MaRisk amendment 2026: our comments with YPOG

Together with YPOG, we submitted comments in BaFin's consultation 02/2026 on the amendment to the Minimum Requirements for Risk Management (MaRisk). In our view, the draft addresses the right issues but leaves room for clarification, particularly for smaller institutions and crypto-asset service providers.

Our main recommendations

• Clarify the applicability to MiCAR-regulated crypto-asset service providers and the boundary with the MiCAR regime.
• Proportionality: allow specialised business models to classify risk types as non-material, with justification.
• No duplication with DORA: recognise DORA-compliant business continuity plans and business impact analyses.
• Outsourcing: clarify the treatment of mixed ICT and non-ICT services and retain the rules on the outsourcing register.
• Relief on liquidity contingency plans for institutions without material liquidity risks.

You can download our full comments as a PDF (in German) below.