Canada    FinTech Guide    Chapter 8    Germany

8. Online Banking Services
Germany  Germany

The onlinebanking market is a still growing market in Germany. A business market with high potential is the mobile online banking market.

Legal Affairs

In Germany online banking services as part of the usual banking business and financial services are regulated in the German Banking Act (Kreditwesengesetz – “KWG”). For banking business and financial services a license is needed.

The costs of a license range from EUR 2,000.00 to 20,000.00 depending on the specific business model.

Among other things, the resources needed for business operations, in particular sufficient initial capital consisting of Common Equity Tier 1 capital, are required to be available in Germany. In the case of asset and portfolio managers, who, in providing financial services, are not authorized to obtain ownership or possession of funds or securities of customers and who do not trade in financial instruments for their own account: an amount equivalent to at least EUR 50,000.00.

Credit institutions have to fulfill the funds requirements according to Art. 92 and following of Regulation (EU) 575/2013 (CRR). These are: a Common Equity Tier 1 capital ratio of 4.5%, a Tier 1 capital ratio of 6% and a total capital ratio of 8%. When calculating the capital ratios, the fixed overheads of the respective asset manager play an important role.

Economic Conditions

According to the German industry association Bitkom 53% of the people in Germany have used online banking services in 2016.


In order to provide online banking services in a cost effective way in which also all legal requirements are complied with a cooperation with a fronting bank is recommended.

Contributing Authors

Schalast Rechtsanwälte mbB

Andreas Walter
Frankfurt, Germany

Search by:

Chapter Index:

1. Payment Services / Mobile Payment

2. Asset and Portfolio Management

3. Consulting and Broking Services / Robo-advisory / Auto-trading

4. Trading Platforms / Social Trading Platforms / Signal Following

5. Crowdfunding / Crowdinvesting / Crowdlending

6. Virtual Currency - Bitcoin

7. Loan Services / Factoring / Loan Broking / Finetrading

8. Online Banking Services

9. Analytics and Research / Data Management / Risk Management

10. Accounting

11. Identification

12. Online-pawning

13. InsurTech

14. RegTech

15. Initial Coin Offerings (ICOs)

The information in this guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.

Publication Date: 1 May 2018