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ARTICLE · 18 MAY 2026

Bafin Seeks Public Comment On The 9th Amendment To The MaRisk

BaFin has published a draft of the 9th amendment to Germany's Minimum Requirements for Risk Management (MaRisk), introducing a fundamental revision aimed at reducing regulatory complexity for financial institutions. The proposed changes establish a new three-tier classification system for institutions based on size, implement proportional risk assessment requirements, and integrate European Banking Authority guidelines on environmental scenario analysis and internal governance.

GermanyFinance and Banking

QuickTake

On 1 April 2026, the Federal Financial Supervisory Authority (Bundesanstalt für Finanzdientsleistungsaufsicht - Bafin)1 published the draft of the 9th amendment to the “Minimum Requirements for Risk Management (MaRisk)”2 for consultation. According to the draft, the MaRisk are to be fundamentally revised.

The revised version is intended to significantly reduce the complexity of regulatory requirements. Furthermore, a new transparent classification of small and very small institutions is intended to simplify the proportional gradation of the applicable requirements in future.

Furthermore, as part of this process, BaFin is also implementing the guidelines on environmental scenario analysis (EBA/GL/2025/04), as well as the guidelines on internal governance (EBA/GL/2021/05).

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