Europe · DE
Germany
BaFin supervises payments, e-money, investment and crypto-asset businesses; online gambling is licensed under the Interstate Treaty on Gambling by the Joint Gambling Authority of the German States.
At a glance
- Status
- EU member state
- Region
- Europe
- Regulated sectors
- GamingPaymentsCryptoInvestment
- Authorities
- BaFin · GGL · FIU
- Licensing routes
- 4
- See also
- EU / MiCA
Overview
The framework
Germany's Interstate Treaty on Gambling permits licensed online sports betting, virtual slot machine games and online poker. Licensing and supervision of these nationwide online products sit with the Joint Gambling Authority of the German States (GGL), while online casino table games are left to the individual federal states.
BaFin is the financial supervisor for banks, payment and e-money institutions, investment firms and crypto-asset service providers under MiCA.
Authorities
Who regulates what
- Federal Financial Supervisory Authority (BaFin)
- Banks, payment and e-money institutions, investment firms and crypto-asset service providers.
- Joint Gambling Authority of the German States (GGL)
- Licensing and supervision of nationwide online gambling products, and enforcement against unlicensed offers.
- Financial Intelligence Unit (FIU)
- Suspicious transaction reporting; part of the customs administration.
Regimes
Licensing routes
Online sports betting, virtual slots and online poker
Nationwide licences under the Interstate Treaty on Gambling, granted by the GGL.
Sectors: Gaming
Payment / e-money institution
BaFin authorisation, passportable across the EEA.
Sectors: Payments
Investment firm
BaFin authorisation under the Investment Firm Act.
Sectors: Investment
MiCA CASP authorisation
Crypto-asset services authorised by BaFin.
Sectors: Crypto
Applications and regulator engagement for these routes are handled by our Regulatory & Licensing practice.
Considerations
What to weigh up
- Product rules under the Interstate Treaty, such as cross-operator deposit limits, shape the offer as much as the licence does.
- Financial licences benefit from EU passporting; gambling licences do not.
This overview is general information, summarised at a high level. Requirements change and depend on the specific activity; seek advice on your circumstances before acting.
Industries
Relevant industries
- iGaming & GamingB2C operators, B2B suppliers, platforms, aggregators and affiliates.
- Fintech & PaymentsPayment and e-money institutions, PSPs and acquirers, payment facilitators and embedded finance.
- Crypto & Digital AssetsCASPs and VASPs, exchanges, custodians, wallets, token projects and crypto payments.
- Forex & InvestmentsForex and CFD brokers, investment firms, trading and investment platforms.
Across jurisdictions
Cross-jurisdiction capabilities
Services we support across the jurisdictions in our directory, described once on their own pages. How each is delivered depends on the local requirements that apply; where local qualification is required, we coordinate locally qualified counsel.
- Privacy & Data ProtectionPrivacy compliance and GDPR programmes, notices and DPAs, DPIAs, data mapping and ROPA, transfers, audits and breach response.
- AML & Financial Crime ComplianceAML/CFT programmes, MLRO-as-a-Service, independent AML/CFT audits, risk assessments, monitoring, sanctions and inspection support.
- IP Registration & ProtectionTrademark and patent registration and protection, copyright protection, domain name disputes, portfolio support and IP agreements.
- Legal OpinionsRegulatory, business model, perimeter, payment, gaming, crypto-asset and cross-border opinions for banks, partners and investors.
- Bank Account OpeningSupport with corporate and operational accounts at banks and EMIs, prepared for how their compliance teams assess high-risk businesses.
- Merchant Account / Acquiring SetupSupport with merchant account applications and acquiring setup at acquirers and PSPs, including for high-risk merchant categories.
Support
How we support businesses in Germany
- Regulatory & Licensing01Strategy, applications and regulator engagement for the gaming, payments, crypto and investment routes listed above.
- Corporate Structuring02Group architecture, incorporation, substance and governance built around your licences, banking and investors.
- Market Entry & Regulatory Strategy10Market prioritisation, regulatory roadmaps and launch readiness for businesses expanding into new jurisdictions.
- Information Security & Technology Compliance06DORA, NIS2 and the information security obligations that apply under EU law.
Discuss your matter with a senior advisor.
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