A BaFin-compliant risk assessment is a strategic process for financial institutions to identify, evaluate and manage risks, particularly in the area of information and communication technology (ICT). It is based on MaRisk, BAIT and, since January 2025, also on DORA, to ensure digital operational resilience and meet supervisory requirements. This protects against financial damage and reputational loss.

Risk management and digital operational resilience at the centre of supervisory attention

A sound risk assessment that meets BaFin's strict requirements is essential to minimise risks and strengthen digital operational resilience.

Key Takeaways

  • A BaFin-compliant risk assessment is a dynamic process that integrates MaRisk, BAIT and DORA to systematically identify, assess and manage ICT and physical security risks.
  • Manufacturer-independent expertise is decisive for developing objective, tailored solutions that avoid long-term manufacturer dependency and strengthen digital operational resilience.
  • Comprehensive documentation and auditability are essential to demonstrate legal compliance to BaFin and to secure stakeholder trust.

The financial industry is undergoing constant change, driven by digitalisation, new business models and a growing threat landscape. At the same time, regulatory requirements are tightening, particularly those set by the Federal Financial Supervisory Authority (BaFin). It is therefore critically important for financial institutions to carry out a risk assessment that covers not only technical aspects but also meets BaFin's specific requirements. This is not a mere formality but a fundamental part of robust risk management and of ensuring digital operational resilience. An inadequate or flawed assessment can have far-reaching consequences, from severe sanctions to significant reputational damage and financial losses.

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Fundamentals of the BaFin-compliant risk assessment: MaRisk, BAIT and DORA

The landscape of supervisory requirements for financial institutions is complex and dynamic. At its centre are the Minimum Requirements for Risk Management (MaRisk), the Supervisory Requirements for IT in Financial Institutions (BAIT), and, since 17 January 2025, also the European Union's Digital Operational Resilience Act (DORA). These frameworks form the basis for a legally compliant risk assessment and the risk management of ICT systems. MaRisk, last updated in BaFin's circular 06/2024 (BA), sets out a holistic framework for managing all material risks and regulates the organisational obligations of institutions. It is principles-based and gives institutions latitude for individual implementation, while at the same time requiring that further precautions be taken where an institution's size, complexity or risk exposure demands it.

BAIT, as a specification of section 25a of the Banking Act (KWG), sets out the requirements for the technical and organisational equipment of IT systems, the associated business processes and IT governance. It aims to secure the IT systems of German banks efficiently and with a view to the future, and to set high standards for cyber resilience. With DORA entering into force on 17 January 2025, BAIT was amended or repealed for many institutions to avoid duplicate regulation. DORA, as a European regulation, applies directly in Germany and imposes comprehensive requirements on ICT risk management, the reporting of serious ICT-related incidents, digital operational resilience testing, and the management of ICT third-party risk. The risk assessment must take account of these overlapping and complementary requirements to ensure seamless legal compliance.

The systematic process of a BaFin-compliant risk assessment

A BaFin-compliant risk assessment is a structured, multi-stage process that goes beyond pure technical analysis and requires an in-depth understanding of regulatory requirements. The first step is the identification of relevant ICT systems and processes. All systems and applications material to the financial institution's business activities must be captured here, including those outsourced to third-party providers. BaFin is watching with concern the growing concentration among IT service providers and is calling on financial institutions for targeted risk management, particularly around outsourcing.

This is followed by the risk analysis and assessment. Here, potential threats and vulnerabilities that could impair the availability, integrity, authenticity or confidentiality of data or services are identified. This includes cyberattacks, system failures, human error and natural disasters. The assessment must consider both the likelihood of occurrence and the potential extent of the damage. Under MaRisk and BAIT, institutions are obliged to keep informed of current external and internal threats and vulnerabilities, and to inform senior management of the results of the risk analysis.

The third step is the definition and implementation of protective measures. Based on the risk analysis, technical, organisational and procedural measures are developed to minimise the identified risks. This can include the implementation of fire alarm systems (BMA) to DIN 14675 and VdS 2095, intrusion detection systems (EMA), video surveillance, access control systems, or the adaptation of IT security architectures. It is important that the measures are proportionate and effective. Finally, the risk assessment undergoes regular review and adjustment. The dynamic threat landscape and changing regulatory requirements demand a continuous adaptation of risk management. BaFin expects institutions to carry out their risk inventory regularly and on an ad hoc basis, to keep an up-to-date overall risk profile.

Specific risk areas and the role of security systems

The risk assessment in the financial sector must cover a wide range of specific risk areas, with ICT infrastructure and physical security systems playing a central role. In the field of information and communication technology (ICT), cyberattacks, data leaks, system failures and the complexity of IT architectures are the foremost concerns. BaFin calls on institutions to maintain robust ICT risk management that covers all phases of the ICT system lifecycle, from development through operation to decommissioning. In particular, the risks arising from the outsourcing of IT services must be comprehensively assessed and managed, since concentration risks can arise when many institutions rely on a small number of specialised providers.

Alongside digital threats, physical security systems are of decisive importance. These include fire alarm systems (BMA), intrusion detection systems (EMA), video surveillance systems and access control systems. Professional planning of fire alarm systems to DIN 14675 and VdS 2095 is essential to minimise injury and property damage caused by fire. These standards and guidelines define detailed requirements for the planning, installation and operation of fire alarm systems, including the qualification of specialist firms and regular maintenance. Integrating these systems into an overarching security management system enables central monitoring and control, which substantially improves response times in an emergency.

The risk assessment must also take account of the interdependencies between ICT systems and physical security systems. A failure of the power supply or network connection, for example, can impair the functioning of fire alarm systems or access control systems. Comprehensive emergency management that also covers these scenarios is therefore essential. BaFin stresses the need for an adequate contingency concept, particularly for IT systems, and for conducting risk analyses and maintaining fallback solutions. PLANATEL® supports financial institutions in planning integrated security concepts of this kind that address both ICT and physical risks and ensure legal compliance with BaFin's requirements.

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The role of independent expertise: manufacturer-independence as a success factor

The complexity of BaFin's requirements and the rapid pace of development in ICT and security technology demand specialist knowledge that is often not sufficiently available in-house. This is where the importance of independent expertise comes in. An external, manufacturer-independent adviser such as PLANATEL® can guarantee an objective risk assessment free of conflicts of interest. The choice of systems and solutions should be based solely on the financial institution's actual needs, not on the sales interests of particular manufacturers.

Manufacturer-independence means that the recommended solutions are not tied to specific products or providers. This makes it possible to select the technologies and services best suited to the individual requirements and risk profile of the financial institution. Without an obligation to any particular manufacturer, innovative approaches and cost-efficient solutions can be identified that strengthen digital operational resilience in the long term and avoid unnecessary manufacturer dependency. BaFin places value on robust risk management that also considers the risks arising from outsourcing and dependency on third-party providers.

PLANATEL® has offered independent planning and consulting services since 1992, over 34 years. This long-standing experience in the financial industry and in dealing with complex infrastructures, from telecommunications through ICT to fire alarm systems and access control, is a decisive advantage. We act as an extended workbench for management and for IT, security and facility managers, to ensure that the risk assessment not only meets current BaFin requirements but is also future-proof. Our expertise covers detailed analysis, the design of tailored solutions, and support through tendering and award, always with the aim of finding the best possible solution for our clients.

Challenges and common mistakes in implementation

Carrying out a BaFin-compliant risk assessment involves numerous challenges, and in practice the same mistakes tend to recur, undermining the legal compliance and effectiveness of risk management. One of the biggest challenges is the complexity and dynamism of regulatory requirements. MaRisk, BAIT and DORA are extensive frameworks that are constantly evolving. It takes continuous effort to stay current and integrate all relevant changes into the risk assessment in a timely manner. A common mistake here is treating the risk landscape as static, rather than pursuing an agile approach that provides for regular updates and adjustments.

Another critical point is the insufficient integration of ICT and physical security risks. These areas are often considered in isolation from one another, even though they are closely linked. A fire in a data centre, for example, can cause not only physical damage but also far-reaching ICT outages that endanger the digital operational resilience of the entire financial institution. The risk assessment must explicitly analyse and evaluate these interdependencies in order to develop holistic protection concepts. BaFin places value on comprehensive emergency management that also considers the impact of ICT incidents on business processes and the restoration of operational capability.

Common mistakes also include inadequate documentation and auditability of the risk assessment. Without transparent, traceable documentation of the risk analyses, the measures taken and their effectiveness, it is difficult to demonstrate legal compliance to BaFin. This can lead to findings and sanctions during examinations. In addition, the importance of staff awareness is often underestimated. Human error is one of the main causes of security incidents. A comprehensive training and awareness programme for all employees is therefore essential to sharpen awareness of ICT and security risks and to promote compliance with internal policies. PLANATEL® supports the identification of these vulnerabilities and the development of pragmatic solutions.

Integrating the risk assessment into overarching risk management

The BaFin-compliant risk assessment is not an isolated project but an integral part of a financial institution's overarching risk management. MaRisk calls for a holistic framework for managing all material risks, and the risk assessment provides essential information for this, particularly in the area of operational risks, which include ICT and security risks. Effective integration means that the results of the risk assessment regularly feed into risk reporting to management and the board, and are taken into account in strategic decisions.

This requires close cooperation between the various functions within the institution, such as the IT department, the security department, risk controlling and internal audit. The compliance function plays a key role in identifying relevant legal rules and requirements, non-compliance with which could jeopardise the institution's assets. The risk assessment must also be embedded in the cycle of continuous improvement. This means that identified vulnerabilities are not only remedied, but the effectiveness of the measures implemented is also reviewed regularly and adjusted as needed.

A key aspect of integration is also taking account of outsourcing and third-party risk. Financial institutions are increasingly outsourcing IT services to specialised providers, which offers advantages such as cost efficiency and specialisation but also creates new risks, particularly concentration risk. DORA requires an assessment and monitoring of third-party ICT risk throughout the entire lifecycle of its use. The risk assessment must therefore also evaluate the risks arising from dependency on external service providers, and ensure that their services meet the institution's own security standards and BaFin's requirements. PLANATEL® supports the development of strategies for managing these complex outsourcing risks and integrating them into overall risk management.

The importance of documentation and auditability

A BaFin-compliant risk assessment is only complete and effective if it is comprehensively documented and auditable at all times. BaFin places great importance on the traceability and transparency of risk management processes. Seamless documentation serves not only as evidence of legal compliance to the supervisory authority, but also as an internal reference for management, the board and operational units. It must set out in detail which risks were identified, how they were assessed, which protective measures are in place, and how their effectiveness is reviewed.

The documentation should include the following elements:

  • Risk inventory: a current overview of all material risks, including ICT and physical security risks.
  • Risk analyses: detailed descriptions of the methodology for risk identification and assessment, including the underlying scenarios and assumptions.
  • Catalogue of measures: a list of all implemented technical and organisational protective measures, such as the planning of fire alarm systems to DIN 14675 or the implementation of access control systems.
  • Test results: records and results of security tests, audits and reviews of the effectiveness of the measures. DORA, for example, requires regular digital operational resilience testing.
  • Responsibilities: clear allocation of roles and responsibilities for risk management and the implementation of protective measures.
  • Contingency concepts: detailed plans for dealing with ICT security incidents and other emergencies, including restart and recovery strategies.

Auditability ensures that external examiners and BaFin can review the adequacy and effectiveness of risk management at any time. This requires not only complete documentation but also the ability to demonstrate transparently the processes and decisions that led to the risk assessment. PLANATEL® supports financial institutions in producing audit-proof documentation that meets BaFin's highest standards and forms the basis for a successful examination.

The long-term benefits of a sound risk assessment

A BaFin-compliant risk assessment is far more than a regulatory obligation; it is a strategic investment in the future and stability of a financial institution. The long-term benefits of a sound and continuously maintained risk assessment reach well beyond mere legal compliance and create sustainable added value for the entire organisation.

One of the primary benefits is the significant reduction of risks and potential damage. By systematically identifying and assessing threats, proactive measures can be taken to prevent ICT security incidents, system failures or physical security gaps, or to minimise their impact. This protects not only against direct financial losses but also against indirect costs such as business interruption, reputational damage and loss of customer trust. According to a survey by the European Central Bank, European banks reported over 2,400 security-related ICT incidents in 2023, an increase of almost 40 percent on the previous year, underlining the urgency of proactive measures.

Furthermore, a sound risk assessment leads to improved digital operational resilience. Financial institutions are increasingly dependent on their ICT infrastructure. The ability to maintain or rapidly restore operations in the event of serious ICT incidents is decisive for competitiveness and for meeting DORA's requirements. A robust risk assessment forms the basis for effective contingency and business-continuity plans.

Not least, a transparent and demonstrably legally compliant risk assessment strengthens the trust of customers, partners and the supervisory authority. It demonstrates a high level of responsibility and professionalism in handling sensitive data and critical infrastructure. This can have a positive effect on business development and strengthen the institution's position in the market. PLANATEL® supports financial institutions in realising these long-term benefits through strategic, independent planning and in shaping a secure digital future.

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Frequently Asked Questions

What are the key differences between MaRisk, BAIT and DORA in relation to the risk assessment?

MaRisk (Minimum Requirements for Risk Management) forms the overarching framework for risk management at financial institutions. BAIT (Supervisory Requirements for IT in Financial Institutions) specifies MaRisk particularly for information technology and information security. DORA (Digital Operational Resilience Act) is an EU regulation that has applied directly since January 2025 and harmonises and extends the requirements for digital operational resilience, ICT risk management, and reporting obligations for ICT incidents. While BAIT and MaRisk are principles-based, DORA provides more concrete requirements that must be reflected in the risk assessment.

What role do fire alarm systems (BMA) play in a BaFin-compliant risk assessment?

Fire alarm systems (BMA) are a critical component of physical security and therefore relevant to the risk assessment. Their planning and execution must comply with the standards DIN 14675 and VdS 2095 to minimise injury and property damage caused by fire. The functioning of a BMA is closely linked to the ICT infrastructure, for example via power supply and network connections. A BaFin-compliant assessment must analyse these interdependencies and ensure that BMAs are integrated into emergency management to guarantee business continuity.

How does the outsourcing of IT services affect the risk assessment under BaFin's requirements?

The outsourcing of IT services is a central focus for BaFin. Institutions must carry out a comprehensive risk assessment before outsourcing IT services to third parties. This includes analysing concentration risks that can arise from dependency on a small number of providers. DORA requires continuous monitoring of ICT third-party risk throughout the entire lifecycle of the outsourcing arrangement. The risk assessment must ensure that outsourced processes meet the same security standards and regulatory requirements as internal processes, and that exit strategies exist in case a service provider fails.

What consequences can result from a risk assessment that does not comply with BaFin's requirements?

A risk assessment that does not comply with BaFin's requirements can have serious consequences for financial institutions. These include supervisory measures such as orders to remedy deficiencies, fines and, in the worst case, withdrawal of the licence to operate. Significant financial losses can also arise from security incidents, business interruptions and reputational damage. Senior management and the board bear responsibility for adequate risk management, and a lack of legal compliance can also lead to personal liability.

How can PLANATEL® support my financial institution with a BaFin-compliant risk assessment?

PLANATEL® has offered manufacturer-independent expertise as an independent planning and consulting firm for over 34 years. We support financial institutions in the detailed analysis of their ICT and security systems, the identification of risks, and the development of tailored concepts that meet the requirements of MaRisk, BAIT and DORA. Our services cover the as-is survey, needs analysis, target concept, detailed planning, tendering/award and support during implementation, to ensure a legally compliant and future-proof risk assessment. We plan maintenance concepts and select certified installers, without carrying out installation or maintenance ourselves.

What are BaFin's core requirements for risk management?

BaFin's core requirements for risk management are set out in the Minimum Requirements for Risk Management (MaRisk). These cover a holistic framework for the identification, assessment, management and monitoring of all material risks at a financial institution, including operational risks such as ICT and security risks.

What role does DORA play for the risk assessment?

DORA (Digital Operational Resilience Act) is an EU regulation that has applied directly in Germany since 17 January 2025 and imposes comprehensive requirements on the digital operational resilience of financial undertakings. For the risk assessment, this means that ICT risk management, reporting obligations for ICT incidents, digital resilience testing and the management of ICT third-party risk must be explicitly considered.

Why is manufacturer-independence important when planning security systems?

Manufacturer-independence in the planning of security systems, such as fire alarm systems or access control, is decisive for ensuring objective, needs-based solutions. It avoids unnecessary manufacturer dependency and enables the selection of the best technologies and services, optimally tailored to the specific requirements and risk profile of the financial institution.

How often must a risk assessment be updated?

BaFin expects financial institutions to update their risk inventory, and therefore the risk assessment, regularly and on an ad hoc basis. Given the dynamic threat landscape and changing regulatory requirements, continuous review and adjustment of risk management is required to ensure the legal compliance and effectiveness of protective measures.

Sources and further information