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| Dimension |
Pinned 🇩🇪 Germany partly open Verified 2026-08-15
|
🇱🇺 Luxembourg
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 granted by the Commission de Surveillance du Secteur Financier (CSSF) |
| Regulator | BaFin (Bundesanstalt fur Finanzdienstleistungsaufsicht) with Deutsche Bundesbank involvement; applications go to both. Widely regarded as the EU's most demanding CASP regulator. | Commission de Surveillance du Secteur Financier (CSSF) |
| Capital requirement | Germany capital requirement is included in the £349 pass. | Luxembourg capital requirement is included in the £349 pass. |
| Timeline to authorisation | Germany timeline to authorisation is included in the £349 pass. | Luxembourg timeline to authorisation is included in the £349 pass. |
| Local substance | Germany local substance is included in the £349 pass. | Luxembourg local substance is included in the £349 pass. |
| Application cost | Germany application cost is included in the £349 pass. | Luxembourg application cost is included in the £349 pass. |
| Ongoing cost | Germany ongoing cost is included in the £349 pass. | Luxembourg ongoing cost is included in the £349 pass. |
| Passporting | Germany passporting is included in the £349 pass. | Luxembourg passporting is included in the £349 pass. |
| MiCA CASPs approved | Germany mica casps approved is included in the £349 pass. | Luxembourg mica casps approved is included in the £349 pass. |
| Key restrictions | Germany key restrictions is included in the £349 pass. | Luxembourg 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. | Rapid growth in H1 2026: as of 30 June 2026, 11 active CASPs including B2C2 Europe, Banking Circle, Bitstamp Europe, Bridge Building, Clearstream Banking, Coinbase Luxembourg, Stokr, Standard Chartered Luxembourg, Swissquote Bank Europe, Zodia Custody Europe and BitFlyer; BitFlyer authorised 26 June 2026, Stokr 22 June 2026, Bridge Building 29 June 2026, all just before the transitional deadline expired on 1 July 2026 |
| Difficulty rating | Germany difficulty rating is included in the £349 pass. | Luxembourg 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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