Solaris

Solaris started as Solarisbank AG in 2016 because BaFin credit-institution licensing under the Kreditwesengesetz is most straightforwardly evidenced under AG governance with its mandatory two-tier Vorstand and Aufsichtsrat, formal supervisory-board composition rules and codified disclosure obligations. In 2024 the company converted AG to SE under the Umwandlungsgesetz to reflect its expanding European footprint, enable cross-border subsidiary mergers without liquidation, and position the parent for ECB direct supervision if it grows beyond the significant-institution threshold under the Single Supervisory Mechanism.

Section 32 of the Kreditwesengesetz requires evidence of capital adequacy under the Capital Requirements Regulation, internal-controls and risk-management frameworks under the MaRisk circular, anti-money-laundering systems under the Geldwaschegesetz, fit-and-proper management assessments for both the Vorstand and the Aufsichtsrat, segregated client-money mechanics, ongoing reporting in line with Finrep and Corep frameworks, and remuneration governance under the Institutsverguetungsverordnung. Application typically takes 12 to 24 months and requires extensive engagement with both BaFin and the Bundesbank as the operational supervisor.

Solaris acts as the regulated principal that holds customer accounts, issues cards, settles transactions and reports to BaFin, while partners such as Trade Republic provide the customer-facing brand, product experience and acquisition. The contractual arrangement is a regulated outsourcing under the MaRisk AT 9 framework, supplemented by partner agreements that allocate AML responsibilities and customer-due-diligence obligations. This banking-as-a-service model lets fintech brands launch faster but concentrates regulatory liability on Solaris, which is why BaFin scrutinises its partner book closely.

No. Form-changing conversion under the Umwandlungsgesetz preserves the existing legal entity, its contracts, its employees and its regulatory licences, including the BaFin credit-institution authorization. Solarisbank AG and Solaris SE are the same legal entity at different stages of its corporate-form evolution. BaFin was notified of the conversion and the SE form was reflected in the licence registry, but no fresh licence application was needed. This continuity is one of the main reasons growing German banks prefer the Umwandlungsgesetz route over alternative restructurings.