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ARTICLE · 25 MAY 2026

WpI MaRisk – BaFin Publishes Consultation Paper

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BaFin has released a second consultation draft of the WpI MaRisk circular, introducing more proportionate risk management requirements specifically tailored for small and medium-sized investment firms. The revised framework aims to reduce regulatory complexity while maintaining alignment with MiFID II and related EU regulations, with stakeholder comments due by June 17, 2026.

GermanyFinance and Banking
Michael Huertas
Michael Huertas
Maxi Wilkowski
Maxi Wilkowski
Melissa Meußer
Melissa Meußer
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Short overview

On 6 May 2026, the Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, “BaFin”) published the second draft of the circular “Minimum Requirements for the Risk Management of Investment Firms (“WpI MaRisk”)” for consultation.1

The second consultation draft of the WpI MaRisk2 is even more closely tailored to the needs and risk profile of small and medium-sized investment firms, with a focus on proportionate regulation. The aim is to reduce complexity and ensure that the requirements are principle-based.

This draft is less extensive than the prior version; it clarifies the legal requirements of Sections 38 et seq. of the Investment Firms Act (WpIG) in line with Directive 2014/65/EU (MiFID II)4 and Delegated Regulation (EU) 2017/565,3 and aims to provide greater transparency regarding supervisory expectations.

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