On November 13, 2025, the German regulator, the Federal Financial Supervisory Authority (BaFin), issued version 5 of its Circular MaBail-in in the context of the resolution of institutions. The aim is to improve the resolvability of institutions for which the application of a bail-in resolution tool is planned.

The circular is addressed to all institutions as defined in Article 2 of the SRM Regulation, as well as to institutions as defined in Sections 1(1) no. 1 to no. 3 of the German Act on the Restructuring and Resolution of Institutions and Financial Groups (Gesetz zur Sanierung und Abwicklung von Instituten und Finanzgruppen – SAG) in the Federal Republic of Germany, provided that they are not within the remit of the Single Resolution Board (SRB) pursuant to Articles 7(2), 7(4)(b) and 7(5) of the SRM Regulation. The circular does not apply to institutions or group companies for which the resolution plan provides for liquidation as part of insolvency proceedings.

The new version focuses on aligning the MaBail-in with the SRB’s Minimum Bail-in Data Template (MBDT), including the Country Annex for Germany, to harmonise the two requirements and minimise transition effort for institutions changing jurisdiction from BaFin to the SRB.

This new circular replaces its predecessor and should be read alongside other BaFin circulars relating to the resolution of institutions.