Circular 06/2026 (BA): Minimum Requirements for Risk Management - MaRisk

BA 54 – MaRisk dated 30.06.2026 Federal Financial Supervisory Authority (BaFin)

Table of Contents
AT 1 Objective of the Circular 7
AT 2 Scope of Application 9
AT 2.1 Target Group 9
AT 2.2 Risks 10
AT 2.3 Transactions 11
AT 3 Responsibility of Management and Supervisory Body 14 AT 3.1 Overall Responsibility of Management 14 AT 3.2 Responsibility of the Supervisory Body and its Committees 14 AT 4 General Requirements for Risk Management 15 AT 4.1 Risk Capacity 15 AT 4.2 Strategies 17 AT 4.3 Internal Control System 19 AT 4.3.1 Structural and Process Organization 19 AT 4.3.2 Risk Steering and Controlling Processes 20

BA 54 - MaRisk dated 30.06.2026 Federal Financial Supervisory Authority (BaFin) AT 4.3.3 Stress Tests 21 AT 4.3.4 Use of Models 22 AT 4.4 Special Functions 24 AT 4.4.1 Risk Controlling Function 24 AT 4.4.2 Compliance Function 25 AT 4.4.3 Internal Audit 26 AT 5 Organizational Guidelines 28 AT 6 Documentation 29 AT 7 Resources 30 AT 7.1 Personnel 30 AT 7.2 Technical and Organizational Equipment 30 AT 7.3 Emergency Management 31 AT 8 Adaptation Processes 32 AT 8.1 New Product Process 32 AT 8.2 Changes to Operational Processes or Structures; Acquisitions and Mergers 33

BA 54 - MaRisk dated 30.06.2026 Federal Financial Supervisory Authority (BaFin) AT 9 Outsourcing 34 BT 1 Special Requirements for the Internal Control System 40 BTO Requirements for Structural and Process Organization 40 BTO 1 Credit Business 41 BTO 1.1 Segregation of Duties and Veto Rights 42 BTO 1.2 Requirements for Processes in Credit Business 45 BTO 1.2.1 Credit Granting 48 BTO 1.2.2 Post-Granting Credit Processing 49 BTO 1.2.3 Credit Processing Control 50 BTO 1.2.4 Intensive Supervision 51 BTO 1.2.5 Treatment of Problem Loans 51 BTO 1.2.6 Risk Provisions 53 BTO 1.3 Requirements for Procedures for Early Risk Detection and Treatment of Forbearance 54 BTO 1.3.1 Procedures for Early Risk Detection 54 BTO 1.3.2 Treatment of Forbearance 55 BTO 1.4 Risk Classification Procedures 56 BTO 2 Trading Business 57

BA 54 - MaRisk dated 30.06.2026 Federal Financial Supervisory Authority (BaFin) BTO 2.1 Segregation of Duties 57 BTO 2.2 Requirements for Processes in Trading Business 58 BTO 2.2.1 Trading 58 BTO 2.2.2 Settlement and Control 60 BTO 2.2.3 Representation in Risk Controlling 64 BTO 3 Real Estate Business 64 BTO 3.1 Structural Organization 64 BTO 3.2 Requirements for Processes in Real Estate Business 65 BTO 3.2.1 Acquisition or Construction of Real Estate 66 BTO 3.2.2 Further Processing and Monitoring 67 BTR Requirements for Risk Steering and Controlling Processes 67 BTR 1 Counterparty Default Risks 68 BTR 2 Market Price Risks 69 BTR 2.1 General Requirements 69 BTR 2.2 Market Price Risks of the Trading Book 70 BTR 2.3 Market Price Risks of the Banking Book (including Interest Rate Risks) 70

BA 54 - MaRisk dated 30.06.2026 Federal Financial Supervisory Authority (BaFin) BTR 3 Liquidity Risks 73 BTR 4 Operational Risks 74 BTR 5 Credit Spread Risks in the Banking Book 75 BT 2 Requirements for Risk Reporting 76 BT 2.1 General Requirements for Risk Reports 76 BT 2.2 Reports by the Risk Controlling Function 77 List of Abbreviations 80

BA 54 - MaRisk dated 30.06.2026 Federal Financial Supervisory Authority (BaFin) AT 1 Objective of the Circular 1 This Circular, based on Section 25a(1) of the Banking Act (KWG), provides a flexible and practical framework for the design of risk management by institutions. It further clarifies the requirements of Section 25b KWG (outsourcing) and Section 26c KWG (ESG risks).

CRD Third-Country Branches
Since CRD third-country branches do not have a supervisory body, these institutions must instead involve their headquarters in an appropriate manner.

2 The Circular also provides a qualitative framework for interpreting key articles of Directive 2013/36/EU (Banking Directive – “CRD IV”, last amended by Directive (EU) 2024/1619 of 31 May 2024, “CRD VI”) regarding the organization and risk management of institutions, as implemented in the Banking Act. Accordingly, institutions must establish appropriate management, steering, and control processes (“Robust Governance Arrangements”), effective procedures for identifying, steering, monitoring, and communicating actual or potential risks, and appropriate internal control mechanisms. Furthermore, they must possess effective and comprehensive procedures and methods ensuring that sufficient internal capital is available to cover all material risks (Internal Capital Adequacy Assessment Process). The Circular sets the framework for the proportional implementation of requirements by institutions and the intensity of supervision by the authorities.

EBA Guidelines
The following EBA guidelines are implemented in the MaRisk insofar as they concern the risk management of institutions:

• EBA Guidelines on Stress Tests of Institutions (EBA/GL/2018/04)
• EBA Guidelines on the Management of Non-Performing and Forborne Exposures (EBA/GL/2018/06)
• EBA Guidelines on Outsourcing (EBA/GL/2019/02)
• EBA Guidelines on Lending and Monitoring (EBA/GL/2020/06)
• EBA Guidelines on Internal Governance (EBA/GL/2021/05)
• EBA Guidelines based on Article 84(6) of Directive 2013/36/EU on criteria for identifying, assessing, managing, and mitigating risks arising from potential interest rate changes, and for assessing and monitoring credit spread risk in banking book transactions (EBA/GL/2022/14)
• EBA Guidelines on the Management of Environmental, Social, and Governance Risks (ESG Risks) (EBA/GL/2025/01)
• EBA Guidelines on Environmental Scenario Analysis (EBA/GL/2025/04).

Sections from the above-mentioned EBA guidelines are only to be observed in addition to the MaRisk requirements if the MaRisk refer to these sections; if these sections in turn refer to other sections or an annex of these EBA guidelines, these references may be disregarded. Otherwise, the cited EBA guidelines are considered fully implemented in the MaRisk – i.e., to the extent that BaFin has declared compliance.

BA 54 - MaRisk dated 30.06.2026 Federal Financial Supervisory Authority (BaFin) 3 The appropriate handling of the principle of proportionality underlying the MaRisk by institutions involves ensuring that institutions take further measures beyond certain requirements presented in the MaRisk in individual cases, insofar as this is necessary to ensure appropriate and effective risk management. In addition to the proportional application of requirements to all institutions, size classes are defined that grant concrete further relaxations. These are explicitly regulated in the relevant sections.

References to EBA Guidelines in the MaRisk and the Principle of Proportionality Where the MaRisk refer to EBA guidelines, the requirements of the EBA guidelines may be implemented taking into account the proportionality criteria mentioned therein.

Small and Very Small Institutions within the Meaning of the MaRisk Small institutions within the meaning of the MaRisk are institutions classified as small and non-complex institutions (SNCI) pursuant to Article 4(1)(145) of the EU Capital Adequacy Regulation (Regulation (EU) No 575/2013, CRR) in its current version, as well as CRD third-country branches of risk class 2. Very small institutions within the meaning of the MaRisk are institutions and CRD third-country branches that do not exceed an average balance sheet total of EUR 1 billion over a four-year period. Very small institutions may claim the relaxations for small institutions even if they do not meet the SNCI criteria. Factoring institutions are additionally considered very small only if the annual volume of receivables purchased does not exceed EUR 5 billion on average over a four-year period.

4 The Circular also clarifies the requirements of Article 16 of Directive 2014/65/EU (MiFID II) via Section 80(1) of the Securities Trading Act (WpHG) in conjunction with Section 25a(1) KWG, insofar as this applies equally to credit institutions and financial service institutions. This concerns the general organizational requirements pursuant to Article 5, the requirements for risk management and internal audit pursuant to Articles 7 and 8, the requirements for management responsibility pursuant to Article 9, and requirements for outsourcing pursuant to Articles 13 and 14 of Directive 2006/73/EC (Implementing Directive to MiFID II).

The regulations on the prevention of money laundering and terrorist financing must always be observed.

5 BaFin expects that the flexible basic orientation of the Circular is taken into account during supervisory examinations. Examinations are to be conducted based on a risk-oriented examination approach.

BA 54 - MaRisk dated 30.06.2026 Federal Financial Supervisory Authority (BaFin) 6 The Circular is structured modularly, so that necessary adjustments in certain regulatory areas can be limited to the timely revision of individual modules. A general part (Module AT) contains fundamental principles for the design of risk management. Specific requirements for the organization of credit, trading, and real estate business are set out in a special part (Module BT). Taking risk concentrations into account, this module also sets requirements for the identification, assessment, steering, monitoring, and communication of counterparty default risks, market price risks, liquidity risks, and operational risks. Furthermore, Module BT provides a framework for the design of risk reporting.

AT 2 Scope of Application
AT 2.1 Target Group
1 The requirements of the Circular apply to all institutions pursuant to Section 1(1b) KWG or Section 53(1) KWG, provided they are not classified as significant institutions within the meaning of Article 6 of Regulation (EU) No 1024/2013 of 15 October 2013 (SSM Regulation) and are thus not subject to direct supervision by the ECB. Furthermore, the requirements also apply to CRD third-country branches within the meaning of Section 53c(1) KWG in accordance with Sections 53c-53cq. They also apply to branches of German institutions abroad. They do not apply to branches of companies with their seat in another State of the European Economic Area pursuant to Section 53b KWG.

Some requirements are only to be observed by institutions with a high NPL portfolio at the individual institution level or consolidated at the group level. These requirements are marked accordingly in the individual modules. A threshold of non-performing loans (gross) of 5% or more applies for the applicability of these requirements.

2 Financial service institutions and large investment firms pursuant to Section 2(18) of the Investment Firm Act (WpIG), which are obliged pursuant to Section 4 of this Act to apply Sections 25a, 25b, and 26c of the KWG, must observe the requirements of the Circular insofar as this appears necessary due to the size of the institution and the nature, scope, complexity, and risk content of the business activities to comply with statutory duties pursuant to Sections 25a, 25b, and 26c KWG. This applies in particular to Modules AT 3, AT 5, AT 7, and AT 9.

3 Parent companies of an institution group, a financial holding group, or a financial conglomerate must ensure that the requirements of this Circular are observed at the group level insofar as this appears sensible and necessary for appropriate risk management at the group level pursuant to Section 25a(3) KWG. This includes:

• Development and implementation of group-wide strategies (business strategy, risk strategy);
• Establishment of a process to ensure risk capacity at the group level based on the group-wide overall risk profile;
• Establishment of appropriate structural and process organizational specifications at the group level;
• Establishment of appropriate risk steering and controlling processes, including appropriate stress tests, at the group level;
• Group audit, which operates in addition to the internal audit of group-affiliated companies;
• Appropriate reporting to the management of the parent company (risk reports, audit reports of the group audit).

Design of Risk Management at the Group Level
The specific design of risk management at the group level depends in particular on the nature, scope, complexity, and risk content of the business activities operated by the group, the size of the group, and the corporate law possibilities.

AT 2.2 Risks
1 The requirements of the Circular relate to the management of risks material to the institution. To assess materiality, management must regularly and on an ad-hoc basis gain an overview of the institution's risks through a risk inventory (overall risk profile). The risks must be captured at the level of the entire institution, regardless of in which organizational unit the risks originated.

Generally, at least the following types of risks are to be classified as material:
Risk Concentrations
In addition to risk positions against single counterparties that constitute a risk concentration solely due to their size, risk concentrations can arise both through the correlation of risk positions within one risk type (“Intra-Risk Concentrations”) and through the correlation of risk positions across different risk types (due to common risk factors or interactions of different risk factors of different risk types – “Inter-Risk Concentrations”).

Information and Communication Technology Risks

BA 54 - MaRisk dated 30.06.2026 Federal Financial Supervisory Authority (BaFin) a) Counterparty default risks (including country risks), b) Market price risks, c) Liquidity risks, and d) Operational risks.

For the risk types listed here as generally material, a separately documented materiality analysis may be omitted. Risk concentrations associated with material risks must be taken into account. Appropriate measures must be taken for risks classified as immaterial. A threshold of 5% relative to the risk coverage potential is recognized as appropriate as the materiality threshold from an economic perspective. Information and Communication Technology Risks (ICT Risks) are a component of operational risks and must be explicitly included in the risk inventory.

2 The institution must, as part of the risk inventory, examine which risks can significantly impair the asset position (including capital adequacy), earnings position, or liquidity position. The risk inventory must not be oriented solely towards the impacts in financial accounting or formal legal structures. With regard to a holistic risk inventory, risks from off-balance sheet corporate structures must also be considered (e.g., risks from non-consolidated special purpose vehicles).

3 In assessing materiality as part of the risk inventory, the design of the internal control system (risk capacity concept, risk steering and controlling processes, processes within structural and process organization), the (risk) strategy, and reporting, the impacts of ESG risks must be appropriately considered.

This involves basing the assessment on various plausible scenarios that are consistent with scientific findings. Relying solely on historical data is insufficient. The assessment must take place from both short- and medium-term perspectives as well as over a long time horizon.

Consideration of ESG Risks
ESG risks (ESG: Environmental, Social, Governance) are understood as events or conditions in the areas of environment, social issues, or corporate governance that act as risk drivers/factors and thus impact the risk types listed in para. 1 a) - d) and other material risk types.

AT 2.3 Transactions
1 The Circular further clarifies and details the particularly risk-relevant transaction types: credit business, trading business, and real estate business.

2 Credit transactions are fundamentally transactions (balance sheet assets and off-balance sheet transactions) with counterparty default risks.

Credit Business
The classification as credit business applies regardless of whether the relevant positions are to be subject to securitization.

3 A credit decision is any decision regarding new credits, credit increases, participations, limit exceedances, the setting of borrower-specific limits as well as counterparty and issuer limits, rollovers, and changes to risk-relevant facts underlying the credit approval (e.g., collateral, purpose of use). It is irrelevant whether this decision is made exclusively by the institution itself or jointly with other institutions (so-called syndicated business).

Rollovers
Regarding the term “rollovers,” no distinction is made between external and internal rollovers (e.g., internal extension of externally b.a.w. committed credits). Internal “monitoring templates” that serve solely for credit monitoring during the term are not considered rollovers and thus not credit decisions.

Interest Rate Adjustments
Interest rate adjustments following the expiration of interest fixation periods (which do not coincide with the total term) can be regarded as part of the overall credit contract, which were (co-)reviewed before credit granting. Therefore, they are generally not a separate credit decision.

Forbearance
Forbearance does not constitute planned changes to the credit relationship from the outset and is thus to be qualified as a credit decision.

4 Trading transactions are fundamentally all contracts that constitute a transaction with crypto assets or a financial instrument pursuant to Section 1(11) KWG in the form of a) money market transactions, b) securities transactions, c) foreign exchange transactions, d) transactions in tradable receivables (e.g., trading in promissory notes), e) transactions in commodities, or f) transactions in derivatives

Emission Business
The initial issuance of securities is fundamentally not a trading transaction. However, the initial acquisition from an emission constitutes a trading transaction. In the case of initial acquisition, relaxations regarding market fairness control are possible (see explanations for BTO 2.2.2, Settlement and Control in Trading Business, para. 5).

Traditional Commodity Business of Mixed-Economy Credit Unions The requirements for trading business apply mutatis mutandis to the traditional commodity business.

BA 54 - MaRisk dated 30.06.2026 Federal Financial Supervisory Authority (BaFin) as a basis and which are concluded in their own name and for their own account. Transactions with bearer bonds and securities lending are also considered securities transactions, but not the initial issuance of securities. Trading transactions also include – regardless of the subject matter of the transaction – agreements on return or repurchase obligations and securities lending transactions. Receivables pursuant to letter d) are to be qualified as trading transactions if the institution has a trading intent based on suitable criteria.

5 Transactions in derivatives include futures transactions whose price is derived from an underlying asset, a reference price, reference interest rate, reference index, or a pre-defined event.

Guarantees/Aval
Guarantees/aval and similar instruments do not fall under the derivative definition of this Circular.

6 Real estate transactions are transactions with real estate operated for the own account of an institution, where one of the following intentions is pursued:
a) Acquisition or construction of real estate for generating income through leasing/renting, b) Acquisition or construction of real estate for resale (e.g., developer business), c) Generating income through leasing/renting of existing real estate or resale.

In addition to direct real estate transactions, real estate transactions operated for the own account of subsidiaries of the institution pursuant to Section 290 of the German Commercial Code (HGB) are also considered real estate transactions of the institution, provided that the assets of the subsidiary consist exclusively or predominantly of real estate transactions or participations in real estate transactions. Subsidiaries are equated with companies on which institutions can jointly exercise a controlling influence.

Real estate transactions that predominantly serve the institution's own business operations are not considered real estate transactions.

Establishment of Parent-Subsidiary Relationships The acquisition of a relationship with a company that results in that company becoming a subsidiary is equated with the acquisition of real estate, provided that the assets of the subsidiary consist exclusively or predominantly of real estate transactions or participations in real estate companies.

BA 54 - MaRisk dated 30.06.2026 Federal Financial Supervisory Authority (BaFin) AT 3 Responsibility of Management and Supervisory Body AT 3.1 Overall Responsibility of Management 1 All members of management are responsible – regardless of internal allocation of responsibilities – for the proper organization of business and its further development. Management fulfills this responsibility only if they can assess risks and take the necessary measures to limit them. This also includes the development, promotion, and monitoring of an appropriate risk culture within the institution and the group. The management of a parent company of an institution group, a financial holding group, or a financial conglomerate is also responsible for the proper organization of business in the group and thus for appropriate and effective risk management at the group level.

Risk Culture
The risk culture generally describes the manner in which...