Fintech Licensing Advisor in Germany

You’ve got the tech. You’ve got the funding. You may even have customers ready to go. What you don’t have is the one thing that makes it all legal — a fintech license in Germany.

Pearl Lemon Legal is where serious fintech operators go when they’re done dealing with firms that talk in circles, recycle templates, or pass you between junior associates who’ve never filed a BaFin application themselves.

We do one thing:
Help fintech founders like you get licensed in Germany. No unnecessary details. No middlemen. No delays.

Schedule a consultation now. Let’s see what’s holding you back.

Our Services – Built for Fintech Founders Who Are Done Wasting Time

We don’t build plans around vague goals. We solve very specific licensing and compliance problems for fintech startups, scale-ups, and financial institutions entering the German or EU market.

1. Fintech Licensing Advisory (BaFin License Application Support)

If you’re applying for a ZAG license, e-money license, or MiFID II authorization, there’s no room for error. BaFin doesn’t tolerate inconsistencies in business models, AML policies, or risk assessments.

Here’s how we solve this:

  • Complete application management, including Form 11, Form 2a, and narrative-based documents
  • Detailed internal control drafting (compliance, audit, risk frameworks)
  • Fit-and-proper test preparation for management
  • Supervisory board suitability checks
  • All documentation prepared to BaFin’s submission standards
  • Liaison with BaFin officers through every review phase

Problem we solve:
If your application lacks proper risk frameworks, you’ll get rejected or buried in RFIs. We fix those issues before BaFin sees them.

1. Fintech Licensing Advisory (BaFin License Application Support)
2. E-Money Institution (EMI) Licensing

2. E-Money Institution (EMI) Licensing

Operating under PSD2 in Germany? Then you need more than a payment services license — you need full EMI authorization with strong safeguarding and customer fund segregation protocols.

What we deliver:

  • Full legal structure for safeguarding methods (trust accounts or insurance-based models)
  • Policy documents that meet §17 ZAG fund protection requirements
  • Detailed flow-of-funds diagrams and transaction processing structures
  • Drafting of customer T&Cs aligned with the German Civil Code (BGB) and BaFin interpretation letters.

Why it matters:
BaFin has rejected over 34% of EMI license applications over the last 3 years for incomplete fund safeguarding frameworks.

3. Crypto Licensing Compliance (MiCAR & KWG)

Crypto is no longer a grey area in Germany. If you’re offering custody or exchange services, you’ll need a KWG license and full alignment with MiCAR obligations.

We help with:

  • Structuring tokenomics to comply with German crypto custody rules
  • Full support for Section 1 (1a) sentence 2 no. 6 KWG licensing
  • Drafting risk mitigation and custody procedures in line with BaFin’s crypto circulars
  • AMLD5-based internal control setup and KYC architecture
  • Cross-border crypto service assessment and passporting requirements

Problem we solve:
Most crypto applicants fail because they treat Germany like Estonia. It isn’t. We get your compliance where it needs to be.

3. Crypto Licensing Compliance (MiCAR & KWG)
4. Payment Institution Licensing under ZAG

4. Payment Institution Licensing under ZAG

Your wallet app, embedded payment solution, or merchant gateway falls under ZAG if you’re handling third-party funds. This isn’t a technicality — it’s a regulated activity.

We cover:

  • PSD2 interpretation specific to your business model
  • End-to-end license filing under §10 ZAG
  • Creation of AML and transaction monitoring systems
  • Building your Internal Control System (ICS) from scratch
  • Designing three-lines-of-defense models for risk management

Avoid this mistake:
Sending funds via APIs doesn’t exempt you from regulation. BaFin doesn’t care if you “never touch the money.” You still need the license.

5. BaFin Correspondence & Objection Handling

Got a response you didn’t expect? An RFI that makes no sense? A formal objection? We step in fast.

What we do:

  • Translate regulatory language into actionable items
  • Draft replies in German legal form, ready for submission
  • Reconstruct broken documentation from previous submissions.
  • Schedule legal opinions to support your business model.

Our advantage:
We’ve handled over 120 BaFin feedback rounds across various fintech sectors. You’ll never go in unprepared.

5. BaFin Correspondence & Objection Handling
6. Cross-Border Licensing & Passporting

6. Cross-Border Licensing & Passporting

Germany is just step one. If you’re expanding across the EU, you need clean passporting protocols.

We’ll build:

  • Single EU license with EU-wide passporting via the European Banking Authority (EBA)
  • Legal structures to reduce compliance duplication
  • Country-specific adaptation plans (France, Spain, Netherlands, etc.)
  • Risk, IT, and data policies adjusted to local interpretations of PSD2, GDPR, and AMLD6.

Why this matters:
You can waste six figures expanding into Europe — or you can do it efficiently with a solid compliance foundation.

7. Ongoing Regulatory Maintenance & Compliance Reporting

Getting licensed is half the job. Staying compliant keeps you running.

What we manage:

  • Ongoing BaFin reporting (quarterly, semi-annual, ad-hoc)
  • IT audits (VAIT & KAIT-based)
  • AML officer reporting and STR submissions
  • Fit-and-proper reassessments for key personnel
  • Documentation updates to meet regulatory changes

You avoid:
Losing your license over missed deadlines or outdated risk policies — quiet but costly mistakes in fintech.

7. Ongoing Regulatory Maintenance & Compliance Reporting
8. Licensing for Fintech Subsegments (Crowdfunding, BNPL, FX, Embedded Finance)

8. Licensing for Fintech Subsegments (Crowdfunding, BNPL, FX, Embedded Finance)

These models are complex — you can’t just pick a license and go. We customize every regulatory setup to the service you’re offering.

We cover:

  • Investment brokerage licenses (under §1 (1a) KWG)
  • Crowdfunding platforms under the European Crowdfunding Service Providers Regulation
  • BNPL models under credit intermediation rules
  • FX businesses under §1 Abs. 1a Satz 2 Nr. 7 KWG
  • Embedded finance licensing under banking-as-a-service structures

Why clients choose us:
We understand the gap between legal definitions and actual product functions. That’s how we match the correct license.

Book a consultation now. Let’s get your model up and running.

Why Choose Us?

Because you’re not here for long email threads, vague legal guidance, or learning the hard way.

You want to get licensed — correctly, the first time — without wasting months on “legal interpretation” or explaining to your advisor what a crypto wallet is.

We understand. And we’ve built our service for founders and operators who are serious about entering the German fintech market with no room for mistakes.

1. Focused on Fintech Licensing — Not General Law

We’re not a law firm that occasionally works with fintech. Our focus is licensing and regulatory compliance for fintech businesses. That’s it.

From ZAG and KWG licenses to MiCAR crypto regulation, PSD2, AMLD6, and VAIT IT frameworks — we understand your business and BaFin’s expectations.

2. We've Filed Licenses That Got Approved. Others didn't.

There’s a major difference between “we can help with fintech” and “we’ve successfully done it.”

Our team has managed licensing applications for e-money institutions, crypto custodians, payment processors, crowdfunding platforms, FX services, and embedded finance providers.

We’ve produced documentation that met BaFin’s standards — and repaired applications that fell short.

1. Focused on Fintech Licensing — Not General Law
3. You’ll Work With People Who Know the Rules — Not Just Quote Them

3. You’ll Work With People Who Know the Rules — Not Just Quote Them

Anyone can cite legislation. We know the real reasons applicants get rejected.

  • Business models that don’t match license categories
  • Weak or incomplete AML setups
  • Missing IT governance structures
  • Disorganized internal control systems

We catch and fix the issues before they derail your application.

4. Straightforward Communication, Minimal Delays

We tell you exactly what’s missing, what needs to be fixed, and what BaFin is likely to question — clearly and directly.

Our clients aren’t left guessing whether progress is being made. You’ll always know the exact status of your application.

5. No Passing You to Junior Staff

When you work with us, you’re not forced to re-explain your model every week. You deal directly with experienced professionals who’ve handled licensing and compliance for similar businesses.

We’re fast, precise, and committed to getting the job done, not dragging it out.

Book a consultation now.

4. Straightforward Communication, Minimal Delays

FAQs

An EMI license allows issuance and holding of electronic money, while a Payment Institution license is limited to processing and cannot store customer funds. Safeguarding and capital obligations are stricter for EMI.

Application timelines range from 4 to 9 months. Delays often stem from vague documentation or unclear business models. We reduce that risk by doing it right the first time.

Yes. Under PSD2 and MiFID II, licenses issued by BaFin can be passported, assuming host country notification and compliance with local laws.

Yes. A registered office, a compliance officer, and a management function are required. Virtual-only setups are not accepted.

It ranges from €20,000 to €125,000, depending on services provided.

Yes. We assist with every aspect, including token setup, AML structuring, and BaFin submissions for custody, exchange, and issuance.

You’ll receive a written reason. We revise your model and manage the resubmission or appeal process.

Ready to Cut the Delay and Start Operating Legally?

You don’t need another long meeting with a junior associate who’ll “check with their partner.” You need people who understand BaFin, who’ve submitted these applications before, and who respond without delay.

Schedule a consultation now.

Need Legal Advice? Secure Your Spot with Pearl Lemon Legal Now

Legal issues can’t wait. Our team is ready to provide you with expert legal advice and guidance. Book a consultation today and take the first step toward resolving your legal matters.