BaFin Revises Rules Following the End of the Million-Loan Reporting System
On 19 October 2026, the Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin, German Federal Financial Supervisory Authority) published a draft omnibus regulation for consultation. This follows the discontinuation of the million-loan reporting system under § 14 Kreditwesengesetz (KWG, German Banking Act). The supervisory provisions linked to this reporting procedure will also be amended once the procedure is discontinued.
The Standortfördergesetz (German Act to Promote Germany as a Business Location) of 4 February 2026 was promulgated in the Bundesgesetzblatt (BGBl., German Federal Law Gazette) on 9 February 2026 (BGBl. 2026 I No. 33). Under the Act, the million-loan reporting system will be discontinued as of 30 December 2026. The final million-loan reports must be submitted for the reporting date of 30 September 2026.
Large Exposure Regulation to Replace Existing GroMiKV
The current Großkredit- und Millionenkreditverordnung (GroMiKV, German Large Exposure and Million-Loan Regulation) contains provisions governing both large exposures and the million-loan reporting system. Once the latter has been discontinued, the GroMiKV is to be replaced by a Großkreditverordnung (GroKV, German Large Exposure Regulation). The new regulation will contain the requirements that continue to apply to large exposures.
Further Regulations to Be Streamlined
In addition to recasting the rules on large exposures, the draft provides for amendments to other BaFin regulations. References to the KWG provisions governing the million-loan reporting system, which will cease to apply, are to be removed or amended.
The full title of the regulatory instrument is “Verordnung zur Anpassung verordnungsrechtlicher Vorschriften der Bundesanstalt für Finanzdienstleistungsaufsicht nach Einstellung des Millionenkreditmeldewesens nach dem Kreditwesengesetz” (“Regulation Amending Regulatory Provisions of the German Federal Financial Supervisory Authority Following the Discontinuation of the Million-Loan Reporting System under the German Banking Act”).
The necessary amendments will be implemented by means of two separate omnibus amending regulations:
- One regulation issued by the Bundesministerium der Finanzen (German Federal Ministry of Finance) concerns banking supervisory provisions falling within its remit.
- A further BaFin regulation covers the provisions issued by BaFin.
The deadline for submitting comments on the draft being considered in parallel by the Bundesministerium der Finanzen expired on 30 September 2026.
Reduced Reporting Burden for Credit Institutions
The initiative to discontinue the million-loan reporting system originated with BaFin and the Deutsche Bundesbank (German Federal Bank). It is intended to reduce the administrative burden on credit institutions and avoid duplicate reporting obligations. According to BaFin, around 3,200 companies are still required to report loans of one million euros or more on a quarterly basis.
BaFin President Mark Branson stated that the reporting system was being discontinued because the financial supervisory authority now obtains the necessary information from other sources. At BaFin’s proportionality conference in mid-September 2026, Nikolas Speer, BaFin’s Executive Director of Banking Supervision, referred to the future use of AnaCredit instead of duplicate reports.
AnaCredit as a European Credit Data Register
AnaCredit is a credit data register maintained by the Europäische Zentralbank (European Central Bank). Credit institutions in Germany transmit the relevant data to the Deutsche Bundesbank. This existing European data collection system is therefore a key reason for discontinuing the previous million-loan reporting system.
The discontinuation concerns the reporting procedure for million loans. By contrast, the supervisory requirements governing large exposures will remain in place and are to be regulated by the new GroKV in future.
BaFin’s Written Consultation Open Until November 2026
BaFin is conducting Consultation 10/2026 exclusively in writing. Comments on the draft regulation may be submitted by email until 2 November 2026. The reference number BA 52-FR 2434/00007#00001 must be quoted.
Anyone who does not consent to the publication of their comments or their disclosure to third parties must expressly state this in their email to BaFin. The consultation provides an opportunity to participate in the drafting process; it does not constitute a final version of the omnibus regulation.
Significance of the New Rules for Banking Supervision Law
The end of the million-loan reporting system will eliminate a separate reporting procedure, while the provisions governing large exposures will remain in force. BaFin’s planned omnibus regulation is intended to align the secondary legislation with this distinction and remove references to the repealed reporting provisions.
Companies, credit institutions and investors may face various legal issues in connection with the remaining large exposure provisions and the transition to the new supervisory regulatory framework. MTR Legal Rechtsanwälte advises clients on matters relating to banking law. Further information is available under Legal Advice on Banking Law.
