Regulatory Alerts2021-08-23 | Minimum Requirements under Supervisory Law on the System of Governance of Institutions for Occupational Retirement ProvisionMinimum Requirements under Supervisory Law on the System of Governance of Institutions for Occupational Retirement Provision
The Federal Financial Supervisory Authority (BaFin) issued this circular to establish binding guidelines for German Institutions for Occupational Retirement Provision (IORPs) regarding their system of governance. IORPs must implement a principle-based, proportionate governance framework that assigns collective responsibility to the management board and mandates clear segregation of duties alongside defined materiality thresholds for key risk categories. The regulations require documented risk cultures, dual control mechanisms for material decisions, and a comprehensive written policy that aligns with business strategies, all of which must be regularly assessed and adapted to the institution's profile.
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