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Publications·01/05/2026·1 Stunde

The New Compliance Function: Implementation of CRD VI and the EBA Guidelines on Internal Governance – Part 1 (german only)

Published in Compliance Berater (CB), Issue 06/2026. This article analyses the supranational upgrade of the Regulatory Compliance function through CRD VI and the revised EBA Guidelines on Internal Governance. It examines how the new requirements reshape the compliance mandate, governance architecture, and operational scope for financial institutions across the EU — and what this means for teams preparing for the 2026 transposition deadline. Article is in German only.

The New Compliance Function: Implementation of CRD VI and the EBA Guidelines on Internal Governance – Part 1 (german only)
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European banking regulators are fundamentally revising their requirements for internal governance. In a three-part series of articles in Compliance-Berater, Prof. Dr. Frank Passing, Markus Müller, and Finn Brüggemann analyze how CRD VI (Directive (EU) 2024/1619) and the revised EBA guidelines are repositioning the compliance function.

The first part traces how CRD VI and the revised EBA guidelines strategically elevate the compliance function. With the revision of Article 76 of CRD VI, compliance risk has moved to the forefront of risk strategy as an independent risk driver. Greater independence, special protections for the head of the function, and heightened qualification requirements underscore the role of compliance as a fundamental pillar of internal governance—and usher in the shift from national “MaRisk compliance” to European-style “regulatory compliance.”

Published in Compliance-Berater (CB) 6/2026.

To the article (German only): https://www.juris.de/jportal/nav/news-abstracts/jaktuell-cb-2026-6-006-212.jsp?utm_source=Linkedin.com&utm_medium=social&utm_campaign=AIJP

The New Compliance Function: Implementation of CRD VI and the EBA Guidelines on Internal Governance – Part 1 (german only) — Fairfield & Archer