MaRisk is an acronym referring to the minimum requirements for risk management a circular by the German Federal Financial Supervisory Authority ( Bundesanstalt für Finanzdienstleistungsaufsicht, BaFin) providing concepts. Federal Financial Supervisory Authority (BaFin). Minimum Requirements for Risk Management (MaRisk) – Page 1 of BaFin Translation -. The present. BaFin publishes amended Minimum Requirements for Risk MaRisk are to be complied with by all institutions within the meaning of Section 1.

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The MaRisk have undergone several revisions due to recent developments and international regulatory initiatives.

BaFin’s Supervisory Requirements For IT In Financial Institutions – Finance and Banking – Germany

For further information on the updates to the MaRisk please see our Client Alert which forms baafin of this briefing series.

All institutions must prepare regular risk reports and be able baafin produce risk information on a timely basis as necessary. Amongst others, these requirements include the strategic development of the institution’s organizational and operational structure of IT and of the outsourcing of IT services, the responsibilities and integration of information security into the organization and the strategic development of the IT architecture.

Content International developments Data aggregation: These bafn are already in force and now form a core component of IT supervision in the banking sector in Germany. The rapidly expanding provision of IT-based financial services as well as banks’ and financial institutions’ increasing internal reliance on IT processes put new challenges on supervisors.

If employees and management are open to alternative points of view, then it is guaranteed that decisions will be made with msrisk for all relevant factors. Nonetheless, BaFin expects that, as a result of the requirements of AT 4.

These rights include the rights of access to the business premises, data centers, servers, and employees of the cloud service provider. The established principles-based character of the MaRisk has been preserved, allowing the banks enough leeway with regard to their practical implementation of the requirements.

Tools Share content Share Webcode https: Further, institutions must take into account that the BAIT and the MaRisk do not compile the supervisory expectations for compliance with the requirements for IT in financial institutions in an exhaustive way.

Did you find this article helpful? Their IT infrastructure must facilitate comprehensive and precise aggregation of risk exposures and must promptly make this information available to the banks’ reporting systems. In this regard the BAIT has a significant impact on the market: In-scope firms will want to implement and adhere to the principles- based requirements of the BAIT as non-compliance might bring them into the supervisor’s focus.


By way of technical and organizational measures institutions marizk ensure that circumvention of the requirements contained in the user access rights concepts is excluded. This requires clear maisk from the management board, and from other management levels, as to what behaviour is and is not desired. Outsourcing individual activities and processes of the control functions and the internal audit function, however, remains a possibility for all institutions.

G-SII have had to meet these requirements since January in any event.

BaFin publishes revised MaRisk including clarifications on outsourcing

In addition, risk reports must contain an assessment of future risks. Ireland has for many years been the premier European location for activities to support the global cross border debt issuance market.

Struggling to keep up to date with Trading Venue requirements? BaFin emphasizes that such rights of information and audit must be unrestricted: Supervised entities are afforded flexibility in defining the nature and the scope of a risk assessment, and the results of the risk mzrisk must be taken into account in developing contractual arrangements between supervised entities and their cloud service providers.

Please take note of the Standard Terms and Conditions of Use. The new version of the MaRisk entered bacin force upon publication. In-scope firms include inter alia credit and financial institutions within the meaning of the KWG 9 as well as German branches of third country firms providing banking business or financial services in Germany third country branches.

Under certain conditions regionally active institutions and small institutions can appoint a joint information security officer. The content of this article is intended to provide a general guide to the subject matter. These requirements should be understood in proportion to the institution’s business activities and the risks taken: Additional details are explained in the accompanying notes to the MaRisk only available in Narisk.

Appropriate arrangements must ensure that after the application goes live the confidentiality, integrity, availability and bfain of the data to be processed are comprehensively assured. Information security management It is the management board’s bzfin to agree an information security policy and to communicate this within the institution. The requirements primarily provide greater clarification regarding the limitations of outsourcing. However, BaFin grants institutions a year to implement requirements that are entirely new mraisk that do not simply clarify existing requirements.


The MaRisk also require central outsourcing managementat least from institutions abfin extensive outsourcing arrangements. This is directed at all institutions. Apart from the purely technical side, the BAIT’s impact on institutions’ general organizational set-up and governance arrangements must be analyzed and necessary amendments made. With the requirement of at least quarterly reporting to the management board the BAIT underlines the significance of this function within institutions’ internal control framework.

A code of conduct, as is now required by AT 5, is an important tool here. The information security officer is responsible for all information security issues within the institution and with regard to third parties and must report to the management bbafin on the status of information security regularly, at least once a quarter, and on an ad hoc basis.

BaFin publishes revised MaRisk 2017 including clarifications on outsourcing

Outsourcing and other external procurement of IT services Under the BAIT, risk assessments must be conducted prior to each instance of “other external procurement of IT services”. The MaRisk also specify that the institution must still possess the knowledge and experience required to ensure effective monitoring of the services performed by the external service provider in the event that activities and processes in the control and core bank areas are outsourced.

Did you find this article helpful? The MaRisk provide a comprehensive framework for the management of all significant risks based on section 25a of the German Banking Act Kreditwesengesetz — KWGwhich governs the organisational requirements for institutions with regard to their internal risk management. In view of the rapid developments on the financial markets, modern regulation cannot rely on compliance with quantitative indicators alone, but must focus in particular on institutions’ risk management.

The general approach is that the court is likely to allow inspection if the open justice principle is engaged and there is a legitimate interest.