Name
Global FinTech Guide
Country _ Name
Germany
SectionTitle
DLT and cryptocurrencies
Body
FinTechs belonging to this category offer financial services using crypto currencies. This category also includes FinTechs utilising blockchain and distributed ledger technologies (DLT) upon which Bitcoin and Ethereum are based, among others. FinTechs develop and do research in this field in order to create new services – e.g. crypto currency exchange markets, wallet providers, NFTs-related services, new payment services, "smart contracts" or new clearing and settling services.

Introduction

Attitude of the country towards financial services using crypto currencies

Using cryptocurrencies in banking and financial services is an emerging trend in Germany. While adoption is still limited among the broader population and many companies, interest has been steadily increasing, especially among younger and more tech-savvy users. By the end of 2023, several German banks, including some savings banks (Sparkassen), have begun exploring or offering crypto trading and custody services to meet growing customer demand. Upcoming regulations, such as the EU’s Markets in Crypto-Assets (MiCA) framework, are expected to provide clearer rules and foster broader adoption. Overall, cryptocurrencies are becoming a recognized part of Germany’s evolving financial landscape, although widespread mainstream use is still developing.


Legal affairs

Obligations and requirements to provide financial services using crypto currencies described above

In Germany, crypto currencies are deemed to be crypto-assets, which are regulated according to the European Regulation (EU) 2023/1114 (MiCAR).
Whether a license is required in this context depends on the business model. Offers of crypto-assets to the public and the provision crypto-asset service trigger a licence requirement. ‘crypto-asset service’ means any of the following services and activities relating to any crypto-asset:

  • providing custody and administration of crypto-assets on behalf of clients;
  • operation of a trading platform for crypto-assets;
  • exchange of crypto-assets for funds;
  • exchange of crypto-assets for other crypto-assets;
  • execution of orders for crypto-assets on behalf of clients;
  • placing of crypto-assets;
  • reception and transmission of orders for crypto-assets on behalf of clients;
  • providing advice on crypto-assets;
  • providing portfolio management on crypto-assets;
  • providing transfer services for crypto-assets on behalf of clients;
License costs depend on the specific business model and result from fixed and time spent costs. Fixed costs are based on the time required and additional time spent costs depend on the complexity of respective business model.
Issuers of asset-referenced tokens shall, at all times, have own funds equal to an amount of at least the highest of the following: (a) EUR 350 000; (b) 2 % of the average amount of the reserve of assets; (c) a quarter of the fixed overheads of the preceding year.
Crypto-asset service providers shall, at all times, have in place prudential safeguards equal to an amount of at least the higher of the following: (a) the amount of permanent minimum capital requirements indicated in Annex IV, depending on the type of the crypto-asset services provided; (b) one quarter of the fixed overheads of the preceding year, reviewed annually.
Anti-money laundering and data protection regulation is also to be complied with.

Additional comments regarding the legal situation for financial services using crypto currencies or what FinTech’s must be aware of in this business area

Under German law, there is also the business of qualified crypto custody, which requires a license, as a catch-all provision if MiCaR does not apply.


Economic conditions

Market size for financial services using crypto currencies and biggest companies in this business area

Following a turbulent 2022 and strong 2023 rebound in crypto markets, Germany’s crypto-financial services sector is estimated to reach approximately €1.93 billion in turnover in 2024, growing to around €2.33 billion by 2028—reflecting a modest annual growth rate of 4.8%. Leading domestic players include Börse Stuttgart Digital, which offers trading, custody, and the consumer-oriented Bison app used by about 1 million users in 2024 and accounted for around 25% of group revenue. Another key entrant is DWS (via AllUnity), which plans to launch Germany’s first BaFin-regulated euro stablecoin in 2025.

Additional comments regarding the economic situation for financial services using crypto currencies or what FinTech’s must be aware of in this business area

Although specialist firms with both technical and regulatory expertise remain limited, competition is already heating up—on one side, providers race to offer secure, compliant services (“race to the top”), while on the other, EU member states may compete for a lighter regulatory environment (“race to the bottom”).

Germany operates under the EU’s MiCA regulation (in effect since December 2024), which mandates licensing for Crypto Asset Service Providers and implements the "Travel Rule".

Meanwhile, the Digital Euro is moving forward: the ECB’s preparatory phase began in November 2023, with legislation expected by October 2025 and potential issuance by 2028. This will introduce a central-bank-backed digital payment instrument across the euro area.

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