🇩🇪 Germany vs 🇬🇧 United Kingdom: crypto licensing compared
Choosing between Germany and United Kingdom for a crypto licence starts with who you will answer to: BaFin (Bundesanstalt fur Finanzdienstleistungsaufsicht) with Deutsche Bundesbank involvement; applications go to both. Widely regarded as the EU's most demanding CASP regulator. on one side, Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers. on the other, via 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. and the Today: FCA registration under the Money Laundering Regs 2017 (AML/CTF only). Incoming: full FSMA authorisation for cryptoassets (SI 2026/102, made 4 Feb 2026, laid 5 Feb) - gateway opens 30 Sep 2026, mandatory regime commences 25 Oct 2027; no automatic conversion from MLR registration. respectively. The two regimes differ on 8 of 9 tracked decision dimensions, including capital requirement and timeline to authorisation. Every figure behind the comparison carries a last-verified date and a primary source.
Germany: verified 2026-07-03 · United Kingdom: verified 2026-07-03
| Dimension |
🇩🇪 Germany
partly open
Verified 2026-07-03
|
🇬🇧 United Kingdom
Free in full
Verified 2026-07-03
|
|---|---|---|
| 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. | Today: FCA registration under the Money Laundering Regs 2017 (AML/CTF only). Incoming: full FSMA authorisation for cryptoassets (SI 2026/102, made 4 Feb 2026, laid 5 Feb) - gateway opens 30 Sep 2026, mandatory regime commences 25 Oct 2027; no automatic conversion from MLR registration. |
| Regulator | BaFin (Bundesanstalt fur Finanzdienstleistungsaufsicht) with Deutsche Bundesbank involvement; applications go to both. Widely regarded as the EU's most demanding CASP regulator. | Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers. |
| Capital requirement | Germany capital requirement is locked. Unlock with the £349 pass. | No minimum initial capital under the current MLR registration. The incoming FSMA regime's final prudential rules (PS26/12, 30 Jun 2026) set Permanent Minimum Requirements by activity: GBP 75,000 (arranging/dealing as agent), 150,000 (custody, trading platform, staking), 350,000 (stablecoin issuance), 750,000 (dealing as principal). |
| Timeline to authorisation | Germany timeline to authorisation is locked. Unlock with the £349 pass. | MLR registration: 3-month statutory clock from a COMPLETE application, but realistically ~9-12 months including pre-application; historically low approval rate. |
| Local substance | Germany local substance is locked. Unlock with the £349 pass. | Business must be carried on in the UK (UK entity in practice); an MLRO / nominated officer (Reg 21(3)) who is UK-based, genuinely competent, independent and closely involved. |
| Application cost | Germany application cost is locked. Unlock with the £349 pass. | FCA application fee GBP 11,150 (Category 6, non-refundable) plus typically GBP 50k-150k in professional fees; ~GBP 90k all-in representative (~EUR 105k at 1.16). |
| Ongoing cost | Germany ongoing cost is locked. Unlock with the £349 pass. | Annual FCA periodic fee under fee-block G.30 (renumbered from G.23): minimum GBP 2,229 for 2025/26 plus GBP 15.13 per GBP 1,000 of cryptoasset income above GBP 100,000. Plus AML operations, annual audit and compliance headcount; costs rise materially under the incoming FSMA regime. |
| Passporting | Germany passporting is locked. Unlock with the £349 pass. | No - post-Brexit the UK regime is standalone; no EU/EEA passport and no MiCA equivalence in either direction. |
| MiCA CASPs approved | Germany mica casps approved is locked. Unlock with the £349 pass. | Not applicable: non-MiCA jurisdiction, no CASP regime. See this jurisdiction's own licence route. |
| Key restrictions | Germany key restrictions is locked. Unlock with the £349 pass. | Cryptoasset financial promotions regime (since 8 Oct 2023): mandatory risk warnings, 24-hour cooling-off for first-timers, ban on incentives; plus significant bank de-risking / de-banking of crypto firms. |
| 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. | SI 2026/102 made 4 Feb 2026 (laid 5 Feb); FCA final rules published 30 Jun 2026 (PS26/10 stablecoins, PS26/11 regulated activities, PS26/12 prudential); authorisation gateway 30 Sep 2026-28 Feb 2027; mandatory FSMA regime from 25 Oct 2027. |
| Difficulty rating | Germany difficulty rating is locked. Unlock with the £349 pass. | 4 - rigorous AML bar, historically low approval rate and severe bank-access friction; the incoming FSMA prudential/conduct regime raises the bar further. |
The two regimes differ on 8 of 9 tracked decision dimensions, including capital requirement and timeline to authorisation. 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.
🇬🇧 United Kingdom (verified 2026-07-03): SI 2026/102 made 4 Feb 2026 (laid 5 Feb); FCA final rules published 30 Jun 2026 (PS26/10 stablecoins, PS26/11 regulated activities, PS26/12 prudential); authorisation gateway 30 Sep 2026-28 Feb 2027; mandatory FSMA regime from 25 Oct 2027.
Quick answers
Who regulates crypto licensing in Germany and United Kingdom?
Germany: BaFin (Bundesanstalt fur Finanzdienstleistungsaufsicht) with Deutsche Bundesbank involvement; applications go to both. Widely regarded as the EU's most demanding CASP regulator.. United Kingdom: Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers..
What licence do you need in Germany compared with United Kingdom?
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 United Kingdom it is Today: FCA registration under the Money Laundering Regs 2017 (AML/CTF only). Incoming: full FSMA authorisation for cryptoassets (SI 2026/102, made 4 Feb 2026, laid 5 Feb) - gateway opens 30 Sep 2026, mandatory regime commences 25 Oct 2027; no automatic conversion from MLR registration.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Germany vs United Kingdom 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-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.