Banking as a Service in Germany

Banking as a service splits a bank into two layers. The licensed bank keeps the balance sheet, the deposit protection, the payment scheme memberships and the compliance duties. On top of that it offers APIs, so a partner can open an account, issue a debit or credit card, move money by SEPA transfer or check a customer's identity from inside its own app. The partner, often a fintech, a neobank or a large consumer brand, owns the customer interface. In the white label version the partner's brand is the only one the customer sees.

The BaaS model earns money from fees per account, per card and per transaction, plus a share of interchange on card payments. It works for use cases where a company wants a financial product without the cost and time of getting a license: a business account inside accounting software, a card for a club's members or an account for a crypto broker's euro balances. The embedded finance page looks at the same deals from the side of the brand that sells the product.

A provider that takes deposits and grants loans needs a license as a credit institution under the Kreditwesengesetz (KWG). In the euro area the European Central Bank grants that license on BaFin's proposal, and BaFin and the Deutsche Bundesbank supervise the bank day to day. A provider limited to payments and e-money needs a license as a payment or e-money institution under the Zahlungsdiensteaufsichtsgesetz. Which one a BaaS platform holds decides what its partners can offer: only a full bank can hold deposits under the statutory deposit guarantee and grant credit from its own balance sheet.

The partner fintech usually needs no license for the parts the bank provides. Its contract with the bank decides who runs the KYC checks, who monitors transactions for money laundering and who handles complaints. Under the KWG and the EU's Digital Operational Resilience Act (DORA) the bank stays responsible for everything it outsources, and DORA requires a register of all contracts with ICT third-party providers.

Solaris in Berlin was one of the first European fintechs to build its business on banking as a service, with a full bank license behind the accounts and cards of its partners. In January 2022 BaFin raised its capital requirements and sent a special representative to the bank, as Startbase reported (in German), after an audit of its anti-money laundering controls. BaFin later ruled that Solaris could take on new partner customers only with its permission, while existing partnerships continued, according to The Paypers.

In February 2025 Solaris raised a 140 million euro Series G round in which the Japanese financial group SBI became majority shareholder, reported by FinTech Futures; SBI completed the ownership control procedure in March 2025. Solaris also became the bank behind the ADAC credit card (in German). For a fintech choosing a BaaS partner, the case shows the dependence in both directions: when BaFin restricts the bank, every brand on its platform feels it.

BaFin treats BaaS as part of a wider question, how much of the German financial sector depends on a few technology providers. Its focus risks list concentration in IT outsourcing and warn that problems at a sub-provider can spread through the whole chain (in German). For a BaaS bank that means documented exit plans, audit rights over its partners and a clear view of which fintech brands rely on which system.

Open banking and BaaS often meet in one product. A fintech reads a customer's accounts at other banks through PSD2 interfaces and opens a new account for the same customer through its BaaS bank. The open banking in Germany page covers the data side of that setup.

Finance Loop is the meeting place for people who run BaaS platforms and for those who build on them: bank staff in compliance and treasury, payment specialists, and product and engineering teams at fintechs. It connects the finance, IT and AI communities in Germany, Austria and Switzerland, with events in Frankfurt, Munich, Berlin and Hamburg. In Berlin, the home of Solaris and many of its partners, Finance Loop brings together people from payments in Berlin and the city's neobanks.

Finance Loop is a partner of Frankfurt Digital Finance and supported the Fintech Founder & Investor Evening in Frankfurt. It is built in collaboration with TechQuartier, where the FinTech FFM meetups often take place.

Banking as a service is a model in which a licensed bank offers accounts, cards, payments and identity checks to other companies through APIs. The partner company sells these products under its own brand, and the bank keeps the license and the regulatory duties. BaaS is the provider side of embedded finance.

There is no separate BaaS license. A BaaS provider holds either a license as a credit institution under the KWG, granted by the ECB on BaFin's proposal, or a payment or e-money institution license from BaFin under the ZAG. The first allows deposits and lending; the second covers payments and e-money only.

White label banking is banking as a service in which only the partner's brand appears. The customer opens an account in the partner's app and receives a card with the partner's design, while the IBAN, the deposit guarantee and the supervision belong to the bank behind it. The bank's name still appears in the terms and the legal notice.

Frankfurt has regular fintech meetups where BaaS is a common topic, among them FinTech FFM, which often meets at TechQuartier, and the monthly meetups of the Frankfurt Payments Network. Finance Loop events in Frankfurt, Berlin, Munich and Hamburg bring BaaS banks and their partners together; dates are in the calendar above.