DE v13.3.0

Germany (DE) · Module Detail

Germany: Stablecoins & Digital Money

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Euro stablecoins regulated as EMTs under MiCAR; KMAG implements MiCAR domestically arming BaFin name-and-warn powers; EURAU (AllUnity) first MiCA-authorised German euro stablecoin (1 July 2025); grandfathering closed end-2025.

Key judgment — Probable · impact ELEVATEDBaFin's refusal of futurum bank AG's MiCAR authorisation is the cycle's most material German payments-adjacent development, demonstrating that Germany's accelerated national MiCA transition cut-off carries real enforcement consequence for an established large retail platform.claims: wpm-2026-W42-001
Standing sub-brief · as of 27 June 2026240 words · last cycle 2026-07-07

Stablecoins & Digital Money

MiCAR (Reg (EU) 2023/1114) is directly applicable, and Germany enacted the Kryptomaerkteaufsichtsgesetz (KMAG) to implement MiCAR domestically and arm BaFin with name-and-warn powers and authority to suspend or prohibit non-compliant offerings. Germany used a 12-month MiCAR grandfathering window that closed end-2025, against full 18-month windows in France, Malta and Luxembourg to July 2026; Ethena Labs ceased its German subsidiary and declined German MiCA authorisation after BaFin scrutiny. On 1 July 2025 BaFin granted AllUnity an EMI licence to issue EURAU (token launched 29 July 2025), positioned as the first euro stablecoin in Germany fully MiCA-authorised and 1:1 euro-collateralised with proof-of-reserves disclosures. E-money tokens are regulated as e-money under EMD2/ZAG and as crypto-assets under MiCAR simultaneously; per §11(1) ZAG only CRR credit institutions or licensed EMIs may issue, a position that bears on both bank and non-bank issuers. This first MiCA-authorised euro EMT under a German EMI licence sets a replicable authorisation template for the EEA.

no periodic updates on record for this sub-brief

1 earlier update recorded under a different module label

An early cycle filed this entry under this module code with a heading naming another subject. Kept for the record; not this module's latest position.

Periodic update · new data 2026-07-08

Prudential Standards & Capital Requirements

No material signal was identified for Germany under W2 (Prudential Standards and Capital Requirements) this cycle. The PSD3/PSR package carries prudential implications — including changes to own-funds requirements and safeguarding diversification obligations — but no Germany-specific prudential-standards development beyond what is captured under W1a and W12 was resolved this cycle.

Outlook

PSD3 transposition will carry prudential-standards implications for German PIs and EMIs. This module will be updated when DE-specific prudential-standards material is available.

Sources and findings (5)
  1. T3https://www.globallegalinsights.com/practice-areas/blockchain-cryptocurrency-laws-and-regulations/germany/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
  2. T3https://www.deloittelegal.de/en/services/legal/perspectives/micar-e-geld-token-crypto.html [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
  3. T3https://www.cryptoninjas.net/news/germany-approves-eurau-first-mica-compliant-euro-stablecoin-gets-green-light-from-bafin/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
  4. T3https://coincub.com/blog/how-european-banks-are-building-on-mica/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
  5. T3https://www.cyfrin.io/blog/mica-regulation-explained-a-guide-to-eu-crypto-compliance [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]