Country _ Name
Germany
SectionTitle
Online banking services
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FinTechs belonging to this area offer traditional banking services in a modern way, usually through online services or mobile applications as well as ancillary services – e.g. enabling customers to manage their giro- or custody-accounts online and in real time or offering e-wallet services. Keywords in this context are also API-Banking or Banking as a Service (BaaS)/ Bank as a Platform (BaaP).

API-Banking:

API stands for application programming interface and is offered to access data banks and to extract and insert information. API-Banking consequently means the access to data banks of banks to offer new and innovative banking applications.

Through these services FinTechs offer services with new functions, e.g. enabling customers to manage their accounts online and in real time.

BaaS – Bank as a Service/BaaP – Bank as a Platform:
 
The API-based Bank as a Service platform has a full banking licence, but merely serves as the back end for standalone independent FinTechs, which “use” the licence and the back end of the bank to offer new financial services, launch additional financial products or expand into additional markets.

Introduction

Attitude of the country towards online-banking services

Online banking is well established in Germany, with around 84% of the population using online banking services in 2024. As traditional bank branches continue to close, more customers rely on digital channels for their banking needs. A key trend is the growing use of mobile apps on smartphones, which have largely overtaken desktop computers as the primary device for accessing online banking. This shift reflects consumers’ preference for convenience and on-the-go access to financial services.


Legal affairs

Obligations and requirements to provide online-banking services described above

Online banking services as part of the usual banking business and financial services are activities governed by the German Banking Act (KreditwesengesetzKWG). For banking business and financial services, a license is generally required.
License costs depend on the specific business model and result from fixed and time spent costs. Fixed costs typically range from EUR 3,262.00 to EUR 10,114.00 and additional time spent costs depend on the complexity of respective business model.

Among other things, particularly sufficient initial capital consisting of Common Equity Tier 1 capital (CET1) available in Germany is required to obtain a license. The amount of required CET1 is subject to a case-by-case assessment. For institutions offering both lending and deposit business, the required initial capital is EUR 5m.

When offering banking services, the service providers are to comply with requirements for the initial capital as well as with the funds requirements at all times. According to Art. 92 Regulation (EU) No. 575/2013 (Capital Requirements Regulation – CRR
), these are: a CET1 capital ratio of 4.5%, a Tier 1 capital ratio of 6%, a total capital ratio of 8% and a leverage ratio of 3 %. When calculating the capital ratios, the fixed overheads of the respective asset manager have an important impact.


Additional comments regarding the legal situation for online-banking services or what FinTech’s must be aware of in this business area

In order to provide online banking services both in a cost-efficient way and at the same time meeting all legal requirements, a fronting bank cooperation is recommended.


Economic conditions

Market size for online-banking services and biggest companies in this business area

Raisin DS, Mambu, and Solaris SE remain the leading players in Germany’s online banking services market. Raisin DS has raised over $300 million and manages more than €50 billion in assets, serving over one million customers across Europe, while actively expanding its offerings, including a recent launch in Poland. Mambu, valued at $5.5 billion, reported revenues of $128.6 million in 2024 and supports over 6,000 customers globally with its cloud-native, API-driven platform for building digital financial products. Solaris SE, formerly Solarisbank, secured $145 million in early 2025 funding and was acquired by SBI Group; it reported €927 million in revenues for 2024, marking strong growth. These companies provide critical SaaS and Banking-as-a-Service infrastructure that drives innovation and the evolution of digital financial services in Germany and beyond.

Additional comments regarding the economic situation for online-banking services or what FinTech’s must be aware of in this business area

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