Article

The 9th amendment to MaRisk and the Lending Business

NEWS 02/2026

What changes will the 9th amendment to MaRisk bring for banks in the lending business?

Prof. Dr. Konrad Wimmer

Roland Helbig

Bank Controlling

MaRisk

Risk Management

28. July 2026 10 minutes reading time

Separation of functions and approval
Collateral and Valuation Reports
Loan pricing
Lending and Credit Processing
Early risk detection
Environmentally sustainable lending and ESG risk plan
Key provisions remaining unchanged
Conclusion
Footnote

The 9th amendment to MaRisk has been welcomed by the banking industry, particularly for its stronger focus on principles, reduced complexity and improved readability: it is described as having been “well executed in many respects”.¹

This assessment is reasonable. Nevertheless, as things stand at present, questions arise in some places as to how the text of the regulation should be interpreted.

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Related Collections

MaRisk

The MaRisk set out clearly what BaFin expects from credit institutions in terms of risk management. Since the publication of the first version of the Minimum Requirements for Risk Management (MaRisk) at the end of 2005, recent developments and international regulatory initiatives have led to the MaRisk being revised on several occasions. The 7th amendment was published on 29 June 2023. Just one year later, on 29 May 2024, the 8th amendment to the MaRisk followed. On 1 April 2026, BaFin submitted the draft of the 9th amendment to the MaRisk for consultation. Here you can keep up to date with the latest developments regarding the MaRisk.

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