The amendment of BAIT for 2021 means new require­ments for credit insti­tu­tions. In contrast, BaFin faces the challenge of imple­menting the Guide­lines on security measures for opera­tional and security risks under the PSD2 and the Guide­lines on ICT and security risk management of the EBA in Germany. This is to be completed by 31 December 2020 with an amendment to the BAIT (banking super­visory require­ments for IT). First drafts have already been discussed and commented on in the insti­tutes and associations.

BAIT 2021 focuses on IT security

With a separate and new chapter, opera­tional IT security is moving further into focus. The require­ments formu­lated there can only be fulfilled with a Security Infor­mation and Event Management System (SIEM). This also includes the estab­lishment and operation of a Security Opera­tions Centre (SOC). Regular opera­tional checks are required. These include:

• internal deviation analyses
• Vulner­a­bility scans
• Penetration tests
• the simulation of attacks (“Red Teaming”)

The new require­ments of BAIT 2021 lead to the estab­lishment of a profes­sional cyber security infra­structure. This means extensive and independent internal infor­mation security structures.

The management assumes overall responsibility

It is noticeable that the draft already refers not only to the respon­si­bility of the management. The management is even required to explicitly acknowledge the overall respon­si­bility for infor­mation security. This also includes regular infor­mation about their concerns and the decision to deal with security risks appropriately.

Require­ments for IT emergency management are consolidated

We expect further changes in the area of IT emergency management. The require­ments from BAIT will be consol­i­dated with those from section AT7.3 of MaRisk. This creates uniform national require­ments. In addition, we expect to tighten and specify the require­ments with regard to emergency planning and prevention, BCM, disaster recovery and backup strategies. In our view, outsourcing to service providers will also be covered by the revised version.

Financial insti­tu­tions face major challenges

According to the assessment of the SRC experts for bank compliance, the expected changes will pose great challenges for the affected insti­tu­tions. This concerns especially the required know-how and the limited resources on the labour market.