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| Dimension |
Pinned 🇩🇪 Germany partly open Verified 2026-08-15
|
🇲🇹 Malta
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 under the Markets in Crypto-Assets Act (Cap. 647); replaces the legacy VFA licence (VFA Act 2018) via a fast-track conversion. Malta granted one of the EU's first full CASP licences (Jan 2025). |
| Regulator | BaFin (Bundesanstalt fur Finanzdienstleistungsaufsicht) with Deutsche Bundesbank involvement; applications go to both. Widely regarded as the EU's most demanding CASP regulator. | Malta Financial Services Authority (MFSA) - single competent authority; a long-standing crypto supervisor since the 2018 VFA regime. |
| Capital requirement | Germany capital requirement is included in the £349 pass. | Malta capital requirement is included in the £349 pass. |
| Timeline to authorisation | Germany timeline to authorisation is included in the £349 pass. | Malta timeline to authorisation is included in the £349 pass. |
| Local substance | Germany local substance is included in the £349 pass. | Malta local substance is included in the £349 pass. |
| Application cost | Germany application cost is included in the £349 pass. | Malta application cost is included in the £349 pass. |
| Ongoing cost | Germany ongoing cost is included in the £349 pass. | Malta ongoing cost is included in the £349 pass. |
| Passporting | Germany passporting is included in the £349 pass. | Malta passporting is included in the £349 pass. |
| MiCA CASPs approved | Germany mica casps approved is included in the £349 pass. | Malta mica casps approved is included in the £349 pass. |
| Key restrictions | Germany key restrictions is included in the £349 pass. | Malta 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. | First-mover: Crypto.com licensed 27 Jan 2025; ~13 CASPs now authorised (OKX, Gemini, Gate, Blockchain.com). ESMA's 10 Jul 2025 peer review criticised the MFSA's authorisation of one CASP, tightening scrutiny. Transition ends 1 Jul 2026. |
| Difficulty rating | Germany difficulty rating is included in the £349 pass. | Malta 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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