Also they state in the same sentence that it's legal to use them as payment for goods and services(just adding)
http://www.bafin.de/SharedDocs/Veroeffentlichungen/DE/Merkblatt/mb_111222_zag.html
Quote from: English translation (rough)
Units of Value intended to function as currency that can be exchanged against real benefits, goods or services or that f.e. Bitcoin, can be created in computer networks ar not classified as E-Money, even if they serve the same economical Funktions as E-Money. [snip]
A permission to create and use this Units of Value as currency is not required. If this Units become a commercial subject themselves the business has to qualify as Bank account as for § 1 Abs. 1 Satz 2 Nrn. 4 or 10 KWG or Financial Service Provider as for § 1 Abs. 1a Satz 2 Nrn. 1 - 4 KWG and operates under reservation of § 32 Abs. 1 KWG
A permission to create and use this Units of Value as currency is not required. If this Units become a commercial subject themselves the business has to qualify as Bank account as for § 1 Abs. 1 Satz 2 Nrn. 4 or 10 KWG or Financial Service Provider as for § 1 Abs. 1a Satz 2 Nrn. 1 - 4 KWG and operates under reservation of § 32 Abs. 1 KWG
Hope this helps.
