 as of an ESMA-register update reported 24 August 2026, the highest of any EU or EEA member state, up from 53 as of May 2026, a probable-confidence finding sourced to secondary trade-press reporting. This leading position reflects the conversion of Germany's large pre-existing national crypto-custody licence base into the harmonised MiCA regime, rather than an unusually permissive new-entrant pathway; the underlying authorisation process remains operationally demanding, involving substantial documentation and extended processing timeframes for applicants. The dual-track structure, MiCA/KMAG CASP authorisation layered on top of the transitional KWG Section 1(1a) custody licence, is the operative regime of record for Germany this cycle, settled in primary law but administratively demanding in practice.

#### Outlook

The unresolved cut-off date for KWG Section 1(1a) grandfathering is the key near-term item: it determines the compliance timeline facing Germany's remaining pre-MiCA custody licensees. Watch for a primary BaFin or KMAG citation that pins down this date definitively, and for whether Germany's CASP count continues its growth trajectory toward the next reporting update.

Periodic update · new data 2026-09-13

#### Crypto Licensing

Germany's MiCA implementation bridges prior national VASP licensing into the MiCA CASP regime under BaFin via FinmadiG and KMAG. The defining development this cycle is the compression of the CASP transition window: rather than the eighteen-month grandfathering period available in much of the EU, Germany has set a hard 31 December 2025 deadline for pre-MiCA BaFin licensees to complete their transition, and new market entrants must meet MiCAR requirements from day one with no grandfathering available to them at all. This is a materiality-5, binding, in-force instrument change in this cycle's evidence set, though it currently rests entirely on T3 secondary trade-press reporting (Yellow.com) rather than a located BaFin primary statement -- the absent_field_provenance register explicitly notes the lack of T1 confirmation, and that gap is treated here as a live sourcing hold rather than a settled fact.

A secondary, lower-materiality observation concerns MiCA Article 143(6), which permits simplified authorisation pathways for entities already licensed under prior national law. German firms and BaFin appear to use this pathway less aggressively than counterparts in France, a comparative posture rather than a substantive divergence in the underlying legal mechanism, and one carried at low confidence given its T4 sourcing.

The practical effect of the compressed timeline is already visible in market behaviour: at least one stablecoin issuer discontinued German operations rather than pursue MiCA authorisation domestically, a development discussed further in this cycle's stablecoin sub-brief. Read together, licensing policy and market response indicate BaFin is applying MiCA's transitional flexibility conservatively relative to peer jurisdictions, favouring a faster convergence on the harmonised EU standard over an extended national accommodation period.

#### Outlook

The near-term question for this module is evidentiary: whether BaFin publishes primary-source confirmation of the 12-month/31 December 2025 deadline in terms consistent with current secondary reporting. A second-order question is whether other EU member states follow Germany's compressed-timeline approach or whether Germany proves an outlier at the strict end of the transitional spectrum, a dynamic with direct bearing on where CASP licensing activity concentrates across the bloc.

Sources and findings (17)
- T4 · CoinDesk[Boerse Stuttgart Digital](https://www.coindesk.com/policy/2025/01/17/boerse-stuttgart-digital-lands-mi-ca-license-from-germany) — Awarded a MiCA CASP authorisation by BaFin, permitting EU-wide crypto asset services under passporting.
- T4 · The Block[Germany (BaFin)](https://www.theblock.co/post/406766/europes-mica-crypto-regime-is-fully-in-force-heres-who-wins-and-loses) — Germany led all EU member states with 57 CASP authorisations as of mid-2026 per compilations of ESMA's interim MiCA register, ahead of France and the Netherlands (26 each).
- T1 · U.S. SEC EDGAR[MiCA transitional regime (EU-wide)](https://www.sec.gov/Archives/edgar/data/1740604/000174060426000020/btgo-form10xk.htm) — MiCA transition period length varies by member state, running at the latest until July 2026 (Art. 143(3) backstop), during which existing licensed/registered providers may continue operating under national law.
- T4 · CoinDesk[BaFin](https://www.coindesk.com/policy/2024/08/21/german-regulator-seizes-13-crypto-atms) — Exchanging euros for crypto constitutes banking activity requiring a BaFin license; BaFin seized 13 unlicensed crypto ATMs across 35 locations for operating without required permission.
- T4 · CoinDesk[Binance](https://www.coindesk.com/policy/2026/06/26/binance-tells-eu-users-it-will-no-longer-provide-services-after-failing-to-secure-mica-license) — Binance entered 1 July 2026 without MiCA authorisation after withdrawing its Greek license application, telling customers in several EU countries it would suspend some services absent a MiCA license by the deadline.
- T4 · CoinDesk[BaFin (KWG regime)](https://www.coindesk.com/business/2022/04/21/germanys-commerzbank-applies-for-local-crypto-licence-report) — Germany's KWG licensing rollout required crypto custodians to obtain BaFin approval; BaFin received 25 custodian applications and approved only four early on, illustrating a historically stringent national process predating and sitting alongside MiCA.
- T3 · Freshfields Technology Quotient[Germany (KMAG / BaFin)](https://technologyquotient.freshfields.com/post/102js41/grandfathering-under-mica-how-member-states-approach-the-transitional-regime) — Germany shortened its national MiCA/KWG grandfathering window to 12 months under the Kryptomarkteaufsichtsgesetz (KMAG) section 50(2) No. 3, closing national transitional authorisations on 31 December 2025 -- six months earlier than the EU-wide Article 143(3) backstop of 1 July 2026 that affected firms such as Binance operating via other member states' transitional windows.
- T3[futurum bank AG](https://www.onvista.de/news/2026/10-06-eqs-adhoc-bitcoin-group-se-bafin-verweigert-beantragte-micar-zulassung-der-futurum-bank-ag-0-37-26561212) — BaFin refused futurum bank AG's MiCAR CASP authorisation application (filed 27 June 2025), disclosed 6 October 2026; the refusal ends the firm's prior toleration (Duldung) under which it continued crypto-asset services during the application's 15+ month pendency.
- T3 · Yellow.com[BaFin](https://yellow.com/news/germany-crypto-regulation-startups) — CASP authorisation under MiCAR; existing pre-MiCA BaFin licences grandfathered only until 31 December 2025
- T4 · Cyfrin[MiCA Article 143(6)](https://www.cyfrin.io/blog/mica-regulation-explained-a-guide-to-eu-crypto-compliance) — Simplified authorisation pathways for entities already licensed under prior national law; used less aggressively by German firms/regulators than peers such as France
- T3[Germany MiCA transition period](https://www.sbs-legal.de/lexikon/mica-2026-regeln-fuer-token-und-kryptodienstleister) — Germany shortened the MiCA Art. 143(3) national grandfathering period for pre-existing crypto-asset service providers to 31 December 2025, six months ahead of the EU's outer limit of 1 July 2026, after which unauthorised provision of CASP services is unlawful.
- T1[BaFin](https://www.bafin.de/DE/unternehmen-maerkte/erlaubnis-registrierung/geschaefte-krypto/kryptowerte-dienstleistungen/kryptowerte-dienstleistungen_node.html) — Crypto-asset services in Germany require BaFin authorisation under MiCAR (Art. 59) or a valid notification (Art. 60) for already-regulated entities.
- T1[Unnamed operators of a repeating series of near-identical websites](https://www.bafin.de/SharedDocs/Veroeffentlichungen/DE/Verbrauchermitteilung/unerlaubte/2026/meldung_2026_09_23_plattformreihe_ki-gestuetzte_krypto-handelsplattform.html) — BaFin amended (20 October 2026) its warning about a repeating series of near-identical websites suspected of offering crypto-asset services without required licence/authorisation, with customer data passed to unsupervised trading-platform operators
- T2[Markets in Crypto-Assets Regulation (MiCA) review](https://cryptoticker.io/de/mica-defi-haftung-boersen/) — EU finance ministers agreed on 9 October 2026 to confine direct ESMA supervision to only the largest CASPs (est. 10-15 of 360 registered firms), leaving the remaining firms, including ~100 BaFin-supervised German CASPs (the largest national cohort), under national supervision
- T1 · BaFin[MiCAR / KMAG](https://www.bafin.de/SharedDocs/Veroeffentlichungen/DE/Fachartikel/2024/fa_bj_0701_MiCAR.html) — Crypto-asset services may only be provided by CASPs authorised under Art. 59 MiCAR; BaFin is the competent German authority under KMAG § 3; unauthorised provision is a criminal offence under KMAG § 46 Abs. 1 Nr. 3 punishable by up to 5 years imprisonment or a fine
- T3 · Traub Legal[KMAG § 50 Übergangsvorschrift](https://www.traub.legal/themen/bank-kapitalmarktrecht/kryptoverwahrung-erlaubnispflicht-micar/) — Firms with pre-existing national (KWG) authorisation may continue crypto-asset services until a MiCAR/CASP decision or 31 December 2025 at the latest
- T3 · nexvyra.de[KWG § 1 Abs. 1a / § 32](https://nexvyra.de/fakten/bafin-kryptoverwahrgeschaeft-erlaubnis.html) — Qualified crypto-custody business concerning crypto-assets that are also financial instruments (not covered by MiCAR) requires a residual KWG § 32 licence; unauthorised operation is a criminal offence under § 54 KWG, with BaFin intervention under § 37 KWG

### Germany: C2 Token ClassificationGreenEnacted in forceModule confidence: Probable▾

Germany follows the MiCA taxonomy: asset-referenced tokens (ARTs), e-money tokens (EMTs), and other crypto-assets, with BaFin as the national competent authority applying EU-level classification guidance including ESMA's qualification guidelines. Germany has an active EMT issuer (AllUnity's EURAU), demonstrating practical application of the EMT category domestically. NFTs and non-fungible, non-transferable loyalty-type tokens are treated as generally out of MiCA's scope absent fungibility/transferability.

Periodic update · new data 2026-09-13

#### Token Classification

Germany, via BaFin, remains among the more active EU national authorities issuing Asset-Referenced Token and E-Money Token authorisations under MiCA's passporting regime, standing alongside France, Ireland, the Netherlands, Luxembourg and Malta. This is a standing state of the regime rather than a fresh development this cycle: the classification framework, MiCA Titles III and IV, is directly applicable EU law, and no German-specific derogation or supplementary classification rule has been identified.

#### Outlook

No near-term change is expected absent a fresh EU-level amendment to MiCA's classification titles; the module is stable and will be monitored for any German-specific interpretive guidance from BaFin.

C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-11-03

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### Germany: C3 On-Chain Activity RegimeAmberEnacted in forceModule confidence: Probable▾

Germany permits regulated staking and custody activity through BaFin-licensed entities under the KWG crypto custody regime and, since December 2024, under MiCA's CASP ancillary-services framework. BaFin-licensed firms including Boerse Stuttgart Digital (via Blocknox) and BitGo Europe offer institutional staking alongside custody and trading. There is no distinct bespoke German statute solely for DeFi, mining, or node operation; these remain governed by the general KWG/MiCA licensing perimeter.

Periodic update · new data 2026-09-13

#### On-Chain Activity Regime

No Germany-specific licensing sub-regime for staking, DeFi participation, or crypto mining activity distinct from the general MiCA CASP perimeter has been identified this cycle. This is treated as a genuine regime gap rather than a research failure: such activities appear to fall within the general CASP authorisation perimeter rather than triggering a bespoke national instrument.

#### Outlook

This gap should be watched for any German-specific rulemaking, particularly if EU-level MiCA follow-on measures address staking or DeFi more explicitly; absent that, the general CASP perimeter is expected to remain the operative framework.

C3 · On-Chain Activity — Full Module Record 0 sub-modules · 180 words · 3 traced claims · Re-verified 2026-11-03

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### Germany: C4 Stablecoin RegimeGreenEnacted in forceModule confidence: Probable▾

BaFin authorises ART/EMT issuance under MiCA and has taken active enforcement action against non-compliant stablecoin issuers, including the EU's first MiCA-related cease-and-desist action (March 2025); Ethena Labs discontinued its German subsidiary after BaFin scrutiny.

Periodic update · new data 2026-09-28

#### Stablecoin Regime

MiCAR Title II sets out transparency and conduct obligations for issuers of crypto-assets other than asset-referenced tokens (ARTs) and e-money tokens (EMTs), while Titles III and IV impose specific authorisation requirements, notification duties and whitepaper-publication obligations on ART and EMT issuers respectively, per BaFin's own Merkblatt on ART/EMT authorisation, a confirmed-confidence finding drawn from primary BaFin guidance retrieved this cycle. Asset-referenced tokens and e-money tokens are defined by direct reference to Article 3(1) Nos. 6 and 7 of Regulation (EU) 2023/1114, incorporated into German law via KMAG Section 2, paragraphs 2 and 3 respectively, both confirmed-confidence findings drawn from directly-retrieved primary statutory text.

The material development this cycle is institutional: Deutsche Bank secured BaFin authorisation under MiCA for crypto-asset custody and transfer services in Germany, with planned custody support for Bitcoin, Ether, and the stablecoins USDC, EURC and EURAU for institutional and corporate clients, with first clients expected in 2026. This is a probable-confidence finding sourced to a single tier-four report. It signals institutional-grade convergence of German banking and crypto custody, extending stablecoin custody capability into an established credit institution rather than a crypto-native CASP, and is the most structurally significant stablecoin-regime development of the cycle for Germany.

#### Outlook

Deutsche Bank's stablecoin-custody rollout in 2026 is the item to watch: its client onboarding pace and scope, particularly for EURC and EURAU custody, will be an early indicator of institutional demand for bank-grade stablecoin custody under Germany's now-mature MiCAR Title III/IV authorisation regime.

Periodic update · new data 2026-09-13

#### Stablecoin Regime

BaFin authorises Asset-Referenced Token and E-Money Token issuance under MiCA and, this cycle, has demonstrated a willingness to enforce reserve-attestation requirements directly. In March 2025, BaFin issued what secondary reporting characterises as the European Union's first MiCA-related cease-and-desist order, suspending issuance by a smaller stablecoin issuer after the issuer omitted required reserve attestations from its disclosures. The issuer remediated the attestation gap within ninety days and resumed issuance, suggesting the action was calibrated to compel compliance rather than to permanently exclude the issuer from the German market -- a distinction that matters for how the action should be read as precedent.

The enforcement action coincides with a market-exit event: Ethena Labs discontinued its German subsidiary operations and will not pursue MiCA authorisation in Germany following BaFin scrutiny. While the structured evidence does not establish a direct causal link between the cease-and-desist action and Ethena's decision, both developments point in the same direction -- a German stablecoin supervisory environment that is demonstrably willing to act on reserve-disclosure gaps, and at least one significant issuer choosing to concentrate elsewhere in Europe rather than meet that bar in Germany specifically.

#### Outlook

The open question is whether the March 2025 action represents a one-off calibration exercise or the first of a recurring enforcement pattern. Further cease-and-desist or remediation actions against stablecoin issuers, or additional issuer relocations away from the German market, would together indicate BaFin intends reserve-attestation enforcement as a standing feature of its MiCA supervisory posture rather than an isolated event.

C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 7 traced claims · Re-verified 2026-11-03

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### Germany: C5 Consumer ProtectionGreenEnacted in forceModule confidence: Probable▾

MiCA's consumer protection provisions apply directly in Germany, including CASP conduct-of-business rules, custody segregation, disclosure obligations, and complaint-handling requirements, with BaFin enforcing against unlicensed/non-compliant operators. Retail-facing rollout by mainstream banks (DZ Bank's meinKrypto) is explicitly scoped as self-directed, non-advisory retail trading rather than advised investment.

#### Consumer Protection

MiCA's consumer-protection provisions apply directly in Germany without need for further national transposition, covering CASP conduct-of-business rules, custody segregation, disclosure obligations, and complaint-handling requirements, and BaFin has shown willingness to enforce these provisions against firms operating outside the licensed perimeter. MiCA's broader stated rationale -- supporting market integrity and financial stability by regulating public offers of crypto-assets and ensuring consumers are better informed of associated risks -- underpins the specific conduct rules that BaFin applies to authorised CASPs, including governance, reserves, capital, asset-safeguarding, segregation, and security requirements as set out in the Regulation.

Enforcement activity this cycle illustrates the perimeter in practice: BaFin publicly warned that the exchange Rtcoin was not authorised to operate in Germany, citing reasonable grounds to suspect unlicensed banking business or financial services -- a direct consumer-facing warning against an unauthorised platform, distinct from BaFin's licensing enforcement against unlicensed ATM operators discussed under the licensing and AML modules. On the mainstream-institutional side, DZ Bank's meinKrypto retail crypto trading platform has been explicitly scoped as aimed at self-directed investors and is not part of DZ Bank's advisory services to retail customers -- a deliberate delineation between execution-only retail crypto trading and advised investment, which matters for suitability and appropriateness obligations since advisory-grade protections do not automatically extend to execution-only platforms.

#### Outlook

Consumer protection in Germany benefits from MiCA's direct applicability and BaFin's demonstrated willingness to issue public warnings against unauthorised platforms. The development worth tracking into the next cycle is how mainstream banks' execution-only retail crypto offerings -- following the DZ Bank model -- are treated under suitability and appropriateness rules as retail adoption grows, particularly whether the non-advisory framing effectively shields such platforms from advisory-grade consumer protection obligations or whether BaFin signals a different expectation as volumes increase.

Read full sub-brief · 294 words Periodic update · new data 2026-10-04

#### Consumer Protection

The central consumer-protection obligation for crypto-asset service providers operating in Germany under the MiCA regime is custody segregation. Client crypto-assets and client funds must be kept segregated from the firm's own assets, and the provider is liable for loss in specified circumstances, consistent with MiCA Art 75. This requirement sits at the core of client-asset protection in a sector where commingling of client and firm assets has historically been a significant source of consumer loss in insolvency or fraud scenarios; a clear segregation duty, backed by provider liability, directly addresses that risk at the structural level.

The evidentiary basis for this finding is reasonably well established: MiCA Art 75 is a directly applicable EU regulatory provision, and secondary German-market commentary consistently describes the segregation requirement as a core feature of the post-MiCA consumer-protection landscape for crypto-asset holders. What is not yet independently verified against BaFin's own published guidance this cycle is the more granular operational detail: specifically, how sub-custody or delegation arrangements are treated under MiCA Art 75(9), which governs circumstances where a CASP delegates custody functions to a third party, and how the insolvency treatment of segregated client assets would actually operate in a German insolvency proceeding. These are not minor technicalities; they determine whether the headline segregation duty translates into effective protection in the scenarios where protection matters most, namely provider insolvency or failure.

The practical significance of this gap is heightened by the context established under the crypto-licensing module this cycle: Germany reportedly hosts the largest population of MiCA CASP authorisations in the EEA, following an early national transitional-period cutoff. A jurisdiction with a large and rapidly authorised population of custody-providing firms has a correspondingly larger pool of client assets potentially exposed to whatever gaps exist in the practical operation of the segregation and insolvency-treatment rules. The core legal protection, Art 75 segregation, is confirmed and in force; the operational robustness of that protection in an actual insolvency scenario involving a German-authorised CASP has not been tested or verified against primary regulatory guidance this cycle.

No consumer-protection enforcement action, consumer complaint pattern, or BaFin guidance update specific to crypto-asset custody was located for Germany this cycle beyond the standing Art 75 framework itself. The consumer-protection picture for Germany should therefore be read as structurally sound at the level of the headline legal obligation, with meaningful open questions at the level of operational implementation that have not yet been resolved through primary-source verification.

#### Outlook

The most useful next step for strengthening confidence in Germany's crypto consumer-protection posture would be direct verification of BaFin's own guidance on MiCA Art 75(9) sub-custody and delegation arrangements, together with clarification of how segregated client assets are treated in a German insolvency proceeding involving a failed CASP. Given the scale of authorisation activity reported for Germany this cycle, these operational questions carry more practical weight than they would in a jurisdiction with a smaller authorised CASP population. No change to the underlying Art 75 segregation obligation itself is indicated by the available material; the framework is in force and stable, with verification work remaining at the implementation-detail level rather than at the level of the core legal rule.

1 earlier distinct update(s) Periodic update · new data 2026-09-13

#### Consumer Protection

BaFin's requirement that token issuers submit a detailed white paper for approval before public offerings remains the operative consumer-protection mechanism under Germany's MiCA implementation. No new German-specific consumer-protection instrument was identified this cycle; the requirement functions as a directly-applicable EU consumer-protection floor supervised by BaFin.

#### Outlook

Stable outlook; any change would most likely arrive via EU-level MiCA amendment rather than German-specific legislative action.

Sources and findings (6)
- T1 · U.S. SEC EDGAR[MiCA (EU)](https://www.sec.gov/Archives/edgar/data/1740604/000174060426000020/btgo-form10xk.htm) — MiCA introduces a comprehensive CASP authorisation/compliance regime, including governance, reserves, capital, asset safeguarding, segregation and security requirements.
- T4 · The Block[BaFin](https://www.theblock.co/post/193595/crypto-exchange-rtcoin-not-licensed-in-germany-bafin-says) — BaFin publicly warned that crypto exchange Rtcoin was not authorised to operate in Germany, citing reasonable grounds to suspect unlicensed banking business/financial services.
- T4 · CoinDesk[DZ Bank (meinKrypto)](https://www.coindesk.com/business/2026/01/14/germany-s-second-largest-lender-dz-bank-secures-retail-crypto-trading-mica-license) — DZ Bank's meinKrypto retail crypto trading platform is aimed at self-directed investors and is explicitly not part of DZ Bank's advisory services to retail customers.
- T1 · ESMA[MiCA (EU)](https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica) — MiCA aims to support market integrity and financial stability by regulating public offers of crypto-assets and ensuring consumers are better informed of associated risks.
- T4 · Scorechain[BaFin](https://www.scorechain.com/blog/micas-impact-on-german-crypto-companies-what-you-need-to-know-and-how-to-prepare) — Token issuers must submit a detailed white paper for BaFin approval before public offerings as part of Germany's MiCA implementation
- T1[BaFin supervisory order powers under KMAG](https://www.gesetze-im-internet.de/kmag/BJNR1B60B0024.epub) — BaFin's supervisory order powers under KMAG extend explicitly to preventing and remedying marketing-communication abuses by CASPs and crypto-asset issuers.

### Germany: C6 Tax TreatmentGreenEnacted in forceModule confidence: Probable▾

Germany taxes crypto disposals by individuals as private sale transactions (Section 23 EStG) with capital gains tax-exempt if held over one year; the BMF published nationwide guidance in 2022 covering mining, staking, lending, hard forks, and airdrops. Separately, the BMF previously flagged that commercial (business) sales of bitcoin may be taxed as a 'miscellaneous service'. No German-specific crypto VAT is levied on crypto-to-fiat exchange consistent with the EU Hedqvist precedent, though this was not independently reconfirmed in this pass.

Periodic update · new data 2026-09-13

#### Tax Treatment

Germany's crypto tax framework continues to build on the 2013 classification of Bitcoin as a "unit of account." Secondary sources reference unspecified "recent tax changes" anticipated for 2026, but none reviewed this cycle name the underlying statutory instrument. This module remains a structurally thin-evidence vector; no specific 2026 German crypto tax-law citation has been located.

#### Outlook

This module should be treated as provisional pending identification of the specific 2026 statutory instrument, if one exists; the standing 2013 classification is expected to remain the operative baseline until such a citation is confirmed.

C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-11-03

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### Germany: C7 Cross-Border TransferGreenEnacted in forceModule confidence: Probable▾

Germany, as an EU/EEA member, applies MiCA passporting allowing BaFin-authorised CASPs to operate across all EU/EEA member states, and applies the EU Travel Rule to crypto-asset transfers crossing borders. AllUnity's EURAU is explicitly positioned to serve instant cross-border euro payments. No distinct German outbound capital-control restriction on crypto was identified; EU sanctions/AWG-based restrictions apply to designated persons/entities.

Periodic update · new data 2026-09-13

#### Cross-Border Transfer

Germany implements the international Travel Rule via its national Crypto Asset Transfer Regulation (KryptoWTransferV), operating alongside the directly-applicable EU Transfer of Funds Regulation (Regulation 2023/1113), in force since 30 December 2024. No change to this implementing architecture was identified this cycle.

#### Outlook

Stable outlook; this surface increasingly intersects with financial-integrity's AML/CFT tracking, and further illicit-finance-specific developments are expected to be captured there rather than in first-party crypto-monitor analysis going forward.

C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-11-03

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### Germany: C8 AML/CFT RegimeGreenEnacted in forceModule confidence: Probable▾

Germany applies EU-level AML/CFT rules to CASPs via the GwG transposing AMLD5/6, plus MiCA-linked authorisation under Regulation (EU) 2023/1113 (Travel Rule) effective since December 2024. CASPs authorised under MiCA are subject to the same AML/CFT requirements and supervision as credit and financial institutions. Germany's 2022 FATF Mutual Evaluation found VASPs generally have good understanding of ML/TF risk among larger firms, though BaFin was noted as able to take a more proactive approach to unlicensed money/value transfer providers.

C8 · AML/CFT Regime — Full Module Record 0 sub-modules · 180 words · 7 traced claims · Re-verified 2026-11-03

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### Germany: C9 Commercial Activity ▾

No standing position recorded for this category.

Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

No periodic updates recorded in this cycle

Sources and findings (1)
- T3[Bitcoin Group SE](https://www.onvista.de/news/2026/10-06-eqs-adhoc-bitcoin-group-se-bafin-verweigert-beantragte-micar-zulassung-der-futurum-bank-ag-0-37-26561212) — BaFin's MiCAR refusal forced Bitcoin Group SE / futurum bank AG into a commercial restructuring of the Bitcoin.de platform around two externally-regulated partners (trading counterparty and custodian), under negotiation as of 7 October 2026.