🇫🇷 France vs 🇩🇪 Germany: crypto licensing compared
France and Germany take recognisably different routes to crypto authorisation. In France the route is the MiCA CASP authorisation (French 'agrement PSCA'); replaces the legacy PSAN regime (mandatory AML registration + optional licence). A single authorisation covers the 10 MiCA services. overseen by AMF (Autorite des marches financiers) grants and supervises the CASP authorisation; ACPR (Banque de France) gives binding assent on AML/CFT and prudential aspects via a joint examination team.; in Germany it is the MiCA CASP authorisation granted by BaFin under national law FinmadiG/KMAG; replaces the legacy KWG crypto-custody business licence, with a simplified transition for existing KWG-licensed firms. under BaFin (Bundesanstalt fur Finanzdienstleistungsaufsicht) with Deutsche Bundesbank involvement; applications go to both. Widely regarded as the EU's most demanding CASP regulator.. The two regimes differ on 6 of 9 tracked decision dimensions, including timeline to authorisation and local substance. The free columns below are open to everyone; the decision figures unlock with a pass, each one dated and sourced.
France: verified 2026-07-03 · Germany: verified 2026-07-03
| Dimension |
🇫🇷 France
partly open
Verified 2026-07-03
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🇩🇪 Germany
partly open
Verified 2026-07-03
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|---|---|---|
| Licence type | MiCA CASP authorisation (French 'agrement PSCA'); replaces the legacy PSAN regime (mandatory AML registration + optional licence). A single authorisation covers the 10 MiCA services. | MiCA CASP authorisation granted by BaFin under national law FinmadiG/KMAG; replaces the legacy KWG crypto-custody business licence, with a simplified transition for existing KWG-licensed firms. |
| Regulator | AMF (Autorite des marches financiers) grants and supervises the CASP authorisation; ACPR (Banque de France) gives binding assent on AML/CFT and prudential aspects via a joint examination team. | BaFin (Bundesanstalt fur Finanzdienstleistungsaufsicht) with Deutsche Bundesbank involvement; applications go to both. Widely regarded as the EU's most demanding CASP regulator. |
| Capital requirement | France capital requirement is locked. Unlock with the £349 pass. | Germany capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | France timeline to authorisation is locked. Unlock with the £349 pass. | Germany timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | France local substance is locked. Unlock with the £349 pass. | Germany local substance is locked. Unlock with the £349 pass. |
| Application cost | France application cost is locked. Unlock with the £349 pass. | Germany application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | France ongoing cost is locked. Unlock with the £349 pass. | Germany ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | France passporting is locked. Unlock with the £349 pass. | Germany passporting is locked. Unlock with the £349 pass. |
| MiCA CASPs approved | France mica casps approved is locked. Unlock with the £349 pass. | Germany mica casps approved is locked. Unlock with the £349 pass. |
| Key restrictions | France key restrictions is locked. Unlock with the £349 pass. | Germany key restrictions is locked. Unlock with the £349 pass. |
| Recent changes | France used the full 18-month transition, ending 1 Jul 2026 (today). Deblock first CASP (May 2025), SG-Forge (Oct 2025); ~18 CASPs authorised by 28 May 2026. AMF adopted ESMA staff knowledge/competence guidelines (Mar 2026). | FinmadiG + KMAG in force 27 Dec 2024; Germany used a 12-month grandfathering (apply before 8 Oct 2025; effective end-2025). By mid-2026 the EU's #1 hub - ~57 CASP authorisations (~23% of the EU's ~244), incl. Trade Republic, N26, Commerzbank, Bitpanda. |
| Difficulty rating | France difficulty rating is locked. Unlock with the £349 pass. | Germany difficulty rating is locked. Unlock with the £349 pass. |
The two regimes differ on 6 of 9 tracked decision dimensions, including timeline to authorisation and local substance. Unlock the pass to see each figure with its source and verification date.
What changed recently
🇫🇷 France (verified 2026-07-01): France used the full 18-month transition, ending 1 Jul 2026 (today). Deblock first CASP (May 2025), SG-Forge (Oct 2025); ~18 CASPs authorised by 28 May 2026. AMF adopted ESMA staff knowledge/competence guidelines (Mar 2026).
🇩🇪 Germany (verified 2026-07-01): FinmadiG + KMAG in force 27 Dec 2024; Germany used a 12-month grandfathering (apply before 8 Oct 2025; effective end-2025). By mid-2026 the EU's #1 hub - ~57 CASP authorisations (~23% of the EU's ~244), incl. Trade Republic, N26, Commerzbank, Bitpanda.
Quick answers
Who regulates crypto licensing in France and Germany?
France: AMF (Autorite des marches financiers) grants and supervises the CASP authorisation; ACPR (Banque de France) gives binding assent on AML/CFT and prudential aspects via a joint examination team.. Germany: BaFin (Bundesanstalt fur Finanzdienstleistungsaufsicht) with Deutsche Bundesbank involvement; applications go to both. Widely regarded as the EU's most demanding CASP regulator..
What licence do you need in France compared with Germany?
In France the authorisation route is MiCA CASP authorisation (French 'agrement PSCA'); replaces the legacy PSAN regime (mandatory AML registration + optional licence). A single authorisation covers the 10 MiCA services.; in Germany it is MiCA CASP authorisation granted by BaFin under national law FinmadiG/KMAG; replaces the legacy KWG crypto-custody business licence, with a simplified transition for existing KWG-licensed firms.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full France vs Germany comparison?
The interactive benchmark lets you pin either jurisdiction and add up to five peers; a Founder Pass or Pro subscription unlocks every gated figure with its source and verification date. This page stays free at /crypto/compare/france-vs-germany.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.