PayTechTalk 37 – Approval procedures: directors, qualifying holdings, and capital requirements

PayTechTalk 37: Geschäftsführer, Inhaber und Eigenkapital
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In our 34th episode of PayTechTalk I talked with my colleague Christian about the licence types for payment service providers. Upon hearing this podcast, Marko Wenthin, one of the co-founders of SolarisBank, asked us to talk in more detail about application for authorization and in particular about directors, qualifying holdings,  and capital requirements, as it is precisely these three topics that can be a bottleneck in the application process of a payment institute. In particular, directors and persons with a qualifying holding always play an important role in approval procedures. This is why Peter and I are happy to answer to this request today.

Enjoy our PayTechTalk 37!

Directors, qualifying holdings, and capital requirements


Who can be a director or CEO of an institute? Can anybody do this? When do you have the relevant technical qualifications and reliability? Is it, for example, sufficient if the prospective director has completed a traineeship at a bank or is that not enough? What exactly is the required theoretical and practical knowledge – and do they need any management experience? And how many directors does an institute require?


Who is regarded as owner of a qualifying shareholding? How is the qualifying holding determined? Is it just about shares or do voting rights also play a role? When is the influence on the business considered to be significant?

You will also find out why it makes sense to keep the shareholding structure of the institute as simple as possible and to oblige investors right from the start to provide all required information by BaFin. In our podcast we also talk about why the ownership control procedure may also be viewed as the “little authorization application as part of a large authorization application”.

Capital Requirements

How much initial capital is required for a payment institute – and how exactly should the two capital components, i.e. initial capital and own funds be calculated?



The original podcast is in German

Cover picture: Copyright © PayTechLaw

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