--- title: "Digital Banking for German EMIs | BaFin and ZAG Ready" description: "White-label digital banking for e-money institutions in Germany: web, iOS and Android apps, cards, SEPA Instant and documents for your ZAG file." url: "https://crassula.io/solutions/digital-banking/germany-emi/" lang: "en" image: "https://crassula.io/static/images/og/crassula-default.d7d01fb8a962.jpg" alternates: "en": "https://crassula.io/solutions/digital-banking/germany-emi/" "de": "https://crassula.io/de/solutions/digital-banking/germany-emi/" "es": "https://crassula.io/es/solutions/digital-banking/germany-emi/" "fr": "https://crassula.io/fr/solutions/digital-banking/germany-emi/" "x-default": "https://crassula.io/solutions/digital-banking/germany-emi/" index: "https://crassula.io/llms.txt" --- Germany · E-Geld-Institut (EMI) # Digital banking for e-money institutions in Germany German customers will hold your app up against their Sparkasse or direct bank. Launch with apps in your brand, accounts, cards and instant transfers on a platform you can already show BaFin while it reviews your application. [Request demo](https://crassula.io/request-demo/) [Digital Banking →](https://crassula.io/solutions/digital-banking/) Your market**Germany**E-Geld-Institut (EMI) - Web, iOS and Android apps in your brand - Interface and notifications in German - SEPA Instant with payee verification - System description for your ZAG file Rails your customers can use **SEPA Credit Transfer****SEPA Instant****SEPA Direct Debit****SWIFT****Card payments****Internal transfers** What the regulator asks about your IT**7** Case Studies ## See what teams build with Crassula. ![Multipass](https://crassula.io/static/images/solutions/cases/logo-multipass.7fb14a8eede7.png) - Multi-currency accounts - Cross-border payments - BaaS connections Live on Crassula ### [Custom financial products for global businesses.](https://crassula.io/cases/multipass/) Global business accounts, multi-currency payments and cross-border solutions, supported by Crassula APIs and BaaS connections. [Read case study: Multipass](https://crassula.io/cases/multipass/) ![LuxPay](https://crassula.io/static/images/solutions/cases/logo-luxpay.7d1fa138b9ba.png) - IBAN · SEPA - Card issuing - KYC onboarding Live on Crassula ### [A connected banking platform for modern financial services.](https://crassula.io/cases/luxpay/) Account details, SEPA payments, card issuing, KYC onboarding and multi-currency exchange in one financial product. [Read case study: LuxPay](https://crassula.io/cases/luxpay/) Digital Banking · E-Geld-Institut (EMI) ## What a German e-money institution can offer its customers ### An everyday account on e-money Customers open an account with an IBAN in the app, receive their salary and pay rent by SEPA transfer or direct debit. Legally the balance stays e-money, and your app says so. ### Debit cards for daily spending A virtual card right after sign-up and a plastic one on request, with freezes, limits and PIN handled in the app. You sign the contract with the card issuer yourself. ### Instant transfers with a name check SEPA Instant from the app, carrying the data your payments provider needs to verify the payee before the customer confirms. ### Sub-accounts and savings goals Pots for holidays or tax money, with no interest promised, and a push notification for every booking. ### Accounts for freelancers and GmbHs Onboarding for freelancers and limited companies, several users with roles, batch payments with approval and transaction exports for the bookkeeper. ### Access for third-party providers Consent screens for account information and payment initiation services, so customers can connect their finance and tax apps. ### What this licence does not cover - Deposits under the German Banking Act (KWG). E-money is outside the statutory deposit guarantee, and your app and terms must make that clear. - Interest on e-money balances, savings goals included. - Overdrafts funded from customer money. Credit is only possible as a narrow ancillary activity under the ZAG, from your own funds. Your market ## What the regulator asks about your IT Each requirement, what the platform gives you for it and who owns it after launch. 1 Security strategy with a detailed risk assessment (section 10(2) ZAG) A write-up of the app architecture, hosting, role model, two-factor login and audit trail to base your risk assessment on. Crassula drafts, you sign off 2 Safeguarding customer funds under section 17 ZAG A ledger that shows outstanding e-money per customer, with exports for the daily match against your trust account. Your finance team, on platform data 3 Strong customer authentication in app and web Two-factor login and payment confirmation in all three front ends. Crassula 4 Customer due diligence under the German Money Laundering Act (GwG) Questionnaires by customer type, identity checks through connected providers and per-customer limits. Reviewing suspicious cases stays with you. Your money laundering officer 5 Accessibility of the consumer app under the BFSG Web and mobile front ends whose content and presentation your team can adapt and test against the requirements. You, with our input 6 ICT third-party risk and the DORA register of information Service description, subcontractor list, audit and access rights, and exit support for your outsourcing assessment. You, with our input 7 Monthly returns to the Bundesbank (section 29 ZAG) Reporting endpoints and exports on accounts, balances and transactions as the data source. You prepare and file the return. You, on platform data Germany ## Payment rails and providers Rails your customers can use SEPA Credit Transfer SEPA Instant SEPA Direct Debit SWIFT Card payments Internal transfers **24/7**real-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. **17 Jan 2025** DORA applies. BaFin withdrew its ZAIT IT circular for payment and e-money institutions as of 16 January 2025, so DORA is now the IT rulebook. 2. **28 Jun 2025** Germany's Accessibility Strengthening Act (BFSG) covers consumer banking services, your e-money app included. 3. **9 Oct 2025** Verification of Payee applies to every payment service provider in the euro area, e-money institutions included, on all credit transfers, not only instant ones. 4. **9 Apr 2027** E-money institutions in the euro area must be able to send and receive SEPA instant payments. 5. **10 Jul 2027** The EU Anti-Money Laundering Regulation applies directly, adding one set of due diligence rules on top of the German GwG. E-Geld-Institut (EMI) ## Applying to BaFin as an e-money institution? Name us in your application. A section 10 ZAG application must include a security strategy, the outsourcing arrangements and the measures that safeguard customer money. A working app lets you answer those points with something concrete, and we write the technical chapters with you. [Talk to us about your application](https://crassula.io/request-demo/) 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 Security strategy, outsourcing, ICT risk under DORA and business continuity sections of your BaFin application. 3. 03 ### Providers lined up Banking, safeguarding and KYC providers from our network, matched to your licence. ![A customer checking her banking app in a café.](https://crassula.io/static/images/features/people/everyday-1200.e86174e595f2.webp) Digital Banking ## How a launch usually runs Picture a founding team in Berlin building an account for freelancers that puts tax money aside, set up as an e-money institution. Before filing, we configure an environment in their brand: German interface, onboarding for freelancers, virtual cards and sub-accounts for VAT. That environment is what the security strategy and outsourcing chapters of the application describe. While BaFin reviews the file, the team connects its trust account bank and card issuer and rehearses the daily section 17 ZAG reconciliation on test data. Once the licence is granted, the same platform goes live. For the regulatory side, read our [BaFin ZAG licence guide](https://crassula.io/guides/licenses/germany-bafin-zag/) and the overview of [e-money institutions in the EU](https://crassula.io/guides/licenses/electronic-money-institution/). Guides ## Read the licence guides ![Germany BaFin ZAG License in 2026: PI and EMI Authorisation](https://crassula.io/static/images/guides/germany-bafin-zag/berlin-gate-preview-960.087e0cb41d7a.jpg) ### [Germany BaFin ZAG License in 2026: PI and EMI Authorisation](https://crassula.io/guides/licenses/germany-bafin-zag/) ![Electronic Money Institution (EMI) License in 2026: The Complete Guide](https://crassula.io/static/images/guides/electronic-money-institution/emoney-coin-preview-960.54bbaf747450.jpg) ### [Electronic Money Institution (EMI) License in 2026: The Complete Guide](https://crassula.io/guides/licenses/electronic-money-institution/) ![White-Label Mobile Banking in 2026: The Ultimate Guide](https://crassula.io/static/images/guides/white-label-mobile-banking/mobile-banking-pebble-preview-960.412714bbfaf1.jpg) ### [White-Label Mobile Banking in 2026: The Ultimate Guide](https://crassula.io/solutions/mobile-banking-app/guides/white-label-mobile-banking/) ![PSD3 and PSR in 2026: The Complete Transition Guide](https://crassula.io/static/images/guides/psd3-psr/psd3-prism-preview-960.fdc84015d1d8.jpg) ### [PSD3 and PSR in 2026: The Complete Transition Guide](https://crassula.io/guides/licenses/psd3-psr/) [**Explore all guides**Licensing, payments, cards and core banking, explained by our team.](https://crassula.io/guides/) Germany · E-Geld-Institut (EMI) ## FAQ The questions teams ask us before a first call. [**Not covered here?**Bring your question to a demo with our team.](https://crassula.io/request-demo/) How long does BaFin have to decide on a ZAG application? Three months from receipt of a complete application. If information is missing, the clock starts when it arrives, and an application still incomplete after twelve months is refused. Leave room for questions and build the app in parallel. How much initial capital does a German EMI need? At least EUR 350,000 under section 12 ZAG, plus own funds that grow with the e-money you issue. Our [BaFin ZAG guide](https://crassula.io/guides/licenses/germany-bafin-zag/) has the details. Do our customers need a German IBAN? Not legally. The SEPA Regulation bars payers and payees from refusing accounts held in another SEPA country. Employers and landlords do not always comply, so discuss the IBAN country code with your account provider early. Can we offer Wero or girocard? Both depend on agreements you sign yourself. Wero, run by the European Payments Initiative, replaced giropay, which closed at the end of 2024. The platform is not connected to either scheme. Debit cards come from your Visa or Mastercard issuer. How do we safeguard customer funds? Section 17 ZAG gives two routes: keep the money separate in an account at a credit institution by the end of the business day after receipt, or cover it with insurance or a comparable guarantee. The platform supplies the balance per customer, and your finance team owns the reconciliation. Do we need our own licence to use Crassula? No. Many clients start on a licensed partner. This page is for teams that hold or are applying for a BaFin licence as an e-money institution. Germany · E-Geld-Institut (EMI) ## What a German e-money institution can offer its customers Tell us your licence and country. We will map the rails, providers and documents you need. [Request demo](https://crassula.io/request-demo/) [**Know what you pay**One setup fee and a monthly plan with accounts and transactions included.*See pricing →*](https://crassula.io/prices/) [**Start with the API**Documented endpoints for accounts, payments, cards and customers.*Explore the API →*](https://crassula.io/features/api/)