IPU Quarterly Assessment: Neue Rechtsgrundlage

8 of the German Banking Act (KWG). For compliance teams at EU parent institutions and individual institutions of third-country groups, this means the reporting requirement remains substantively unchanged: the same thresholds, content, and submission via the Bundesbank's NExt system apply. However, firms must update their internal policies and documentation to reference the KWG provision instead of the previous BaFin order.

The quarterly reporting deadlines (two months after each quarter-end) and the assessment's purpose—monitoring third-country group assets in the EU—are unchanged. Compliance teams should verify that their regulatory change management processes capture this legal shift, update relevant manuals, and ensure that staff are aware of the new legal basis. No immediate action is required beyond these administrative updates, but firms should remain vigilant for any further guidance from BaFin or the EBA.

This change underscores the importance of maintaining robust regulatory mapping to avoid referencing outdated legal bases in compliance frameworks.