Governance & Regulation

The 9th amendment to the MaRisk (consultation 02/2026) establishes the categories “small institution” (SNCI) and “very small institution” directly within the circular and transposes numerous reliefs from the supervisory notice of 26 November 2024 into binding supervisory law – including in relation to validation, stress testing, separation of functions, outsourcing, lending activities and reporting.

In pillar 4 of our governance matrix, we move away from the psychological level and focus on the ‘hard’ infrastructure: the integrity of information and proactive management through compliance.

The Instant Payments Regulation supplements the existing SEPA Regulation with new, uniform reporting requirements (regulatory reporting). In the future, payment service providers must submit their data in a structured format to the relevant national supervisory authority. What does this mean for banks?

The “magic triangle” of Pillar 3 of internal governance focuses on the complex interplay between the Executive Board, the Supervisory Board and the auditors. It is here that it is determined whether risks are identified in good time or simply “managed” until the system collapses.