Germany has introduced a new licensing exemption designed to facilitate market access for certain third-country market makers. The reform, effective since 10 February 2026, allows qualifying firms to conduct proprietary trading as Market Makers on German trading venues without obtaining an EU MiFID investment firm authorisation for market making, which would otherwise be required within the European Union.
The exemption applies exclusively where the third-country firm acts as a member of a regulated exchange or as a participant of a MiFID II trading venue and is therefore subject to the venue’s admission procedures, trading rules and ongoing supervision. What changes is the national layer: Germany removes a bureaucratic hurdle at the point of venue access while maintaining regulatory oversight through the trading venue itself.
This is particularly relevant for crypto-native and digital-asset market makers headquartered in major non-EU financial centres – for example across Asia, the United Kingdom or North America.
This adjustment is technical in wording but strategic in effect.
By reducing the need for additional German licensing structures, the reform lowers operational and financial barriers for global liquidity providers. For firms based in major non-EU financial centres, access to German regulated markets becomes more predictable and less operationally burdensome.
The likely consequences are straightforward yet far-reaching:
- Greater international participation
- Deeper liquidity pools
- Tighter spreads
- Stronger competition among market makers
Liquidity is cumulative. Once additional providers enter a venue, market quality improves, which in turn attracts further participation. Jurisdictions that make access efficient without compromising regulatory standards tend to attract and accrue activity over time.
Implications for digital capital markets and 21X
The reform is particularly relevant for digital- and DLT-based market infrastructures operating within Germany’s regulatory borders.
21X runs a regulated DLT trading and settlement venue that integrates issuance, trading and post trade processes into a unified on-chain environment. Its model is built around atomic settlement and wallet native ownership, but fully embedded within a supervised market structure.
For tokenized financial instruments, liquidity remains the decisive factor. Technology enables issuance. Regulation enables credibility. Liquidity enables scale.
Germany’s new framework directly addresses the liquidity side of that equation. By making it easier for qualifying third-country market makers to connect to German trading venues, it strengthens the conditions under which regulated DLT markets can compete with traditional infrastructures.
As Max J. Heinzle, CEO of 21X points out:
“Through this licensing exemption, Germany is reimagining the trading venue as the regulatory gateway for global liquidity. This significant shift positions also the 21X DLT market model and its structural foundation more to the centre of the new financial map for capital markets.”
The structural aspect is key. This is not a temporary incentive scheme or a local tax adjustment. It is a recalibration of how international liquidity can access regulated German venues.
For issuers considering tokenization, venue selection becomes increasingly strategic. For global market makers, Germany now offers a clearer and more scalable entry point into EU regulated markets. For regulated DLT venues such as 21X, the alignment of regulatory credibility and simplified liquidity access strengthens the investment case for digital market infrastructure.
Germany is positioning itself as a competitive access hub within Europe’s evolving capital market architecture. Regulated digital venues operating within that framework are likely to be direct beneficiaries.
Further information on 21X’s regulated DLT trading and settlement infrastructure is available at: www.21x.eu
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