Non-MiCA crypto operators must register with BZSt before first CARF report

Since 24 December 2025Bzst, providers of crypto-asset services face reporting duties under the Kryptowerte-Steuertransparenzgesetz (KStTG)Bzst. A Kryptowerte-Dienstleister within Article 3(1)(15) of Regulation (EU) 2023/1114 (MiCA) is BaFin-authorisedBzst and never registers with the Bundeszentralamt für Steuern (BZSt)Bzst; a Kryptowerte-Betreiber under § 1(9) KStTG — outside that MiCA definition —Bzst must apply once to the BZSt under § 17 KStTGGesetze IM Internet before the first expiry of the reporting deadline in § 9(1) sentence 1 KStTGBzst.

Registration in Germany is only open to an operator meeting the duties in § 2(1) No 2 and § 2(6) sentence 1 KStTG that is not freed from them by meeting them in another EU Member State (§ 2(2) to (5), (6) sentence 2, § 17(1) KStTG).Bzst The filing asks for the decisive domestic nexus in descending order — tax residence, seat-based, administrative-seat or business-activity ties — confirmed by a statement that no higher-ranking nexus exists elsewhere. Denying the § 17 with § 1(9) conditions, holding or having applied for BaFin MiCA authorisation, or already being registered in another state stops the form.

Filing is electronic only with the BZSt, through a browser form needing no additional infrastructure, reached via the BZSt online.portal with an Elster certificate, BZSt certificate or bundID. First registration uses the Erstantrag, acting for oneself, an organisation, or as a representative under § 1(12) sentence 2 KStTG. Portal profile data cannot be edited inside the form, and switching the acting profile deletes data already entered.

Section 17(2) sentence 1 KStTG fixes the data to report: name and firma; a postal address; business email and website addresses; tax identification numbers or their functional equivalent; every EU Member State where reportable users are tax resident; and every qualified third state. Without an operator email address, naming a website is mandatory. Case notifications go to a Bekanntgabe email address and the portal mailbox; the BZSt reserves other channels such as post for administrative acts in individual cases.

Representatives declare statutory representation under § 34 Abgabenordnung (AO), authorised representation with tax-advisory involvement under §§ 3, 3a and 4 Steuerberatungsgesetz (StBerG) or as a relative under § 15 AO, or other representation under § 80 AO, uploading proof of up to 10 MB. Tax advisers confirm membership of the §§ 3 or 4 No 11 StBerG professions; a represented entity additionally names a contact person with at least an email address.

Changes to the registered information, or loss of the § 17(1) conditions, must reach the BZSt unverzüglich via an Änderungsantrag re-entering all earlier data identically with the registration number (IIN) and case number. A change cannot create a different operator (Löschantrag plus new Erstantrag instead); undoing a deletion needs only a new Erstantrag. Deletion applies once the operator stops acting for reportable users or meeting § 1(9) KStTG, giving the effective date and reason. The BZSt shares the IIN with the other Member States via the central register under Article 8ad(10) of Directive 2011/16/EU.

An operator ignoring the duty, or revoked under § 17(7) KStTG after two unsuccessful demands to report under § 9, can be banned from executing reportable transactions for EU-resident reportable users; the ban must first be threatened with a registration deadline. Revocation is announced in advance, at the earliest 30 days and as a rule no later than 90 days after the second unsuccessful demand; re-registration then needs adequate security under §§ 241 to 248 AO. The filing guide is version 1.1 (Stand Oktober 2026). Legal basis: §§ 1(9) and (10), 2, 9 and 17 KStTG; Article 3(1)(15) of Regulation (EU) 2023/1114; §§ 34 and 80 AO; §§ 3, 3a and 4 StBerG.