🇩🇪 Germany vs 🇵🇹 Portugal: crypto licensing compared
Decision context and regulator route
Germany's public 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 public MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration. are set out side by side. Licence type, regulator and public recent-change notes are open; the full dated and sourced comparison is included with access.
Germany: verified 2026-08-01 · Portugal: verified 2026-08-15
| Dimension |
🇩🇪 Germany
partly open
Verified 2026-08-01
|
🇵🇹 Portugal
partly open
Verified 2026-08-15
|
|---|---|---|
| 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 included in the £349 pass. | Portugal capital requirement is included in the £349 pass. |
| Timeline to authorisation | Germany timeline to authorisation is included in the £349 pass. | Portugal timeline to authorisation is included in the £349 pass. |
| Local substance | Germany local substance is included in the £349 pass. | Portugal local substance is included in the £349 pass. |
| Application cost | Germany application cost is included in the £349 pass. | Portugal application cost is included in the £349 pass. |
| Ongoing cost | Germany ongoing cost is included in the £349 pass. | Portugal ongoing cost is included in the £349 pass. |
| Passporting | Germany passporting is included in the £349 pass. | Portugal passporting is included in the £349 pass. |
| MiCA CASPs approved | Germany mica casps approved is included in the £349 pass. | Portugal mica casps approved is included in the £349 pass. |
| Key restrictions | Germany key restrictions is included in the £349 pass. | Portugal key restrictions is included in 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. BaFin's KMAnzV notification ordinance under KMAG (issued 20 May 2026, Federal Gazette 26 May 2026) standardises CASP notification forms and procedures. ESMA's interim register recorded 61 German CASP entries at its 24 July 2026 refresh, including cooperative banks Raiffeisenbank Auerbach-Freihung eG (19 June 2026) and Volksbank Schwarzwald-Donau-Neckar eG (2 July 2026), both for order execution only. | Lei 69/2025 (MiCA) and Lei 70/2025 (Travel Rule) published 22 Dec 2025, about a year late. The legacy-VASP transitional window closed 1 Jul 2026. Bison Bank became Portugal's first MiCA-authorised CASP in late Jun 2026, following approval from Banco de Portugal and the CMVM. |
| Difficulty rating | Germany difficulty rating is included in the £349 pass. | Portugal difficulty rating is included in the £349 pass. |
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What changed recently
🇩🇪 Germany (verified 2026-08-01): 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. BaFin's KMAnzV notification ordinance under KMAG (issued 20 May 2026, Federal Gazette 26 May 2026) standardises CASP notification forms and procedures. ESMA's interim register recorded 61 German CASP entries at its 24 July 2026 refresh, including cooperative banks Raiffeisenbank Auerbach-Freihung eG (19 June 2026) and Volksbank Schwarzwald-Donau-Neckar eG (2 July 2026), both for order execution only.
🇵🇹 Portugal (verified 2026-07-10): Lei 69/2025 (MiCA) and Lei 70/2025 (Travel Rule) published 22 Dec 2025, about a year late. The legacy-VASP transitional window closed 1 Jul 2026. Bison Bank became Portugal's first MiCA-authorised CASP in late Jun 2026, following approval from Banco de Portugal and the CMVM.
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.