WpI MaRisk – BaFin publishes consultation paper
EU RegCORE Client Alert | German Regulatory Developments
Short overview
On 6 May 2026, the Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, “BaFin”) published the second draft of the circular “Minimum Requirements for the Risk Management of Investment Firms (“WpI MaRisk”)” for consultation.Press release available here.Show Footnote
The second consultation draft of the WpI MaRiskConsultation draft available here.Show Footnote is even more closely tailored to the needs and risk profile of small and medium-sized investment firms, with a focus on proportionate regulation. The aim is to reduce complexity and ensure that the requirements are principle-based.
This draft is less extensive than the prior version; it clarifies the legal requirements of Sections 38 et seq. of the Investment Firms Act (WpIG) in line with Directive 2014/65/EU (MiFID II)Available here.Show Footnote and Delegated Regulation (EU) 2017/565,Available here.Show Footnote and aims to provide greater transparency regarding supervisory expectations.
The revision also served to bring the wording into line with the MaRisk (Circular 07/2024 (BA)), for which the consultation on the 9th amendment remained open until 8 May 2026.Press release available here.Show Footnote
The deadline for submitting comments on the draft is 17 June 2026.
About us
PwC Legal is assisting a number of financial services firms and market participants in forward planning for changes stemming from relevant related developments. We have assembled a multi-disciplinary and multijurisdictional team of sector experts to support clients navigate challenges and seize opportunities as well as to proactively engage with their market stakeholders and regulators.
Moreover, we have developed a number of RegTech and SupTech tools for supervised firms, including PwC Legal’s Rule Scanner tool, backed by a trusted set of managed solutions from PwC Legal Business Solutions, allowing for horizon scanning and risk mapping of all legislative and regulatory developments as well as sanctions and fines from more than 2,500 legislative and regulatory policymakers and other industry voices in over 170 jurisdictions impacting financial services firms and their business.
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If you would like to discuss any of the developments mentioned above, or how they may affect your business more generally, please contact any of our key contacts or PwC Legal’s RegCORE Team via de_regcore@pwc.com or our website.