🇩🇪 Germany vs 🇵🇹 Portugal: crypto licensing compared
On paper, Germany's 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. and Portugal's MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration. answer the same question; in practice the detail decides it. The two regimes differ on 6 of 9 tracked decision dimensions, including timeline to authorisation and local substance. This page compares the two side by side: the identity columns are free, the decision figures are one pass away, and every cell shows when it was last checked.
Germany: verified 2026-07-03 · Portugal: verified 2026-07-01
| Dimension |
🇩🇪 Germany
partly open
Verified 2026-07-03
|
🇵🇹 Portugal
partly open
Verified 2026-07-01
|
|---|---|---|
| Licence type | 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. | MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration. |
| Regulator | BaFin (Bundesanstalt fur Finanzdienstleistungsaufsicht) with Deutsche Bundesbank involvement; applications go to both. Widely regarded as the EU's most demanding CASP regulator. | Twin-peaks: BANCO DE PORTUGAL is the CASP authorisation authority + prudential/AML supervisor (single application front door); CMVM is the conduct-of-business and market-abuse supervisor. (Corrects the seed - not CMVM-led.) |
| Capital requirement | Germany capital requirement is locked. Unlock with the £349 pass. | Portugal capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Germany timeline to authorisation is locked. Unlock with the £349 pass. | Portugal timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Germany local substance is locked. Unlock with the £349 pass. | Portugal local substance is locked. Unlock with the £349 pass. |
| Application cost | Germany application cost is locked. Unlock with the £349 pass. | Portugal application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Germany ongoing cost is locked. Unlock with the £349 pass. | Portugal ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Germany passporting is locked. Unlock with the £349 pass. | Portugal passporting is locked. Unlock with the £349 pass. |
| MiCA CASPs approved | Germany mica casps approved is locked. Unlock with the £349 pass. | Portugal mica casps approved is locked. Unlock with the £349 pass. |
| Key restrictions | Germany key restrictions is locked. Unlock with the £349 pass. | Portugal key restrictions is locked. Unlock with the £349 pass. |
| Recent changes | 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. | Lei 69/2025 (MiCA) + Lei 70/2025 (Travel Rule) published 22 Dec 2025 - ~1 year late. Legacy-VASP transitional window closes 1 Jul 2026 (today). Few Portugal-AUTHORISED CASPs so far. |
| Difficulty rating | Germany difficulty rating is locked. Unlock with the £349 pass. | Portugal 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
🇩🇪 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.
🇵🇹 Portugal (verified 2026-07-01): Lei 69/2025 (MiCA) + Lei 70/2025 (Travel Rule) published 22 Dec 2025 - ~1 year late. Legacy-VASP transitional window closes 1 Jul 2026 (today). Few Portugal-AUTHORISED CASPs so far.
Quick answers
Who regulates crypto licensing in Germany and Portugal?
Germany: BaFin (Bundesanstalt fur Finanzdienstleistungsaufsicht) with Deutsche Bundesbank involvement; applications go to both. Widely regarded as the EU's most demanding CASP regulator.. Portugal: Twin-peaks: BANCO DE PORTUGAL is the CASP authorisation authority + prudential/AML supervisor (single application front door); CMVM is the conduct-of-business and market-abuse supervisor. (Corrects the seed - not CMVM-led.).
What licence do you need in Germany compared with Portugal?
In Germany the authorisation route 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.; in Portugal it is MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Germany vs Portugal 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/germany-vs-portugal.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.