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ARTICLE · 23 APRIL 2026

Investment Management Client Alert April 2026

K&L Gates
K&L Gates
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K&L Gates

K&L Gates

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On 1 April 2026, the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, BaFin)...

GermanyFinance and Banking
Philipp Riedl
Philipp Riedl
Hilger Von Livonius
Hilger Von Livonius
Susanne Albrecht-Roggenstroh, Dipl.-Kffr.
Susanne Albrecht-Roggenstroh, Dipl.-Kffr.
Martin Berg
Martin Berg

BaFin Consults 9th MaRisk Amendment

On 1 April 2026, the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, BaFin) submitted a draft of a 9th amendment to the “Minimum Requirements for Risk Management (MaRisk)” for consultation. As part of the amendment, the circular was fundamentally revised and its complexity was significantly reduced, in particular in order to expand the scope for a proportional application of the requirements. In the future, the proportional requirements will be based on the clearly defined size classes of the supervised institutions, with a distinction being made between very small institutions, small institutions, and less-significant institutions. Institutions that are subject to direct supervision by the European Central Bank (ECB) shall be excluded from the scope of the MaRisk. In addition, BaFin is implementing the new guidelines of the European Banking Authority (EBA) on environmental scenario analysis and

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