Insurance & Pensions regulatory updates from Germany.
Financing, lending, compliance and internal communication: financial entities are using artificial intelligence (AI) in an increasing number of areas. These entities must observe the provisions of the new AI Act. How prepared are they for this? And what is Bafin’s new role? Bafin expert Jens Obermöller addresses these questions in an interview.
In future, Bafin will monitor the use of AI systems by companies in the financial sector. Its key objectives will be to promote innovation and to protect fundamental rights.
The Federal Financial Supervisory Authority (BaFin) has issued its “Guidance on ICT Risks in the Use of Artificial Intelligence at Financial Entities”. The guidance will help entities manage ICT risks in accordance with the requirements under DORA.
BaFin's "Guidance on ICT Risks in the Use of Artificial Intelligence at Financial Entities," published December 18, 2025, provides non-mandatory advice to help financial entities manage ICT risks from AI under DORA across the AI lifecycle. It matters because it integrates AI explicitly into existing ICT risk frameworks, emphasizing security, resilience, and third-party risks for supervised institutions, aligning with RTS on ICT risk management (EU 2024/1774) and subcontracting (EU 2025/532). This clarifies supervisory expectations amid growing AI adoption in finance, reducing ambiguity in DORA compliance.
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