3RMCN
3RMCN combines practical experience with startups and authorisation applications, the development of workable business models and an extensive network of sector resources.
Request a free introductory meeting ↗Explore permission requirements
Could your business idea need authorisation?
Planning a finance app, information service, trading platform or investment service? What clients can actually do through it shapes the regulatory questions. Describe your idea step by step. This initial check highlights possible permission issues and what to clarify next.
Start the initial check ↓Describe your planned service
Start with what your clients can do. Select more than one option where relevant. Your entries stay in this browser.
When questions remain
Turn initial orientation into a workable next step.
For novel or combined models, details determine the appropriate path. Discuss your structure in a free introductory meeting with 3RMCN. You can also find specialist contacts for tied agent structures and legal analysis here.
DonauCapital
A tied agent arrangement may be an option for certain investment services. DonauCapital offers tailored arrangements; their suitability for a particular model requires separate assessment.
Explore the tied agent option ↗mzs Rechtsanwälte
The law firm specialises in banking and capital markets law, including regulatory questions, authorisation procedures and the structuring of novel financial and FinTech models.
Visit the firm ↗Investment services: MiFID II provides the European framework; § 2 WpIG and § 3 WpIG and BaFin guidance on Anlagevermittlung and Anlageberatung help with the analysis. For copy trading: ESMA Supervisory Briefing and BaFin on automated systems.
Other legal areas: Public analysis and recommendations: § 85 WpHG and ESMA on the Market Abuse Regulation. Crypto asset services: MiCAR (EU) 2023/1114 and BaFin on authorisation. Identification by a third party under § 17 GwG requires separate assessment.
Organisational duties after classification: Die MaComp address applicable compliance, conduct and organisational duties in investment services. The MaRisk (Rundschreiben 06/2026) apply to the risk management of relevant institutions. Neither independently determines whether a startup needs authorisation.
This initial assessment covers typical financial models in Germany. Several regimes may apply together. Payment and crypto asset services currently appear only as separate paths; MiCAR applies only to crypto assets within its scope. Rules reviewed: 24 September 2026.
Did you know?
From the Pathfinder
Business concept
How an app can become an activity that requires permission.
Have you explored?
Across our tools & projects
Fit & Proper · skills matrix
Prepare management profiles and collective suitability reviews.
International market entry / Germany
Is Germany your next market?
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.
Discuss your plans ↗Supervisory perspectives
Familiar with several regimes
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.
International structuring
Incorporating offshore?
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.