Skip to content
AgentBureau Docs

ZAG Exemption

ZAG Exemption

Section titled “ZAG Exemption”

A common question regarding our x402-based payment model is whether AgentBureau requires a license from BaFin (the German Federal Financial Supervisory Authority) under the Zahlungsdiensteaufsichtsgesetz (ZAG).

The Commercial Agent Exemption

Section titled “The Commercial Agent Exemption”

AgentBureau operates under the Commercial Agent Exemption (Handelsvertreterausnahme) as defined in § 2 Abs. 1 Nr. 1 ZAG.

According to this exemption, payment services are not considered regulated activities if: “…the payment transaction from the payer to the payee is carried out through a commercial agent who, on the basis of an agreement, is authorized to negotiate or conclude the sale or purchase of goods or services on behalf of either the payer or the payee.”

How it applies to AgentBureau

Section titled “How it applies to AgentBureau”
  1. Service Provision: AgentBureau acts as a commercial agent for the underlying service providers (e.g., Pingen, Telnyx, Lexoffice).
  2. Authorization: We are authorized by these providers to conclude service contracts and collect payments on their behalf.
  3. Direct Settlement: Since we operate as a specialized agent providing a integrated service, the collection of USDC as payment for these specific services does not constitute “money transmission” or “e-money issuance” in the regulated sense.

Risk Management

Section titled “Risk Management”

Even though we fall under this exemption, we maintain strict internal controls, AML (Anti-Money Laundering) checks for high-value services, and transparent reporting to ensure full compliance with the spirit of German financial regulations.