Wallet App Without BaFin Authorisation: When Holding Crypto-Assets Requires a Licence

On 19 August 2026 Germany’s financial regulator BaFin published two consumer notices on the same day about offerings that present themselves as wallets. One concerns a website, the other a website together with an app that appears under its own product name in the usual stores. In both cases the supervisor writes that, on its findings, the operators are active without the required authorisation and are not supervised by it. In one of the two cases it is investigating operators who are unknown.

Both notices rest on the same provision, namely Section 10(7) of the German Crypto Markets Supervision Act (KMAG). And both raise the same question, which reporting on such warnings almost always passes over: at what point does a wallet need an authorisation at all? The answer is not obvious, because millions of people use wallet software with no authorised company behind it, and that is entirely in order. The difference sits at a point you cannot see on an app from the outside.

Two BaFin warnings in one day: what was published on 19 August 2026 about wallet offerings

The first notice concerns a website on which, on the supervisor’s findings, crypto-asset services are offered without authorisation. The second concerns two websites and an app; there, according to the notice, the operators hold themselves out as a company carrying the legal-form designation LLC that is said to operate the app. Names and addresses appear in the supervisor’s own notices, which are freely accessible and linked here. This piece does not name them, because its subject is the pattern and not the individual case.

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