Germany's Federal Financial Supervisory Authority will not object to Pfandbrief banks pausing electronic cover register filings until 30 June 2026

Germany's Federal Financial Supervisory Authority (BaFin) issued a supervisory notice stating that, until the end of June 2026, it will not object if Pfandbrief banks do not transmit to BaFin an electronic record of all entries in their cover registers, notwithstanding the current requirement in section 5(2) of the Pfandbrief Act. The non-objection stance is intended as a bridge to planned legislative changes under the Banking Guidelines Implementation and Bureaucracy Relief Act, including an amendment to section 5(2) of the Pfandbrief Act and the repeal of sections 15 to 17 of the Cover Register Ordinance, which would remove the obligation to file electronic cover register extracts for physical archiving at BaFin. Pfandbrief banks must still ensure that information needed to reconstruct a cover register is securely retained at all times, including making a complete daily backup of each electronically maintained cover register on a separate data carrier that, like the original, remains within the scope of the Pfandbrief Act. The proper maintenance of cover registers will continue to be checked through routine cover audits, and the trustee remains responsible for monitoring compliant entry of cover assets.