A guided review of the application dossier for investment services under section 15 WpIG. Begin with the licensing scope and trace each supporting document through to submission.
20 application checks in five stages
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Classify all requested investment services, ancillary activities and own-account business precisely.
Why?
The authorisation scope must match the actual service.
Expected content
Activity map by client group, instrument, contractual party and workflow; trading and banking book distinction where relevant.
Preparation path
When to check
New feature, product or own-account trading.
Typical owner
Founders / legal.
Possible evidence
Service flow and activity matrix.
Common gap
Marketing terminology does not match the regulated activity.
Guidance 2
Exemptions and alternative access
What is required?
Assess possible exemptions or EEA market-access routes with reasons.
Why?
One exemption cannot be inferred from a label or single task.
Expected content
Analysis of conditions, boundaries and combined activities, identifying open questions.
Preparation path
When to check
Tied agent, liability umbrella or passporting claim.
Typical owner
Legal / management.
Possible evidence
Reasoned legal assessment.
Common gap
An exemption for one step is applied to the whole model.
Guidance 1.1; 3.1.1
Firm category and capital path
What is required?
Consider firm size, client-asset access and own-account activity.
Why?
Classification determines capital and organisational requirements.
Expected content
Reasoned classification, proposed authorisation restrictions and calculation of relevant capital.
Preparation path
When to check
Change in custody, proprietary trading or scale.
Typical owner
Finance / legal.
Possible evidence
Classification and decision.
Common gap
A capital figure is copied without linking it to the activity.
02 / Applicant, capital and owners
Guidance 3.2(a–b); Regulation 2017/1943 Art. 1
Applicant and legal entity
What is required?
State identity, seat, legal form, contacts and requested activities.
Why?
Supervisors need to identify the applicant and proposed business.
Expected content
Application form, current company data, register extract or certified incorporation papers and relevant articles and management rules.
Preparation path
When to check
Incorporation or renaming.
Typical owner
Management / corporate.
Possible evidence
Register extract, articles, data sheet.
Common gap
Names or addresses differ across exhibits.
Guidance 3.1.1; 3.2(c); Regulation Art. 2
Initial capital and its source
What is required?
Provide and evidence available initial own funds.
Why?
The firm needs a sound capital base at launch.
Expected content
Capital calculation and source; EEA CRR bank confirmation of paid-up, unencumbered funds available to managers; recent auditor confirmation for existing firms.
Preparation path
When to check
Contribution, capital raise or scope change.
Typical owner
Finance / owners.
Possible evidence
Bank or auditor confirmation.
Common gap
A funding intention substitutes for proof of available capital.
Guidance 3.1.2; 3.2(d); 5; Regulation Art. 3
Owners and qualifying holdings
What is required?
Disclose direct and indirect owners, qualifying holdings and close links.
Why?
Reputation, influence and effective supervision must be assessable.
Expected content
Ownership chain, beneficial owners and required shareholder evidence; if no qualifying holding, identify up to 20 largest shareholders.
Preparation path
When to check
Fundraising or restructuring.
Typical owner
Corporate / shareholders.
Possible evidence
Cap table, group chart, documents.
Common gap
Indirect holdings or voting agreements are missing.
Guidance 3.1.3; 5
Group structure and supervisory access
What is required?
Make close links and third-country relationships transparent.
Why?
Complex groups must not impede effective supervision.
Expected content
Group chart, control rights, legal and practical information flows and third-country links.
Preparation path
When to check
Foreign parent or shared infrastructure.
Typical owner
Management / group legal.
Possible evidence
Group map and cooperation description.
Common gap
A hidden group company controls operations.
03 / Management and oversight
Guidance 4.1; 3.2(e); Regulation Art. 4
Managers: fitness and time
What is required?
Show reputation, competence, management experience and sufficient time.
Why?
The service needs leaders who can actually direct it.
Expected content
Month-by-month complete, dated and signed CV; mandates, time allocation, declarations and register extracts as required.
Preparation path
When to check
Management appointment or change.
Typical owner
Candidates / corporate.
Possible evidence
CV, mandate list, declarations.
Common gap
Multiple roles have no credible time budget.
Guidance 3.1.2(7); 4.1
Management staffing
What is required?
Evidence the required number of managers and collective capabilities.
Why?
Key-person concentration can overwhelm leadership and controls.
Expected content
Allocation of responsibilities and skills; assess two non-honorary managers where client money or instruments may be held.
Preparation path
When to check
Expanding to custody or client funds.
Typical owner
Owners / management.
Possible evidence
Staffing and responsibility plan.
Common gap
A critical activity has no accountable manager.
Guidance 4.2; Regulation Art. 4
Supervisory body and key roles
What is required?
Name relevant bodies and people with suitable expertise and availability.
Why?
Supervisors assess the capacity to govern and oversee the business.
Expected content
Member list, functions, qualifications, time commitment and relevant key-function holders where applicable.
Preparation path
When to check
New body or control structure.
Typical owner
Corporate / management.
Possible evidence
Organisation chart and profiles.
Common gap
A named controller has no practical authority or resources.
04 / Business model and operations
Guidance 3.2; Regulation Arts 5–6
Programme of operations and client journey
What is required?
Explain services, target clients, markets, channels and processes coherently.
Why?
Supervisors need to see that business model and organisation fit together.
Expected content
An initial three-year programme and end-to-end client journey from marketing and onboarding to orders, settlement, reporting and complaints.
Preparation path
When to check
New app or copy-trading service.
Typical owner
Product / operations.
Possible evidence
Business plan, flow, prototype views.
Common gap
A pitch deck replaces the actual service chain.
Regulation 2017/1943 Art. 5
Financial projections
What is required?
Make financial assumptions and likely business development understandable.
Why?
Capital needs and continuity must fit the proposed service.
Expected content
Reasoned revenue, cost, capital and liquidity projections, assumptions and scenarios as required for the application.
Preparation path
When to check
Forecast change or funding event.
Typical owner
Finance / management.
Possible evidence
Model, assumptions, scenarios.
Common gap
Growth and control staffing costs are inconsistent.
Regulation 2017/1943 Art. 6
Organisation and accountability
What is required?
Explain structure, functions, deputies and reporting lines.
Why?
Supervisors need to know who fulfils operating and control obligations.
Expected content
Organisation chart, functional and process ownership, controls, staffing and provider boundaries.
Preparation path
When to check
Before submission or material change.
Typical owner
Management / HR.
Possible evidence
RACI, chart, resource plan.
Common gap
An outsourced step has no internal owner.
Regulation 2017/1943 Art. 6
Compliance, risk and audit
What is required?
Describe internal controls, conflicts and oversight.
Why?
Breaches and risks must be detected and corrected.
Expected content
Risk inventory, controls, roles, escalation and review functions appropriate to the firm.
Preparation path
When to check
New advice or portfolio management service.
Typical owner
GRC / management.
Possible evidence
Policies, control map, reporting.
Common gap
Policies have no operational control steps.
Regulation 2017/1943 Art. 6
Client protection and contracts
What is required?
Describe client information, terms, suitability or appropriateness journeys and safeguarding, where applicable.
Why?
The promised service must match actual client treatment.
Expected content
Sample contracts and screens; risk, cost and conflict information, client-data collection and client-asset arrangements.
Preparation path
When to check
Product launch or new target market.
Typical owner
Product / legal / compliance.
Possible evidence
Sample journey, contracts, tests.
Common gap
Terms promise functions that systems cannot deliver.
Regulation 2017/1943 Art. 6
Technology and external functions
What is required?
Describe systems, data flows, providers and continuity.
Why?
Digital services must remain controlled and resilient.
Expected content
System map, access controls, critical providers, monitoring and recovery plan.
Preparation path
When to check
Cloud, broker or onboarding integration.
Typical owner
IT / outsourcing oversight.
Possible evidence
Architecture, contracts, recovery test.
Common gap
A critical API has no fallback path.
05 / Completeness and filing
Guidance 3.2; Regulation Arts 1–6
Completeness mapping
What is required?
Map every subject in the Delegated Regulation and standard form.
Why?
The guidance is not exhaustive; missing required information delays review.
Expected content
Submission index linking each required field to exhibit, owner and reasoned non-applicability.
Preparation path
When to check
Before final submission.
Typical owner
Project lead / legal.
Possible evidence
Completeness matrix and approval.
Common gap
A large document bundle is not mapped to form fields.
Guidance 3.3; Regulation 2017/1945
Mandatory forms
What is required?
Use the prescribed standard forms and relevant change notices.
Why?
The application follows binding form requirements.
Expected content
Completed authorisation form and management-body list; change form where relevant, consistent with supporting documents.
Preparation path
When to check
Before dispatch or management change.
Typical owner
Project lead / legal.
Possible evidence
Forms and version review.
Common gap
A free-form letter replaces a required form.
Guidance 3.3
Submission method and language
What is required?
Check delivery channel, copies, evidence form and language.
Why?
Authorities need usable, secure evidence in the required form.
Expected content
Package addressed as set out in the guidance; original/certified material, secure electronic delivery and signed original power of attorney when applicable; agree English documents in advance.
Preparation path
When to check
Just before dispatch.
Typical owner
Project lead / authorised representative.
Possible evidence
Dispatch record, mandate, correspondence.
Common gap
An uncertified scan or insecure data room is submitted.
Guidance 3.3; Regulation 2017/1943
Updates and follow-up requests
What is required?
Handle changes after filing and additional information requests coherently.
Why?
The decision must rest on a current, consistent application.
Expected content
Versioned follow-ups, change log, owners, deadlines and cross-references to affected exhibits.
Preparation path
When to check
New manager, investor or changed product.
Typical owner
Project lead / workstream owner.
Possible evidence
Change register and delivery record.
Common gap
One exhibit changes while related plans and forms remain stale.
Working status:
Before submitting
Does every requested service match the business plan and contracts?
Can every mandatory form field be traced to a current supporting document?
Are assumptions, responsibilities and versions consistent throughout the dossier?
Sources and scope
Bundesbank guidance dated 27 January 2025; Delegated Regulation (EU) 2017/1943; Implementing Regulation (EU) 2017/1945. This is a selective editorial checklist. Map each required field of the official application to its attachment; agree any special submission route and language with the competent authority.
Considering a local office, a branch or a standalone authorisation in Germany? The appropriate route depends on your home jurisdiction, activities and operating model. 3RMCN combines experience from complex supervisory projects with product, technology and delivery expertise: from entry strategy and key interfaces through to operational readiness.
Experience in the context of CySEC (Cyprus), MFSA (Malta), FCA (United Kingdom), the European ESMA framework and MAS (Singapore). ESMA is not a national licensing authority.
For incorporation in offshore jurisdictions, relevant specialists from the network can be involved. Jurisdiction, activities and regulatory obligations need to be considered for each project.