erlaubnisantrag.comRegulatory Pathfinder
Financial business models · Germany
Interactive initial assessment

What are the components of your business model?

Select every activity that resembles your planned service. Combinations matter: a market newsletter with a buy recommendation and a provider link raises different questions from a purely informational service. See the reasoning behind an initial assessment and the next questions to examine.

Self Assessment

Choose the options closest to your model. Your entries stay in this browser.

1 · Select all relevant activitiesYou can select several activities. Then describe how you address your users.

Detail · What happens after a signal or recommendation?The details help distinguish analysis, personal advice, intermediation and portfolio management. Choose the closest description.
2 · How specific is the trading prompt?
3 · How is the recommendation addressed?
4 · What is passed to third parties?
Used only in the local printout; do not enter sensitive customer information.
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.

Business model and implementation

3RMCN

3RMCN combines practical experience with startups and authorisation applications, the development of workable business models and an extensive network of sector resources.

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Institutional structure

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 ↗
Legal assessment

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 ↗
Further reading · SupervisionWhat supervisors are examining in consumer protectionESMA on digital investor information, finfluencers, affiliate marketing and app design, with developments through 2026. Read the article ↗
Legal framework and sources

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.