ESMA Register Shows 14 Of 16 Newest CASP Entries Are German Cooperative Banks

Fourteen of the sixteen newest crypto-asset service provider entries in the European Securities and Markets Authority register are German cooperative banks, according to a review of the public CASP register. The entries show order execution as the only authorized service, while a parallel count of the BaFin crypto custodian database finds zero of twenty-one cooperative institutions registered to hold customer crypto assets.

The pattern points to a deliberate, narrow entry into digital-asset services by Germany's cooperative banking sector. The banks are registering to execute customer orders for crypto-assets under the Markets in Crypto-Assets Regulation, which took full effect for CASPs on December 30, 2024, while leaving custody to licensed specialists.

ESMA Register Shows 14 Of 16 Newest CASP Entries Are German Cooperative Banks

The ESMA register of crypto-asset service providers lists fourteen German cooperative banks among its sixteen most recent additions. The entries carry order execution as the sole authorized activity, a service that lets a bank accept and route customer buy and sell orders without ever holding the underlying crypto-assets.

The concentration is striking because the CASP register is European, not German. Cooperative banks from one member state account for 87.5 percent of the newest cohort, a share that reflects the coordinated rollout strategy of Germany's cooperative financial network rather than isolated filings.

The register entries postdate the MiCA authorization regime that began binding CASPs from the end of 2024. Under that framework, a CASP must obtain authorization in one member state and then passport services across the European Economic Area. The German cooperative banks are using their home-country authorization through BaFin as the gateway.

The order execution registration is the lightest CASP category available. It does not require the capital, custody infrastructure, or insurance arrangements that a custody license demands. For a sector built on retail deposits and mortgage lending, the lighter category is the path of least resistance into crypto.

BaFin Database Counts 21 Cooperative Institutions With Zero Crypto Custody Licenses

The BaFin crypto custodian register counts twenty-one cooperative institutions, and none of them holds a crypto custody license. The count covers the cooperative banks and their central institutions that appear in BaFin's public database of registered crypto custodians.

The custody gap is the defining feature of the cooperative sector's crypto posture. A bank that executes customer orders but does not hold the assets must rely on a third-party custodian to settle and safeguard the purchased crypto. That third party carries the regulatory burden the cooperative banks have chosen not to take on.

Crypto custody in Germany has been a licensed activity since January 1, 2020, when the amended German Banking Act brought the safekeeping of crypto-assets under BaFin's supervision. The license requires the same organizational and capital standards as traditional securities custody, including segregation of customer assets and operational resilience.

The zero-custody result among twenty-one institutions is not a data artifact. BaFin's register distinguishes between institutions that hold a custody license and those that appear in related databases for other reasons. The cooperative institutions counted here are in the crypto custodian database without the custody authorization.

Order Execution Only: What Cooperative Bank CASP Services Actually Cover

Order execution only means the cooperative banks accept customer instructions to buy or sell crypto-assets and transmit those instructions to a trading venue or counterparty. The bank never takes the crypto onto its own balance sheet and never holds customer private keys.

The service is functionally similar to how a traditional broker handles equities: the broker routes the order, while a separate custodian holds the securities. In the crypto context, the custodian is typically a licensed crypto custody provider that maintains the wallets and manages the private keys.

The exclusion of custody from the cooperative banks' CASP registrations is explicit in the register entries. A CASP that wanted to offer custody would need a separate authorization under MiCA's custody class, which imposes safekeeping duties, client asset segregation, and liability for lost assets.

For customers, the distinction matters. A customer who buys crypto through a cooperative bank's order execution service does not have a custody relationship with the bank. If the third-party custodian fails, the customer's recourse runs to that custodian, not to the cooperative bank.

Why Cooperative Banks Skip Custody Registration Despite CASP Status

The cooperative banks' decision to skip custody registration reflects a calculation about regulatory burden and business strategy. Custody licensing under BaFin requires dedicated compliance staff, cold storage infrastructure, insurance, and ongoing supervisory reporting that a small regional bank may not want to carry.

The cooperative sector's centralized service providers offer a cleaner route. The banks can white-label order execution through a central cooperative institution while leaving custody to a partner that already holds the necessary licenses. The arrangement lets individual banks offer crypto to retail customers without building custody operations in-house.

The business case for custody is also weaker for cooperative banks than for exchanges or dedicated custodians. A regional Volksbank serving a few thousand retail customers generates modest crypto order flow. The fixed cost of custody infrastructure would be hard to justify against that volume.

The reliance on partner custodians also shifts liability. Under MiCA, a custody provider is liable to clients for lost crypto-assets. A bank that only executes orders avoids that liability entirely, a meaningful advantage for institutions with conservative risk appetites.

Which Cooperative Banks Are Among The 21 Institutions And What They Offer

The specific names of the twenty-one cooperative institutions in the BaFin count and the fourteen banks in the newest ESMA entries are not fully disclosed in the available register snapshots. The open question of which exact Volksbank and Raiffeisenbank entities filed the recent CASP entries remains unanswered in the public data reviewed.

What is clear is the service pattern. The cooperative banks that have registered as CASPs are offering crypto order execution to retail customers, typically integrated into their existing online banking platforms. The service lets customers buy and sell major crypto-assets without leaving the bank's app.

The cooperative sector's crypto offering has been building since at least 2024, when the first Volksbanken began piloting crypto trading through central cooperative service providers. The current ESMA register entries suggest the rollout has accelerated into 2026, with a wave of individual banks completing their CASP registrations.

The custody question remains open. None of the twenty-one cooperative institutions has signaled a plan to seek custody registration, and the open questions in the source material flag this as unresolved. The sector appears content to leave custody to licensed partners while capturing the customer-facing order execution layer.

The next signal to watch is whether any cooperative institution files for custody authorization as MiCA's transitional arrangements wind down. A filing would mark a strategic shift. Until then, the cooperative sector's crypto footprint is execution-only by design.