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| Dimension |
Pinned 🇫🇷 France partly open Verified 2026-08-15
|
🇩🇪 Germany
partly open
Verified 2026-08-15
|
|---|---|---|
| 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 included in the £349 pass. | Germany capital requirement is included in the £349 pass. |
| Timeline to authorisation | France timeline to authorisation is included in the £349 pass. | Germany timeline to authorisation is included in the £349 pass. |
| Local substance | France local substance is included in the £349 pass. | Germany local substance is included in the £349 pass. |
| Application cost | France application cost is included in the £349 pass. | Germany application cost is included in the £349 pass. |
| Ongoing cost | France ongoing cost is included in the £349 pass. | Germany ongoing cost is included in the £349 pass. |
| Passporting | France passporting is included in the £349 pass. | Germany passporting is included in the £349 pass. |
| MiCA CASPs approved | France mica casps approved is included in the £349 pass. | Germany mica casps approved is included in the £349 pass. |
| Key restrictions | France key restrictions is included in the £349 pass. | Germany key restrictions is included in 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. 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. |
| Difficulty rating | France difficulty rating is included in the £349 pass. | Germany difficulty rating is included in the £349 pass. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.
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