A risk assessment for banks is a systematic process for identifying, analysing and evaluating risks that could threaten a financial institution's business operations, data and systems. It is essential for meeting regulatory requirements such as MaRisk, DORA and NIS2, strengthening digital operational resilience, and ensuring the security of IT and physical infrastructure. External, independent experts such as PLANATEL® provide the specialist expertise and manufacturer neutrality required for this.

Comprehensive risk analysis in the financial sector: regulatory requirements and independent expertise

A professional risk assessment is essential to identify risks, strengthen digital operational resilience and ensure legal compliance. Find out how to design this critical process effectively.

Key Takeaways

  • A risk assessment is essential for banks due to complex regulatory requirements (MaRisk, DORA, NIS2) and the dynamic threat landscape.
  • A comprehensive approach must cover physical and digital risks as well as operational processes to ensure holistic digital operational resilience.
  • Commissioning independent, manufacturer-neutral experts such as PLANATEL® secures objective, legally compliant, forward-looking solutions without manufacturer dependency.

The financial sector has always been exposed to heightened risk – from physical threats to highly sophisticated cyberattacks. Banks and financial service providers are confronted not only with traditional security challenges but must also navigate an increasingly complex landscape of ICT risks and far-reaching regulatory requirements. The need to commission a comprehensive risk assessment for banks is therefore not just a matter of good corporate governance but an existential necessity to secure stability, customer trust and legal compliance. Such an assessment forms the foundation for a resilient, future-proof infrastructure.

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The growing importance of risk assessment in the financial sector

The dynamics of the threat landscape in the financial sector have changed significantly in recent years. Where physical robberies once dominated, complex cyberattacks, data leaks and system failures now dominate the risk discussion. Financial institutions manage sensitive customer data and form the backbone of the economy, making them a preferred target for criminal actors. A sound risk assessment is therefore no longer just an option but a strategic necessity. It allows banks to proactively identify and remedy weaknesses before attackers can exploit them. This protects not only assets and data but also the reputation and customer trust that are invaluable to financial institutions. Continuous adaptation to new threats and technologies requires a systematic approach that goes beyond isolated security measures and enables a holistic view of the risk situation. Without such systematic analysis, banks risk overlooking material risks that, in an actual event, can lead to significant financial losses and reputational damage.

The regulatory requirements for banks in Germany and Europe are extensive and constantly evolving. The Federal Financial Supervisory Authority (BaFin) sets the framework for financial institutions' business organisation and risk management through the Minimum Requirements for Risk Management (MaRisk). Under section 25a(1) of the Kreditwesengesetz (KWG), institutions must have a proper business organisation that includes appropriate, effective risk management, including a contingency plan for IT systems. MaRisk concretises these requirements, particularly with regard to IT risk management (AT 7.2).

In addition, new, far-reaching regulations are coming into force at European level. The Digital Operational Resilience Act (DORA), which has applied to financial undertakings and ICT service providers since 17 January 2025, establishes a binding European framework for managing ICT risk. DORA calls for strengthened ICT security, resilience in crisis situations, and the systematic analysis, documentation and management of cybersecurity risks. It is implemented in Germany through the Financial Market Digitalisation Act (Finanzmarktdigitalisierungsgesetz, FinmadiG).

In parallel, the NIS2 Directive (Network and Information Security 2) tightens cybersecurity obligations for a broader range of companies, including banks and financial market infrastructures. The NIS2 Implementation Act, which came into force at the end of 2025, obliges affected companies to take stricter cybersecurity measures, apply systematic risk management, and comply with extended reporting obligations for security incidents. Management is personally liable for compliance with these provisions. For banks and insurers, the DORA Regulation applies as "lex specialis" to NIS2, which means the stricter requirements of DORA must be met. These complex, overlapping frameworks require a precise, forward-looking risk assessment to ensure legal compliance and avoid potential sanctions.

The comprehensive approach to a risk assessment for banks

An effective risk assessment for banks must go far beyond pure IT security and take a holistic view of all relevant areas. PLANATEL® follows a structured approach here that takes account of both physical and digital aspects. This begins with a detailed as-is analysis of existing infrastructure and processes. This includes evaluating building and site protection concepts, access control systems, video surveillance systems, and fire alarm systems (BMA) as well as intrusion detection systems (EMA). In the digital domain, the IT infrastructure, telecommunications systems, data management and interfaces to third-party providers are examined in precise detail.

Another critical point is the analysis of operational processes and personnel-related risks. This involves assessing internal procedures, staff training levels and potential weaknesses that could arise from human error or malicious intent. The needs analysis then identifies which protection objectives need to be achieved, based on the risks identified and the regulatory requirements. This includes defining protection zones, classifying data and systems according to their protection needs, and setting resilience and recovery targets. A comprehensive approach also takes into account dependencies on external service providers and the associated risks, which are receiving increasing attention under DORA and MaRisk. Only this broad perspective allows a complete picture of the risk situation to be gained and a genuinely robust security strategy to be developed.

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Methodology and approach: the PLANATEL® process

PLANATEL® has more than 34 years of experience in the planning and consulting of complex infrastructures and offers a proven process for risk assessment based on the requirements of the BSI IT-Grundschutz framework, MaRisk and DORA. Our approach is modular and comprises the following steps:

  1. As-is survey and structural analysis: We begin by recording in detail the existing IT and telecommunications infrastructure, the physical security systems (for example fire alarm systems in accordance with DIN 14675 and VdS 2095, intrusion detection systems in accordance with DIN VDE 0833), and the organisational processes and interfaces. This also examines dependencies on third-party ICT service providers, a central aspect of the DORA Regulation.
  2. Protection needs analysis: Based on the as-is survey, we assess the protection needs of individual assets (data, systems, processes, buildings) in terms of confidentiality, integrity and availability. This is essential for prioritising protective measures.
  3. Threat and risk analysis and risk identification: We identify potential threats and weaknesses that could compromise the protection objectives. This covers technical, organisational, personnel and infrastructural risks, taking into account both internal and external threats.
  4. Risk evaluation: The risks identified are assessed in terms of their probability of occurrence and potential impact. This enables a transparent view of the risk landscape and the prioritisation of areas for action.
  5. Deriving measures and the target concept: Based on the risk evaluation, we develop concrete, targeted measures to minimise risk. This can include planning new fire alarm systems, optimising access control systems, or adapting contingency plans. Our recommendations are always manufacturer-neutral and tailored to the bank's specific needs.
  6. Documentation and reporting: All findings, assessments and recommended measures are documented in detail and summarised in a traceable report. This serves as the basis for implementation and as evidence of legal compliance to supervisory authorities.

This systematic approach ensures that all relevant risks are captured and addressed, and provides a clear roadmap for strengthening digital operational resilience and physical security.

The role of independent experts: why PLANATEL® is the right partner

The complexity of a risk assessment, particularly in the highly regulated banking sector, requires specialised knowledge and an independent perspective. Commissioning an external, independent expert such as PLANATEL® offers decisive advantages here. As a manufacturer-neutral, financially independent consulting firm since 1992, we act solely in our clients' interests. This ensures that the solutions we recommend are objective, needs-based and free of any manufacturer dependency. We accept no commissions from suppliers, underlining our independence and the quality of our advice.

Our more than 34 years of experience in planning and optimising complex IT, telecommunications and security systems, including fire alarm systems, intrusion detection systems, video surveillance systems and access control systems, makes us ideally suited to this demanding task. We have in-depth knowledge of the relevant standards and guidelines, such as DIN 14675, VdS 2095, DIN VDE 0833 and EN 54, as well as banking-supervisory requirements such as MaRisk, DORA and NIS2. Our team of experienced engineers and consultants brings not only technical expertise but also a comprehensive understanding of the specific operational and strategic challenges faced by financial institutions. Working with PLANATEL® gives banks not only a detailed risk assessment but also strategic advice aimed at long-term resilience and efficiency. We plan maintenance concepts and select certified installers to ensure the professional implementation of the planned measures, without carrying out installation work ourselves.

Integrating security systems and infrastructure planning

A risk assessment is only the first step. The real value comes from deriving and implementing concrete measures that are integrated into the existing infrastructure. PLANATEL® helps banks translate the findings of the assessment into future-proof planning of security systems and infrastructure. This includes detailed planning of fire alarm systems that meet the requirements of DIN 14675 and VdS 2095, ensuring fast, reliable alerting in the event of fire. Equally important is the planning of intrusion detection systems and video surveillance systems, designed in accordance with DIN VDE 0833, to secure physical access points and detect suspicious activity.

We also advise on the design of access control systems, which enable precise control of the flow of people and protect sensitive areas. In the ICT infrastructure domain, we plan concepts for unified communication, FTTx networks and infrastructure management that strengthen digital resilience and meet DORA's requirements. Integrating all these systems into an overarching security management system (PSIM) or building management system (BMS) is essential to enable central monitoring and control and to ensure fast, coordinated responses in an emergency. Our planning always takes account of scalability, future viability and the possibility of manufacturer-neutral procurement, in order to secure long-term investment protection and avoid manufacturer dependency.

Common mistakes and how to avoid them

When carrying out a risk assessment and subsequently implementing measures, various mistakes can be made that undermine the effectiveness of the security strategy. One of the most common mistakes is an incomplete or superficial analysis that overlooks material risks. This can happen if the assessment does not cover all relevant areas (physical, IT, processes, personnel), or if internal resources are used without sufficient specialist expertise. Another mistake is neglecting regulatory requirements. Without in-depth knowledge of MaRisk, DORA and NIS2, measures may be planned that are not legally compliant, leading to fines or supervisory action.

Lack of manufacturer neutrality is also a critical problem. If advisers or planners are tied to particular manufacturers, there is a risk that solutions will be recommended that are not optimally tailored to the bank's needs or that incur unnecessary costs. This often leads to unwanted manufacturer dependency. In addition, continuous review and adjustment of the risk assessment is often neglected. The threat landscape and regulatory requirements are constantly changing, which means a one-off assessment is not sufficient. PLANATEL® helps avoid these mistakes by carrying out a comprehensive, legally compliant, manufacturer-neutral analysis. We place great value on detailed documentation and develop concepts for regular review, to ensure the bank's security strategy always remains current and effective.

Long-term benefits and continuous optimisation of the security strategy

A professionally conducted risk assessment is not a one-off exercise but the cornerstone of continuous improvement in a bank's security strategy. The long-term benefits extend far beyond mere legal compliance. Systematically identifying and mitigating risk sustainably strengthens the financial institution's digital operational resilience. This means the bank can maintain its critical business functions even in the event of cyberattacks, technical failures or other crisis situations. This is a central objective of the DORA Regulation and is essential to the stability of the financial sector.

In addition, an optimised security strategy leads to increased efficiency and potential cost savings. Avoiding security incidents avoids direct costs for remediation, litigation and reputational loss. Forward-looking planning of security systems and infrastructure, as offered by PLANATEL®, also enables efficient use of resources and avoids misguided investment. Continuous monitoring and adjustment of security measures ensures the bank always remains at the cutting edge of technology and regulatory requirements. This not only protects against current threats but also creates a competitive advantage by strengthening customer and partner confidence in the bank's security. PLANATEL® helps banks achieve these long-term goals and establish a robust, future-proof security architecture.

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Next step

Contact us for a no-obligation initial consultation.

PLANATEL®: Independent planning and consulting since 1992
Tel: 040 / 23 73 02-30
Email: info@planatel.de

Frequently Asked Questions

How often should a bank update its risk assessment?

Given the dynamic evolution of threats and regulatory requirements, a bank should review its risk assessment regularly, at least annually, and update it as needed. Significant changes to IT infrastructure, business processes or the regulatory landscape require immediate reassessment. This is also essential to the continuous improvement of digital operational resilience required by DORA. Regular updates help identify new risks early and secure legal compliance on an ongoing basis.

What role do external ICT service providers play in a bank's risk assessment?

External ICT service providers play a decisive role, as they often perform critical functions for banks. The DORA Regulation places particular emphasis on managing third-party ICT risk and requires banks to systematically identify, assess and manage these risks. A risk assessment must therefore also cover the security and resilience of outsourced services, in order to protect the entire value chain and ensure legal compliance. PLANATEL® helps assess these dependencies.

How does the NIS2 Directive affect the physical security of banks?

Although NIS2 is primarily aimed at cybersecurity, it has indirect implications for the physical security of banks. The directive requires comprehensive risk management measures and state-of-the-art technical and organisational safeguards. This also includes protecting the physical infrastructure that is essential to operating ICT systems. Robust physical security, such as fire alarm systems or access control, is a basic precondition for the integrity and availability of IT systems and is therefore an integral part of an NIS2-compliant security strategy.

What does "digital operational resilience" mean in the context of DORA?

In the context of DORA, digital operational resilience means a financial undertaking's ability to withstand, manage and recover from ICT-related disruptions, incidents and threats, in order to ensure the continuous provision of services. It is not just about repelling attacks, but also about remaining functional in the event of a successful attack or system failure. This requires comprehensive ICT risk management, contingency plans and regular resilience testing to secure the stability of the financial sector.

How does PLANATEL® support banks in implementing MaRisk requirements?

PLANATEL® supports banks in implementing MaRisk requirements by conducting a detailed analysis of existing risk management processes and IT infrastructure. We assess the technical-organisational setup (AT 7.2) and contingency management (AT 7.3). Our advice includes developing target concepts, planning security systems and optimising processes to meet MaRisk requirements efficiently and in a legally compliant way. Here, we place great value on manufacturer-neutral advice to ensure tailor-made, sustainable solutions.

The need for a risk assessment for banks arises from the Kreditwesengesetz (KWG), in particular section 25a KWG, BaFin's Minimum Requirements for Risk Management (MaRisk), the DORA Regulation (Digital Operational Resilience Act) and the NIS2 Directive.

What is the difference between DORA and NIS2 for financial institutions?

DORA (Digital Operational Resilience Act) is a specific EU regulation for the financial sector that imposes comprehensive requirements on digital operational resilience. NIS2 (Network and Information Security 2) is a broader EU directive on cybersecurity. For financial institutions, DORA applies as "lex specialis", meaning the stricter requirements of DORA must be met.

What areas does a risk assessment for banks typically cover?

A comprehensive risk assessment for banks typically covers IT infrastructure, telecommunications systems, physical security (fire alarm systems, intrusion detection systems, video surveillance, access control), operational processes, data management and dependencies on third-party ICT service providers.

Why is manufacturer neutrality important when commissioning a risk assessment?

An independent adviser such as PLANATEL® is not tied to particular products or suppliers, which ensures an optimal choice of technologies and avoids manufacturer dependency.

Sources and further information