Regulatory Alerts2026-04-29 | Circular 11/2025Circular 11/2025 on Management and Supervisory Body Members under the German Banking Act
Issued by BaFin, this circular consolidates prior guidance notices to establish suitability and governance requirements for members of management, administrative, and supervisory bodies under the German Banking Act. It incorporates relevant EBA and ESMA guidelines, mandates a proportionality principle that weighs operational complexity and risk factors, and explicitly addresses qualified crypto custody business. The framework applies to all KWG institutions, excluding qualified crypto custodians subject to MiCAR, while ensuring European supervisory standards take precedence.
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