Lithuania vs Germany: CASP authorisation compared
Germany has the largest authorised population in Europe and almost none of it does what a crypto business does. The headline number and the useful number point in opposite directions.
Eighty-nine authorisations against Lithuania's four looks decisive until you read what they are authorised to do. Germany licensed crypto custody as a banking business under the KWG from 2020, so its supervisory relationship with crypto began inside the banking system, and the register still shows that.
| Criterion | Lithuania | Germany |
|---|---|---|
| Regulator | Bank of Lithuania | Federal Financial Supervisory Authority (BaFin) |
| Legal framework | MiCA, with Lithuanian implementing law | MiCA. Germany licensed crypto custody as a banking business under the KWG from 2020. |
| Old regime transitional period | Ended 31 December 2025 | 12 months from 30 December 2024, the same as Lithuania. Reported to ESMA by the national authority. |
| Application fee | Not located on the regulator’s pages. Consultancy sites circulate a figure; no Lithuanian instrument found to support it. | Not read. BaFin restructured its site and the crypto pages did not resolve. |
| Supervisory fee | Not located on the regulator’s pages. | Not read, for the same reason. |
| Language of application | Not stated on the pages read. | Not read, for the same reason. |
| How it is submitted | Not stated on the pages read. | Not read, for the same reason. |
| Pre-application support | No published pre-application stage found on the pages read. | Not read, for the same reason. |
| Completeness check | 25 working days (MiCA Article 63(2)) | 25 working days (MiCA Article 63(2)) |
| Decision period | 40 working days from a complete application (MiCA Article 63(9)) | 40 working days from a complete application (MiCA Article 63(9)) |
| Clock suspension | Up to 20 working days (MiCA Article 63(12)) | Up to 20 working days (MiCA Article 63(12)) |
| Domestic authorisations granted | Four Article 63 authorisations, plus two entities providing services under Article 60(4): six entries in the ESMA register | 89 in the ESMA register, all under Article 63. The largest home state in the EEA. |
What is identical, because MiCA harmonises it
The service list, the Annex IV capital classes, the Article 67 fixed-overheads test, the application contents, the establishment conditions, the governance requirements, the refusal grounds and the passporting mechanism are the same in both. The full list, stated once.
What actually differs
The German population executes orders. It does not hold assets.
Counted from the ESMA register, this is the sharpest difference between any two jurisdictions on this site.
| Permission | Germany (n=89) | Lithuania (n=6) |
|---|---|---|
| Execution of orders on behalf of clients | 69% | 33% |
| Custody and administration of crypto-assets | 18% | 100% |
| Exchange of crypto-assets for funds | 17% | 50% |
Two thirds of German CASPs may execute client orders. Fewer than a fifth may hold client crypto-assets. That is the signature of an incumbent financial sector adding crypto trading for existing customers while a third party does the custody. Around two in five of the German entries carry a bank or AG name: Trade Republic, N26 Bank, flatexDEGIRO, Baader Bank, Boerse Stuttgart Digital, EUWAX.
Two of the 89 hold a trading-platform permission. Lithuania has none, and neither does any other Baltic state, so on that specific service the comparison is between two and zero rather than between 89 and four.
Germany took the same transitional period as Lithuania
Both reported 12 months to ESMA, against 18 for Malta, Cyprus and Estonia and six for Latvia. From 30 December 2024 that put both deadlines at the end of December 2025. On this axis the two are not different at all.
Who Lithuania suits better
- Firms whose model is custody or exchange. Every Lithuanian CASP holds a custody permission and half may exchange crypto for funds, so the supervisory conversation starts from a familiar place rather than an unusual one.
- Applicants who would rather not be a small file in the largest caseload in Europe.
- Anyone weighing operating costs, where the Baltic base is materially below Germany's.
Who Germany suits better
- Regulated institutions adding crypto execution to an existing client base, which is what most of the German register is.
- Firms that already hold a German banking or investment permission, where BaFin is the incumbent supervisor and the Article 63(5) consultation stays in one place.
- Businesses whose customers are German and who value a domestic regulator for reasons of distribution rather than of law, since the law does not require it.
What the choice actually costs
Annex IV asks the same of both, so capital is not the variable. Neither is the fee, which this page does not state because BaFin relaunched its website and the crypto pages no longer resolve.
The variable is the shape of the firm you have to build. A German file is assessed by an authority whose crypto caseload is overwhelmingly banks and brokers, which sets an implicit reference point for governance and documentation that a six-person startup meets at some expense. Add that Article 67 ties your capital to a quarter of fixed overheads, and the staffing needed to look ordinary in Frankfurt raises the number you have to hold. The calculation.
What this page could not verify
- BaFin pages: unavailable. The site was relaunched and the crypto URLs return 404, so no German fee, language, submission channel or pre-application process is stated here.
- ESMA register: full text, read 15 September 2026, file last updated 31 August 2026. The percentages above are counted from it and move as it does.
- The reading of the German population as bank-led is an inference from permissions and entity names, not a statement by BaFin.
- Salary comparisons are our assessment and carry no figure.
Primary sources
- Read 2026-09-11 Bank of Lithuania: transitional period ends 31 December 2025
- Read 2026-09-11 Bank of Lithuania: fourth CASP authorisation granted
- Read 2026-09-15 · full text ESMA: interim MiCA register of crypto-asset service providers (CASPS.csv, last updated 31 August 2026)
- Read 2026-09-15 · full text ESMA: list of grandfathering periods decided by Member States under Article 143(3)
- Read 2026-09-15 · unavailable BaFin: crypto supervision pages
Questions
How many CASPs are authorised in Germany?
The ESMA register listed 89 entries with BaFin as competent authority when it was read on 15 September 2026, every one of them an authorisation under Article 63. That is the largest population of any home state in the European Economic Area, roughly two and a half times the next largest.
Is Germany a good jurisdiction for a crypto exchange?
The register suggests it is not where exchanges have gone. Only 18% of German CASPs hold a custody permission and 17% may exchange crypto-assets for funds, against 69% authorised to execute orders. The German population is dominated by banks and brokers routing client orders rather than firms holding client assets or running a book.
Does Germany have a shorter transitional period than other Member States?
Germany reported 12 months to ESMA, the same as Lithuania, against the 18 months taken by Malta, Cyprus and Estonia. Running from 30 December 2024, that placed the German deadline at the end of December 2025. ESMA notes that some reported periods had not been written into national law when its list was published.
Do I need a German entity to serve German clients?
No. An authorisation from any Member State passports into Germany under Article 65 by notification, and Article 59(7) removes any requirement for a physical presence in the host state. Choosing Germany as a home state is a decision about which authority supervises you, not about which market you can sell into.
Regulatory references on this page were read against the primary text on 15 September 2026. Every figure is held in the source register with the document it came from.