Regulatory Alerts2026-01-14 | Circular 09/2025 (VA)BaFin Circular 09/2025 on Minimum Governance Requirements for Solvency II Insurance Undertakings
BaFin issued Circular 09/2025 to establish binding guidelines on the system of governance for German Solvency II insurance undertakings and groups. The circular mandates proportionate implementation of risk culture, materiality thresholds, and segregated responsibilities while aligning national requirements with EIOPA guidelines, DORA, and the AI Regulation. It takes effect on 14 October 2025, replacing Circular 02/2017 and ensuring consistent supervisory application across all covered entities.
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