Germany
BaFin commonly expects ~2–3× the statutory minimum during § 32 KWG / ZAG own-funds review, scaled by transaction volume and risk profile. The two-MD rule and operational complexity drive the cushion higher than peer NCAs.
PSD2 Article 12 statutory clock = 3 months from complete file. BaFin's realistic timeline reflects the pre-application completeness cycle, which routinely runs 6–12 months.
Specific BaFin fee schedule under § 14 ZAG. Higher fees apply to credit-institution authorisation under § 32 KWG.
BaFin's ongoing supervision is funded by the supervised entity. Annual contribution scales with gross income and balance-sheet size — typically €15,000–€100,000+ for an active EMI/PI.
BaFin enforces the two-MD rule (two managing directors with executive authority in Germany) under § 32 KWG and similar under ZAG. Inspections regularly probe local hours of senior management.
Tier-1 EU clearing concentrated in Germany; BaFin-authorised firms travel well across global correspondent networks. CASP onboarding remains conservative even at Tier-1.
- Strongest supervisory pedigree in the EEA — BaFin authorisation is the most-recognised in Tier-1 correspondent conversations
- Largest single euro-clearing-bank concentration in the EEA
- Two-MD rule, while costly, is what drives the institutional credibility
- Longest realistic authorisation cycle in the EEA at 9–18 months
- Heaviest substance bar — two MDs, German management, real local presence
- BaFin moves slowly on novel crypto activity; CASP class 2/3 authorisations take longest here
BaFin authorisation is the gold standard for institutions targeting Tier-1 EU correspondents and serving German operating markets. Worth the timeline if Germany is the actual operating market — not worth it as a passporting shell.