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Definition: What Is MaRisk?
The Minimum Requirements for Risk Management (MaRisk) form the central regulatory framework issued by BaFin (German Federal Financial Supervisory Authority) for credit and financial service institutions in Germany. MaRisk specifies the requirements of § 25a of the German Governance Banking Act (Kreditwesengesetz – KWG), offering a flexible and practical approach to risk management.
Objectives of MaRisk
Protect customer assets and interests
Ensure the institution’s risk-bearing capacity
Prevent conflicts of interest and compliance violations
Strengthen internal control systems (ICS) and governance structures
Segregation of Duties Under MaRisk: What It Means and Why It Matters
Segregation of Duties (SoD) is a core element of the internal control system and explicitly required by MaRisk. It ensures that incompatible tasks – such as initiating and controlling transactions – are performed by different individuals. This structure makes compliance with MaRisk verifiable and reduces operational and fraud risks measurably.
Goals of Segregation of Duties
Avoid conflicts of interest
Reduce error and fraud risk
Ensure objective risk assessments
Provide transparent compliance for regulators and auditors
Typical Examples
Business Area | SoD Required Between | Objective |
|---|---|---|
Credit Business | Front Office (Sales) and Back Office (Verification) | Independent credit decisions |
Trading | Trading and Risk Control / Settlement | Prevent manipulation, ensure independent oversight |
IT and Access Rights | Provisioning, Control, and Recertification | Protect against unauthorized access, enhance cybersecurity |
MaRisk, BAIT, VAIT, and DORA: How the Frameworks Interconnect
MaRisk: Overarching requirements for risk management and organizational structure, including SoD
BAIT – Supervisory Requirements for IT in Financial Institutions: Extends MaRisk with IT-specific obligations, including Identity Governance & Administration (IGA) and Identity & Access Management (IAM)
VAIT – Supervisory Requirements for IT in Insurance Undertakings: Equivalent requirements for insurers
DORA – Digital Operational Resilience Act: EU-wide regulation ensuring digital and cyber resilience
These frameworks reinforce each other, all relying on Segregation of Duties as a key control principle.
Important to know: DORA will gradually supersede BAIT and VAIT in relevant areas and complement or overlap MaRisk in IT resilience. According to BaFin: “With the direct application of Regulation (EU) 2022/2554 (DORA), BAIT and VAIT will be replaced in affected areas. National regulations will be adapted accordingly.”
Furthermore, under the Financial Market Digitalization Act (FinmadiG), from January 1, 2027, additional institutions will be required to apply DORA, while BAIT will be fully repealed by December 31, 2026.
How to Implement SoD Under MaRisk Efficiently
Example Scenario: A mid-sized bank faces challenges in meeting MaRisk SoD requirements within IT. Manual documentation and access management are error-prone and resource-intensive.
The Solution
Implement a centralized Identity Governance & Administration (IGA) system such as Garancy
Define incompatible role combinations using an SoD matrix
Automate access review and documentation processes
Perform regular recertifications and staff training
Integrate third-party applications into the central access management framework
Benefits
Reduced manual effort and process costs
Auditable MaRisk compliance for auditors and regulators
Lower risk through clear accountability and automated controls
Challenges and Best Practices in MaRisk Compliance
Common Pain Points
Complex and heterogeneous process landscapes
High manual documentation overhead
Lack of transparency in roles and permissions
Resistance to organizational change
Best Practices
Involve key stakeholders early
Define clear role and access management concepts
Use modern IGA and IAM tools
Provide continuous employee training and awareness programs
Utilize proportionality clauses for smaller institutions
Conclusion: Segregation of Duties as the Key to Audit Readiness and Resilient Processes
MaRisk compliance through effective Segregation of Duties is not just a regulatory requirement – it’s a strategic enabler. It minimizes risk, strengthens compliance, and optimizes processes. In times of digital transformation and skill shortages, automated IGA and IAM solutions offer the opportunity to reduce costs while meeting supervisory requirements efficiently and sustainably.
Get Expert Advice
Want to learn how to implement Segregation of Duties under MaRisk efficiently and audit-ready in your organization? Get in touch with our IAM specialists for a no-obligation consultation. Send us a message and we will respond to you shortly. We look forward to hearing from you!
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