Your Volksbank crypto asset license: Why you need to check custody services separately

If your Volksbank or Raiffeisenbank recently launches cryptocurrency services, they will only hold BaFin's order execution authorization

If your Volksbank or Raiffeisenbank recently started providing cryptocurrency services, this means that they are authorized by the German Federal Financial Supervisory Authority (BaFin). In most cases, this authorization covers only one specific service: executing your buy and sell orders. It does not cover custody of your crypto assets. The bank's authorization document does not say who holds control of your assets, which is the key question you must clarify before making your first purchase.

The background of this phenomenon is recent changes in the European registry. According to an analysis released by the trade services agency The Industry Spread on September 10, 2026, between August 12 and September 10, 2026, 16 new institutions were added to the CASP (Cryptographic Asset Service Providers) registry of the European Union Securities and Markets Authority (ESMA). Among them, 14 are German Rabobank. Professional services organization MiCA Watch also reached the same conclusion on statistics for the same period. Currently, a total of 31 German regional banks have been authorized by MiCA, and each bank has only been approved for one service and is limited to operating in Germany.

What is allowed to do under CASP authorization under the MiCAR framework

CASP stands for crypto asset service providers, which refers to companies that commercially provide one or more crypto services listed in the European Union's Crypto Asset Markets Regulation (MiCAR) and require authorization from national regulatory authorities. MiCAR is the EU regulation on the crypto asset market, which will take effect from the end of 2024; the competent authority in Germany is BaFin.

A decisive feature of this type of authorization is often ignored in day-to-day use: such authorization is by no means universal. MiCAR lists ten independent services, from asset custody and trading platform operations to advice on investment in crypto assets. Institutions need to apply separately for each service, and the registry will clearly list the specific projects it has approved. Therefore, a bank may have authorization but still not have the right to keep your coins.

The second point concerns the scope of application. Although the authorization applies in principle to the entire EU, it is limited to countries notified by the agency. For cooperative banks, the scope of notification is usually limited to a single country, namely Germany. This has no material impact on you as a German customer, but it explains why these institutions have a different image in the European registry than international exchanges.

Cooperative banks are filling the ESMA registry: 14 of 16 new entries

The data from both analyses are unambiguous. During the time window from August 12 to September 10, 2026, The Industry Spread pointed out that 14 of the 16 newly added registrations belonged to cooperative banks, accounting for 87.5%. MiCA Watch showed that 15 of the 17 new entries added in August belonged to cooperative banks, accounting for 88.2%. Both services use ESMA's machine-readable registration documents as their data source. The names appearing there are all local banks, such as Raiffeisenbank Schwaben Mitte, Volksbank Euskirchen, VR-Bank Mittelfranken Mitte, Volksbank Raiffeisenbank Dakhau, Frankfurter Volksbank Rhein/Main, etc.

Regarding the overall size of the registry, there are differences in the values, so we will not obscure it: MiCA Crypto Alliance counted the total number of 294 after adding 14 new companies, while the CASP Tracker service counted 338 authorized crypto asset service providers on September 7, 2026. This difference may arise from differences in statistical methods, such as counting by institution or branch, including or excluding notified branches. At present, only the direction is reliable, and this is unambiguous.

The implications of this trend can be calmly described as: Germany's crypto access channels are migrating from the professional provider space to bank distribution networks. Users who previously had to open accounts with the exchange can now find relevant services in their corner bank app. As for the comparison of costs incurred through banking channels to exchange fees, we calculated them in a separate analysis of Sparkasse and Volksbank commissions.

Execution of orders only: Why order execution does not include asset custody

The service name of all local banks involved in the registry is "Execution of Crypto Asset Orders on Customers". This refers to only one process: your bank accepts your orders and forwards them for execution, buying and selling in your name.

Under MiCAR, custody is an independent service with the registry name "Custody and Management of Cryptographic Assets on behalf of Customers." This means holding access credentials, which are the private keys needed to control cryptographic assets. A private key is a secret sequence of numbers that can move encrypted assets; whoever holds the private key truly controls the coin.

This creates a specific verification task for you as a customer. If your bank only provides execution services, then your assets are held by a third party whose risk is as important as the bank from which you placed the order. For details on the existence of custody models and their differences, see our hardware wallet comparison article, in which self-custody is used as a control model.

CASP authorization is not a blank check: it accurately lists the services an institution is allowed to provide

Our own statistics: There are 66 crypto asset service providers in the BaFin database

In order not to rely solely on other people's statistics, we collected our own data from Germany. The basis is BaFin's public company database, which is queried through the "Cryptographic Asset Service Provider" category. This evaluation will be completed by cryptoticker.io on September 13, 2026.

Method description: On September 13, 2026, we completely searched the results of the "Cryptographic Asset Service Provider" category in BaFin's database in alphabetical order because the list of results was truncated at 50 items and each institution's category designation was evaluated.

The combined results for 66 institutions are as follows:

• BaFin lists 66 institutions in the crypto asset service provider category.
• Twenty-one of them belong to cooperative departments, including Volksbanken, Raiffeisenbanken, VR-Banken, Westerwald Bank and DZ BANK as a central institution.
• 33 of the 66 are also credit institutions;23 are investment companies.
• Another 10 homes in 66 have an additional designation of "crypto asset custodian".
• None of the 21 cooperative institutions has a "crypto-asset custodian" designation.
• Three institutions are additionally registered as crypto securities registries.

The last line is the core: the cooperative department accounts for one-third of Germany's crypto asset service providers, but none of them has custody qualifications.

Crypto Custodians under KWG Article 32: Which ten institutions hold licenses

The "crypto custodian" designation in the BaFin database refers to crypto custody operations under the German Banking Act, a national license that existed before MiCAR and was subsequently renewed in parallel with the European authorization. Although this designation is not exactly the same as MiCA's custody service, it covers the same business: holding crypto assets for others.

According to our statistics as of September 13, 2026, the following ten institutions have the designation: BitGo Europe, Boerse Stuttgart Digital Custody, Bullish Europe, Commerzbank, Crypto Finance Deutschland, DekaBank, Hauck Aufhäuser Digital Custody, Tangany, Tradevest Digital Assets and V-Bank. For a market with 66 authorized service providers, this is a short list that shows the high concentration of custody business in the hands of a few institutions.

Why this concentration is important to you

Custodians pool the assets of many banks 'numerous customers. If the custodian goes bankrupt, it will impact the customers of every institution connected to it, not just the customers of a single bank. This is not an accusation against any particular institution, but an intrinsic attribute of the model that should be included in a risk assessment before you deposit a large amount of money. Anyone who wants to compare this route to regulated exchanges with their own custody arrangements should first determine how many links they are separated from the coins.

meinKrypto Project: Who holds the key behind Atruvia and DZ BANK

The platform used by local banks to provide services to customers is called meinKrypto. It was jointly developed by Atruvia, an IT service provider in the partner department, and DZ BANK. According to IT-Finanzmagazin, it has been available in VR Banking apps since January 2026. At the time of launch, options for Bitcoin, Ethereum, Litecoin and Cardano were available. According to reports, more than one-third of the approximately 700 affiliated cooperative banks plan to go online in the following months.

There are two theories about behind-the-scenes division of labor, and they are not completely consistent. Let us reproduce the two here. IT-Finanzmagazin wrote that custody is the responsibility of Boerse Stuttgart Digital and order execution is the responsibility of EUWAX AG. MiCA Watch describes the model as a "hub and spoke" and allocates custody to DZ BANK, while local banks take orders.

Our own statistics support the first statement, but only for national licenses: Boerse Stuttgart Digital Custody has the cryptographic custodian designation, while DZ BANK does not. EUWAX AG appears as an investment company in BaFin's crypto asset service provider category. However, the BaFin database cannot read which of MiCA's ten services DZ BANK has registered in the ESMA registry. So if DZ BANK holds European custody services and outsources technical custody to Boerse Stuttgart Digital, both statements can hold true. This can only be clarified through DZ BANK's own registration entry.

Questions you can ask banks

You don't have to untie the chain yourself. Simply ask the bank one question and ask for a written answer: Which company is keeping my crypto assets and based on what authorization? Banks that distribute cryptocurrencies must have a clear answer to this. If you don't get an answer, that's information in itself.

The box belongs to the bank, the coins are outside the box: Custody occurs at different nodes of the chain

Center-spoke mode: What this means for your counterparty risk

In hub-and-spoke model, your assets pass through three sites: the local bank where you place the order, the entity where you execute the order in the market, and the custodian where you deposit the coins. Every site is regulated, and each site is a separate link where problems may arise. Therefore, this model is not worse than the route through the exchange, just the cutting method is different, and you should know where the cutting point is.

One point that is often confused with deposit protection needs to be clearly mentioned: Crypto assets are not deposit-statutory deposit guarantee and partnership departments protection plans apply to the balance in your account, not to coins in your portfolio. This is the same at your own bank as it is at an exchange, and MiCA authorization does not change that.

In contrast, MiCA stipulates separation: custodians must separate customer assets from their own assets and accept liability for their losses. This is indeed an improvement compared to unregulated conditions, but it is not a guarantee of value by the state.

Transfers to your personal wallet: Things to clarify before making your first purchase

Only the most practical and important consequences of the execution mode involve transfers. If your bank does not provide its own custody and the assets are held in a pooled structure by custodians, the ability to pay to your own wallet address depends on whether the provider provides it. Whether your organization offers this functionality is not stated in the registry, but rather in the Terms of Service.

There are four points worth checking in your pre-purchase documentation. The first is the transfer: Is it possible to pay to an external address, for which coins, and how much will the fee be? Secondly, tax records: Do you receive a statement containing the acquisition date and acquisition cost for each addition and meet the holding period requirements? The third is the settlement price and mark-up, because in banking products, costs are usually implicit in the price difference rather than explicit fees. Fourth, because it's important when selling: How fast is the order executed, is it a limited price or is it only applicable to the next determinable price?

Which banks have fully launched the service has been compiled by our editorial team in Volksbanken's Overview of Cryptocurrency Trading.

What is not displayed in the registry and the limitations of our statistics

Be honest and ask to state the limitations of your data. BaFin's corporate database lists only one designation per institution, such as a crypto asset service provider or crypto custodian. Unnamed is which MiCA service the institution has registered in the European registry. Therefore, our statistics on 66 institutions accurately indicate who is listed as a crypto asset service provider in Germany and who is additionally listed as a crypto custodian, but do not indicate the exact scope of MiCA's authority in each case.

The ESMA registry does include this scope, and the above statement that local banks only hold orders for execution comes from this. The statement comes from the two professional analyses mentioned above, not our own measurements: On September 13, 2026, since the search form of the ESMA registry only displayed the results page to the browser, it could not be evaluated through automatic search. It is usually available to readers, so we link to it for this purpose.

Registration entries for DZ BANK are also open, which is a key entry in determining custody responsibility. We did not make our own measurements of this, so we replayed the two published claims without claiming either as fact.

Checking your Volksbank cryptocurrency license: Your key points

Distinguish between two issues. Just because your bank has crypto authorization does not mean who holds custody of your coins. Ask about the custodian and their permissions, and compare their answers to providers in our overview of regulated crypto exchanges before committing.

Clarify transfer issues before purchasing. Assets that cannot be transferred to your own address are bound to the provider. Whether and how coins can be withdrawn is stated in the terms; the comparison model can be seen in our hardware wallet comparison.

Check tax records while you still have the option. For the holding period, you need the acquisition date and acquisition cost for each addition. Ask to see a sample annual statement before making your first purchase and compare providers with other options in the market through our overview of regulated crypto exchanges.

Original sources of this article: BaFin's public company database, where you can check the categories of crypto asset service providers; and ESMA's CASP registry, which lists the independent services approved by each institution. (As of September 13, 2026. This article does not constitute investment advice. Price and fee structures are subject to change; please check terms with provider before purchasing.)