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Blueprints / BP-1 · Banks & credit institutions

Crypto Trading and Custody Inside the Bank's Existing App

A retail bank can offer spot crypto trading and custody inside the app its customers already log into, on the banking authorisation it already holds - by notification, not by a new licence.

Maturity
Proven
Regime
MiCA Art. 60
Proven stack
Sygnum · Boerse Stuttgart Digital · Bitpanda · Ripple Custody
Last verified
August 2026

Reviewed by Andrei Yurkevich, Founding Member at Protofire

Trusted across 60+ networks and 95+ protocols
~4 months

observed interval from regulatory clearance to live, at both BBVA (5 Mar to 4 Jul 2025) and DZ BANK (end Dec 2025 to first co-operative bank live 5 May 2026).

Seven named institutions in production across five countries, earliest live October 2022. The licence is not the constraint - the core-banking integration is.

01. The opportunity

Retail deposit money is already leaving banks for exchanges, and much of it belongs to customers the bank never reaches through its investment products. When PostFinance launched in-app crypto, around 56 per cent of its crypto clients had never used any investment product at the bank before, according to its Head of Digital Assets in June 2025. Offering spot crypto inside the app the customer already logs into keeps that flow, and those customers, on the bank's own rails: the position is bought with money already in the account, appears in the same portfolio view as funds and securities, and carries through to the year-end statement and tax certificate, with no separate app and no separate onboarding.

The regulatory ground shifted underneath it. MiCA lets a credit institution add crypto-asset services on the authorisation it already holds, by an Article 60 notification instead of a new licence, and the transitional period for older national registrations has now closed across the EU. For the customer it is a regulated, familiar surface for assets they were otherwise buying on venues with no banking protections, and it is the entry point to the products the same infrastructure supports next, with staking (BP-3) the typical follow-on inside the first year.

02. The regulatory position

MiCA via the Art. 60 credit-institution notification - 40 working days, completeness check only, no power to refuse on the merits. Plus DORA and the Transfer of Funds Regulation. Swiss banks operate outside MiCA under their banking licence with DLT-Act segregation (Banking Act Arts. 16 no. 1bis and 37d, DEBA Art. 242a). MiFID II does not apply.

03. Who's already done this

Market references, not our clients
DZ BANK
BaFin MiCAR authorisation received end December 2025, Germany · Live 12 Jan 2026

meinKrypto inside the VR Banking App - BTC, ETH, LTC, ADA, self-directed and outside advisory. Custody by Boerse Stuttgart Digital, execution by EUWAX AG, built with Atruvia. The clearest illustration of the gap between licence and launch: the first co-operative bank went live 5 May 2026, and each of the 646 banks must activate in its own name.

PostFinance
Systemically important Swiss bank, FINMA-supervised · Live 21 Feb 2024

Trading and custody on Sygnum's bank-to-bank platform via API, 11 assets at launch and 22 today, extended to corporate clients May 2026. The sequencing reference for the library - staking followed in January 2025 - and the clearest case of a bank reaching non-investors: around 56 per cent of crypto clients had not previously used any investment product.

BBVA
Registered with the CNMV as a credit institution for custody, execution and transfer, effective 5 March 2025 - the Art. 60 route rather than a CASP authorisation · Live 4 Jul 2025

BTC and ETH buy, sell and custody in the BBVA app for all adult retail customers in Spain, after a phased rollout. BBVA is custodian of record and runs Ripple Custody as its own key-custody technology. The reference case for a bank that keeps custody in-house, and evidence the Art. 60 notification route works in practice.

Zuger Kantonalbank
FINMA-supervised cantonal bank, Switzerland · Live 2 Oct 2023

Crypto buying and trading inside the bank's own e-banking and app, on Sygnum; offering expanded 17 March 2025. A mid-sized regional institution rather than a household name, which makes it the more useful comparator for most readers.

BancaStato
Cantonal bank of Ticino with a cantonal state guarantee; FINMA-supervised · Live 23 Jul 2026

BTC, ETH, SOL and LTC in the existing InLinea channel, execution and custody by Sygnum via direct API into Avaloq SaaS, assets held off-balance-sheet with no external wallet transfers. The newest deployment and the most transparent about its constraints: crypto is displayed like any other security in e-banking, statements and tax certificates.

N26
German banking licence; the crypto service is provided by Bitpanda Asset Management GmbH, BaFin-authorised 24 January 2025 and disclosed to the customer as counterparty · Live Oct 2022

Trading and custody embedded in the N26 app, 300+ assets, live in Austria first and subsequently across the EU and Switzerland, with Bitpanda setting pricing and holding the keys. The earliest in-channel deployment located and the clearest example of the second lawful shape - the licensed provider is the contracting counterparty and the bank supplies the channel.

dwpbank and MLP Banking AG
dwpbank operates wpNex for connected institutions; MLP Banking AG is BaFin-authorised, Germany · Live 5 Jun 2024

wpNex places crypto beside securities in the member bank's own depot, funded from the bank account with no separate wallet. Shows the pattern delivered through a shared securities-processing utility rather than bilaterally.

04. Does this fit you?

  • Yes if you hold a banking authorisation, run your own retail e-banking channel with an installed customer base, and already produce securities statements the crypto positions can join.
  • Not if you have no banking authorisation, if you are a broker or venue without a banking channel, if you serve a network of member banks rather than your own customers, or if the product you want is customer-controlled self-custody.

05. The stack, layer by layer

Most of these layers can be rented from a named vendor, and usually should be. The part that matters is the one layer you have to own yourself.

Yours

The authorisation, the channel and the client record

The banking authorisation and with it the Art. 60 route; the customer relationship, identity record and the account the money comes from; the e-banking channel with its authentication and design system; securities custody, statement production and tax reporting; and the compliance, risk and complaints functions the regime assumes.

Rented

Custody, liquidity and chain connectivity

Custody infrastructure or key-management software, liquidity, pricing and settlement, and chain connectivity with Travel Rule messaging. Explicitly not included: no core-banking connector, no statement or tax output, no customer channel and no complaints handling.

SygnumBoerse Stuttgart DigitalEUWAXBitpanda Asset ManagementRipple CustodyTaurusTangany
Ours

The core-banking seam and the governance pack

The core-banking-to-custodian seam - position mirroring, posting, end-of-day reconciliation and break handling; statement and tax plumbing per jurisdiction; the channel surface inside the existing app; the Art. 60(7) notification pack, custody policy and Art. 74 wind-down plan; and monitoring, decision thresholds, rehearsed runbooks and out-of-hours cover.

Yours, never rentableRented from a named vendorBuilt and run by Protofire

06. Why this stack

  • The bank does not need a new licence or a new legal entity. A credit institution notifies its home authority 40 working days ahead under MiCA Article 60, and the authority's review is a completeness check rather than an approval it can withhold on the merits.
  • "Renting a CASP passport" is not a lawful structure. MiCA has no agent concept, the passport is not transferable, and Article 75(9) restricts custody sub-delegation to authorised providers. Two shapes work: the bank is the provider, or a licensed provider is the disclosed counterparty.
  • The demanding part is the integration between the core banking system and the custodian - position mirroring, reconciliation, statements and tax - and no off-the-shelf connector to a licensed European custodian exists.
  • Swiss banks sit outside MiCA entirely, under their banking licence with DLT-Act bankruptcy segregation, which FINMA restated in guidance on 12 January 2026.

07. What we don't claim

There is no published decision-to-live timeline for this pattern anywhere. Two clearance-to-live intervals are observable and both are about four months, but they measure only the last stretch. Payment for order flow is prohibited, principal inventory is capital-expensive under CRR3, and several live deployments allow no external wallet transfers at all, so a customer can sell the position but cannot move it to a self-custodied wallet.

Request the full blueprint

This is the short version. The full blueprint is a single document your counsel and board can read cold, and a third-party-risk function can lift wholesale. Leave your work email and your personal link arrives in your inbox.

What is inside
  • The regulatory position, stated article by article
  • Proven options at each layer, with the vendors that hold up
  • The risk table with a named owner for each risk
  • The division of labour: what is rented, built, and operated
  • The third-party-risk pack a DORA governance function can lift
  • The delivery path, step by step, with the monitoring and incident model

FAQ

What authorisation does a bank need to add crypto trading and custody inside its existing app?

Under the Crypto Trading and Custody Inside the Bank's Existing App pattern, a retail bank uses its existing banking authorisation and the MiCA Art. 60 credit-institution notification, which runs 40 working days as a completeness check with no power to refuse on the merits, so no new licence is required. DORA and the Transfer of Funds Regulation also apply, and MiFID II does not. Swiss banks operate outside MiCA under their banking licence with DLT-Act segregation.

Which banks already offer spot crypto trading and custody in their own app?

BBVA registered with the CNMV as a credit institution for custody, execution and transfer on 5 March 2025 via the Art. 60 route and went live on 4 July 2025 with BTC and ETH in the BBVA app, running Ripple Custody as its own key-custody technology. DZ BANK received its BaFin MiCAR authorisation in late December 2025 and launched meinKrypto inside the VR Banking App, with custody by Boerse Stuttgart Digital and execution by EUWAX AG. PostFinance has run trading and custody on Sygnum since February 2024.

In this pattern, what does the bank build and what does it rent?

The bank owns the parts that already exist: the banking authorisation and Art. 60 route, the customer relationship and account, the e-banking channel, and securities custody with statement and tax reporting. It rents custody infrastructure, liquidity, pricing, settlement and chain connectivity with Travel Rule messaging from providers such as Sygnum, Boerse Stuttgart Digital, EUWAX, Bitpanda Asset Management or Ripple Custody. What gets built is the core-banking-to-custodian seam, the statement and tax plumbing, the channel surface, and the Art. 60(7) notification pack with an Art. 74 wind-down plan.

Already evaluating this for your institution?

When you are ready, we scope a business case on your own numbers: the costed build, the controls, the SLA and the ROI your board needs to approve it. Or talk it through first.

Run this pattern in production, or tried to and stopped? .

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