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Crypto banking for crypto-asset service providers authorised by BaFin

Germany ended its MiCA transition early, on 31 December 2025. Any firm serving German clients now needs its own authorisation or an EU passport. Build the product BaFin will review: custody, exchange and euro accounts on one ledger.

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Case Studies

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Crypto Banking · CASP

What you can offer with a BaFin MiCA authorisation

Crypto custody for your clients

Every client gets crypto accounts with their own deposit addresses and QR codes. Under MiCA you are the custodian, and the keys sit in MPC wallet infrastructure that you contract.

Buy and sell against euro

Exchange of crypto-assets for euro with liquidity from a connected provider. Proceeds land in the client's euro account inside the same app.

Euro accounts next to crypto

IBAN accounts with SEPA, SEPA Instant and SWIFT transfers through your banking partner, posted to the same ledger as the crypto holdings.

Crypto transfers

Internal transfers between clients and on-chain withdrawals. Originator and beneficiary data travel through a connected Travel Rule provider.

Crypto-linked cards

Visa and Mastercard cards that spend crypto-linked balances, settled in euro at the point of sale. You sign the contract with the card issuer.

What this licence does not cover

  • Deposit taking or lending. A MiCA authorisation does not make you a credit institution.
  • Issuing euro stablecoins (e-money tokens). MiCA reserves that for credit institutions and e-money institutions.
  • EU-wide business on an old KWG crypto custody licence. BaFin states that only a MiCA authorisation comes with the European passport.
  • Services on tokens that count as financial instruments. Those fall under securities law, not MiCA.
Your market

What the regulator asks about your IT

Each requirement, what the platform gives you for it and who owns it after launch.

1Proof of DORA compliance inside the authorisation application

ICT architecture, access roles, 2FA, audit trail, backups and our incident process described, plus the details you need for your register of ICT third-party providers.

You, with our input
2Technical documentation of ICT systems and security arrangements, with a non-technical description (Art. 62 MiCA)

A technical write-up of the platform and a plain-language version for your management board and BaFin.

Crassula drafts, you adopt
3Register of positions per client (Art. 75 MiCA)

Crypto holdings per client on the ledger, every movement posted, with exports to reconcile against the wallets in your custody infrastructure.

Your operations team, on platform data
4Legal and operational segregation of client crypto-assets from your own

Client and own-account holdings on separate ledger accounts. The wallet structure is set up with your custody technology provider.

Shared
5Custody policy and liability for losses (Art. 75 MiCA)

Approval flows, access roles and controls described as they run on the platform.

You, with input from us and the custody provider
6Travel Rule under Regulation (EU) 2023/1113

Originator and beneficiary data captured at onboarding and on each transfer, exchanged through a connected Travel Rule provider.

Your money laundering officer
7Customer due diligence under the German Money Laundering Act (GwG)

Onboarding questionnaires per client type, identity checks and transaction monitoring through connected providers, client limits.

Your money laundering officer
8Outsourcing of critical or important functions

Service description, contract terms, audit and access rights, and exit support.

You, with our input
Germany

Payment rails and providers

Rails your customers can use

SEPASEPA InstantSWIFTOn-chain transfersInternal transfers

Fireblocks

Technology provider of MPC-based wallet and custody infrastructure, used by regulated crypto firms in Germany. You stay the custodian under MiCA.

Kraken

Holds a MiCA authorisation from the Central Bank of Ireland and can serve the whole EEA. Liquidity for your exchange service, or Kraken Embed if you start without your own authorisation.

24/7real-time processing, no batch window
60+payment and provider integrations connected
150+companies run on Crassula
15+languages the platform speaks
Germany

Dates to plan around

Rules that change what you have to build, in the order they apply.

  1. 1 Jan 2020

    Crypto custody becomes a licensed financial service under the German Banking Act (KWG).

  2. 30 Dec 2024

    MiCA rules for crypto-asset service providers apply, together with the crypto Travel Rule under Regulation (EU) 2023/1113.

  3. 17 Jan 2025

    DORA applies. BaFin expects the evidence in the authorisation application.

  4. 31 Dec 2025

    Germany's shortened transition ends. Crypto services in Germany now need a MiCA authorisation or a passport.

  5. 1 Jul 2026

    The last transitional periods in the EU expire. Firms relying on national registrations elsewhere had to stop or be authorised.

CASP

Applying to BaFin as a CASP? Name us in your application.

BaFin wants to see the systems behind your service and expects the DORA evidence in the file itself. We give you a working platform and the technical documentation, while your legal advisers handle the rest.

Talk to us about your application

Crassula provides technology and documentation support. We do not provide legal or regulatory advice and cannot guarantee the outcome of an application.

  1. 01

    A platform you can demonstrate

    A configured environment to show the regulator, not slides.

  2. 02

    The technical part of your application, prepared

    ICT systems and security, DORA, outsourcing and business continuity sections of your BaFin application.

  3. 03

    Providers lined up

    Custody infrastructure through Fireblocks and liquidity through Kraken, plus banking and KYC providers from our network.

A customer checking digital-asset balances at home.
Crypto Banking

How a launch usually runs

Picture a Berlin team building an app for bitcoin and ether savings plans with a euro account. It needs custody and exchange against euro, which puts it in class 2 with at least EUR 125,000 of initial capital. Before filing, the team takes up the initial meeting BaFin offers. Meanwhile we set up an environment in its brand, with wallets on Fireblocks infrastructure and liquidity from Kraken, and write the ICT, DORA and outsourcing sections together.

While BaFin reviews the file, the operations team practises reconciling the per-client register of positions against the wallet balances on test data. Once authorised, the team goes live on the platform the supervisor has already seen. Teams that want to reach the market sooner ask Kraken whether Kraken Embed is available for German clients, and ask their lawyers whether that model works without their own authorisation.

For the regulatory background, read our guide to crypto custody in Germany and the MiCA CASP licence guide.

Guides

Read the licence guides

Explore all guidesLicensing, payments, cards and core banking, explained by our team.
Germany · CASP

FAQ

The questions teams ask us before a first call.

Not covered here?Bring your question to a demo with our team.
Can we still rely on the German transitional period?
No. Germany cut the MiCA transition short to 31 December 2025. Since then, serving German clients needs a MiCA authorisation, a passport from another member state, or, for banks and investment firms, a notification under Article 60 MiCA.
How long does BaFin take to decide?
MiCA gives BaFin 25 working days to check that the file is complete, then 40 working days to decide. Requests for more information can pause that clock for up to 20 working days. Real timelines are longer because few files are complete at the first attempt.
How much capital do we need?
Custody and exchange against funds or other crypto put you in class 2, with EUR 125,000. Running a trading platform means class 3 and EUR 150,000. If a quarter of last year's fixed overheads is higher, that figure applies instead.
Can we offer crypto without our own BaFin authorisation?
Kraken pitches Kraken Embed for exactly that: you run the front end, and Kraken handles execution and market connectivity under its Irish MiCA authorisation. The first public launch, with bunq, covered the Netherlands, France, Spain, Ireland, Italy and Belgium. Check with Kraken whether Embed is available for German clients, and with your lawyers whether your model then needs no authorisation of its own.
Does Crassula hold our clients' crypto?
No. Crassula is the software for accounts, exchange, apps and back office. Keys sit in the custody infrastructure you contract, and you are the custodian towards clients and BaFin.
We are already a bank or investment firm. Do we need a full MiCA authorisation?
Usually not. Credit institutions and the other firms listed in Article 60 MiCA can notify equivalent crypto services at least 40 working days before they start. You still need the platform and the technical documentation.
Crypto Banking

Explore your launch market

Germany · CASP

What you can offer with a BaFin MiCA authorisation

Tell us your licence and country. We will map the rails, providers and documents you need.

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