The Federal Financial Supervisory Authority (BaFin) has launched a consultation on draft rules to remove requirements associated with Germany’s million euro loan reporting regime while retaining supplementary rules for large exposures. The proposal follows legislative changes abolishing reporting under Section 14 of the Banking Act from Dec. 30, 2026. It would replace the existing Large Exposures and Million Euro Loans Regulation with a regulation covering large exposures alone and amend related supervisory regulations. The replacement regulation would retain provisions on exemptions from large exposure limits, management approval requirements and large exposure reporting. It would also make arrangements for electronic submission of borrower master data more flexible. Consequential amendments to housing company solvency and audit reporting rules would replace references to deleted Banking Act provisions with the exposure definition in the Capital Requirements Regulation. Existing definitions of derivatives and off balance sheet exposures would be incorporated directly into the housing company rules, while references to million euro loan reporting would be removed from investment firm notification rules. The substantive changes are proposed to apply from Dec. 30, 2026. Sept. 30, 2026, was the final reporting reference date for million euro loans, with existing rules continuing to govern submission and supervisory feedback for those reports. The draft’s explanatory statement also provides for dispensing with the external auditor’s examination of million euro loan reporting for 2026. The abolition is intended to eliminate duplicate data collection, with BaFin and the Deutsche Bundesbank assessing that borrower risk monitoring can instead draw on statistical sources such as AnaCredit.
Germany’s Federal Financial Supervisory Authority launches consultation on rule changes following abolition of million euro loan reporting
Germany’s Federal Financial Supervisory Authority (BaFin) is consulting on replacing its combined large exposure and million euro loan regulation with rules covering large exposures alone, following the legislative abolition of million euro loan reporting from Dec. 30, 2026. The proposal would remove related references across supervisory regulations and make electronic submission of large exposure borrower master data more flexible. Sept. 30, 2026, was the final reporting reference date for million euro loans.