GermanCryptoLicenceCost—BaFinFees.

What is the total budget for a German crypto licence?

Budget €200,000–€500,000 total: professional fees (€15,000–€50,000), BaFin fees (€5,000–€15,000), entity formation, and the minimum regulatory capital (€125,000+ for KWG custody, higher for MiCAR).

Is the minimum regulatory capital a cost?

It must be maintained on an ongoing basis (not just at application). For KWG crypto custody, minimum capital is typically €125,000. This is equity in your business, not a fee.

Are there cheaper ways to get EU crypto exposure?

Some opt for a Lithuanian or Estonian crypto licence (cheaper, lower capital), then passport to Germany. We advise on the trade-offs — Germany generally offers stronger credibility with institutional clients.

What happens if BaFin rejects the application?

BaFin typically issues preliminary concerns before formal rejection, giving opportunity to address deficiencies. We manage this process to maximise approval probability.

What are BaFin ongoing annual supervision fees for a CASP?

BaFin charges annual supervision fees under FinDAG §16e, calculated based on balance sheet totals and business volume. For a small CASP (balance sheet under €10M), annual BaFin fees are typically €10,000–€30,000. These are statutory government fees — they cannot be reduced or negotiated. Budget BaFin annual fees as a fixed ongoing operating cost from the first year of authorisation.

Can I begin crypto operations while the BaFin application is pending?

No. Under MiCA Art. 59, a CASP may not provide crypto-asset services without BaFin authorisation. Operating without a licence is a criminal offence under German MiCAR implementation law. Grandfathering provisions exist only for entities that held a valid KWG §32 crypto custody licence before the MiCAR transition. Do not begin operations before receiving the written BaFin authorisation decision.

How much does a MiCAR White Paper preparation cost?

A full MiCAR White Paper (Art. 4–21) covering project description, token economics, risk factors, rights of holders, and redemption procedures typically costs €10,000–€30,000 in legal and compliance preparation fees. For asset-referenced tokens (ARTs) and e-money tokens (EMTs), BaFin pre-approval requirements increase complexity and cost further. Our fee includes White Paper drafting and BaFin notification filing.

What happens to the regulatory capital if BaFin rejects the application?

The minimum own funds remain in the company and are available for return to shareholders or redeployment into a new business purpose. Capital is not seized or paid to BaFin. BaFin application fees (€5,000–€15,000) are non-refundable regardless of outcome. Professional service fees are also non-refundable. This is why thorough pre-application readiness assessment reduces risk.

Are DORA compliance costs included in the professional fee?

Our CASP application fee includes initial DORA compliance documentation — ICT risk management framework, incident reporting procedures, and digital resilience testing protocols required for the BaFin application. Ongoing annual DORA compliance (testing, third-party ICT provider assessments, annual reviews) requires specialist cybersecurity firms — typically €10,000–€30,000/year additional — and is included in our ongoing compliance retainer at the Scale level.

Is EU passporting of a German MiCAR licence free?

The BaFin passporting notification to ESMA under MiCA Art. 65 incurs no BaFin fee. However, the target member state's national competent authority may charge a registration or notification fee (typically €500–€2,000 per country). Our professional fee for preparing and filing the passporting notification is approximately €1,500–€2,500 per country. The 10-business-day notification process then allows services to begin in the new jurisdiction.