Multipass is a financial services provider offering global business accounts, multi-currency payments, and cross-border transaction solutions.
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Digital Banking
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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.
- Web, iOS and Android apps in your brand
- Interface and notifications in German
- SEPA Instant with payee verification
- System description for your ZAG file
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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.
What the regulator asks about your IT
Each requirement, what the platform gives you for it and who owns it after launch.
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 offA ledger that shows outstanding e-money per customer, with exports for the daily match against your trust account.
Your finance team, on platform dataTwo-factor login and payment confirmation in all three front ends.
CrassulaQuestionnaires by customer type, identity checks through connected providers and per-customer limits. Reviewing suspicious cases stays with you.
Your money laundering officerWeb and mobile front ends whose content and presentation your team can adapt and test against the requirements.
You, with our inputService description, subcontractor list, audit and access rights, and exit support for your outsourcing assessment.
You, with our inputReporting endpoints and exports on accounts, balances and transactions as the data source. You prepare and file the return.
You, on platform data
Payment rails and providers
Rails your customers can use
SEPA Credit TransferSEPA InstantSEPA Direct DebitSWIFTCard paymentsInternal 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
Dates to plan around
Rules that change what you have to build, in the order they apply.
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.
28 Jun 2025
Germany's Accessibility Strengthening Act (BFSG) covers consumer banking services, your e-money app included.
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.
9 Apr 2027
E-money institutions in the euro area must be able to send and receive SEPA instant payments.
10 Jul 2027
The EU Anti-Money Laundering Regulation applies directly, adding one set of due diligence rules on top of the German GwG.
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.
01
A platform you can demonstrate
A configured environment to show the regulator, not slides.
02
The technical part of your application, prepared
Security strategy, outsourcing, ICT risk under DORA and business continuity sections of your BaFin application.
03
Providers lined up
Banking, safeguarding and KYC providers from our network, matched to your licence.
Crassula provides technology and documentation support. We do not provide legal or regulatory advice and cannot guarantee the outcome of an application.
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 and the overview of e-money institutions in the EU.
Read the licence guides
FAQ
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.
At least EUR 350,000 under section 12 ZAG, plus own funds that grow with the e-money you issue. Our BaFin ZAG guide has the details.
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.
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.
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.
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.
