The Issuers of E-Money
Only e-money issuers are allowed to conduct the e-money business. E-money issuers are according to section 1a subsection 1 ZAG:
- credit institutions within the meaning of Article 4 (1) of Directive 2006/48/EC,
- the federal government, state governments, municipalities and municipality associations, and indirect administrative bodies on federal and state level insofar as they act as public authority,
- the European Central Bank, the Deutsche Bundesbank and other central banks in the European Union or the other Contracting Parties to the Agreement on the European Economic Area if they are not acting in their capacity as monetary authority or other public authority,
- the Kreditanstalt für Wiederaufbau (KfW),
- e-money institutions.
An e-money institution is every company that conducts the e-money business without falling under numbers 1-4. As an e-money institution the company has to apply for a licence according to section 8a subsection 1 ZAG. E-money issuers as defined by numbers 1-4 are allowed to issue e-money without having to apply for a separate licence under the ZAG.
With a licence according to section 8a subsection 1 ZAG, providing payment services is possible as well (see section 8a subsection 2 No 1 ZAG). Therefore, e-money institutions are also payment service providers (see section 1 subsection 1 No 2 ZAG).