Germany's Federal Financial Supervisory Authority (BaFin) launched public consultation 16/2025 on a draft update to its circular on the minimum requirements for making bail-in operationally feasible (MaBail-in), updating the 2024 circular. The draft applies to undertakings in Germany covered by Article 2 of the Single Resolution Mechanism Regulation and to undertakings within scope of Section 1(1) nos 1 to 3 of the German Recovery and Resolution Act that are not under the remit of the Single Resolution Board (SRB). It generally does not apply where the resolution plan provides for liquidation in insolvency proceedings. The main change is alignment with the SRB’s Minimum Bail-in Data Template, including the Germany country annex, to ensure consistency and reduce conversion effort if responsibility shifts from BaFin to the SRB. BaFin states the draft does not create additional compliance or administrative burden beyond existing requirements under the Single Resolution Mechanism Regulation, the German Recovery and Resolution Act implementing the Bank Recovery and Resolution Directive, and Commission Delegated Regulation (EU) 2016/1075. Comments are due by 23 September 2025. BaFin intends to publish submitted responses and asks respondents to indicate whether they consent to publication, onward sharing or use, and to avoid including personal data or confidential third-party information without documented consent.

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