On June 12, 2026, the German regulator, the Federal Financial Supervisory Authority (BaFin), launched a consultation on the revision of its circular “Minimum Requirements for Risk Management of Capital Investment Companies (KAMaRisk).”
The revision of the KAMaRisk is driven, among other things, by the Fund Risk Limitation Act (Fondsrisikobegrenzungsgesetz – FRiG). The FRiG implements the revised EU Directive on the regulation of alternative investment funds (AIFMD II) into German law. This directive establishes harmonised requirements across the EU for credit funds. Accordingly, the amendments to the KAMaRisk primarily concern the specific requirements for the granting of loans and investment in unsecuritised loan receivables (Section 5 KAMaRisk), which are significantly shortened and reduced in complexity.
Requirements relating to electronic data processing (Section 8 KAMaRisk in its previous version) are removed entirely. In addition to eliminating overlaps with DORA, the consultation draft of KAMaRisk explicitly incorporates ESG risks into risk management expectations. Further, the rules on internal audit are aligned with international standards.
The amendments to KAMaRisk aim to reduce the complexity of regulatory requirements by bringing national rules closer in line with the underlying European framework.