WpI MaRisk 2025 & ILAAP – What Medium-Sized Securities Institutions Must Implement Now
1. Why the Topic is Important Now
With the publication of the WpI MaRisk 2025 and the SREP Guidelines of the EBA/ESMA (EBA/GL/2022/09, ESMA35-42-1470), liquidity management is becoming more of a focus for supervision.
The Bundesbank is currently sending questionnaires on liquidity management to all securities institutions – with a submission deadline of August 12, 2025.
The goal: Uniform procedures for the assessment of liquidity risks and to ensure liquidity at all times —scaled according to the size, type, and risk profile of your institution.
The principle of proportionality plays a central role:
- Small securities institutions do not require a formal ILAAP.
- Medium-sized securities institutions must establish a full Internal Liquidity Adequacy Assessment Process (ILAAP) .
| Topic | Small WpI – Core Obligation | Medium WpI – Core Obligation | Proof / Reference |
|---|---|---|---|
| ILAAP | No formal ILAAP required | Formal, documented ILAAP mandatory | ILAAP Handbook, Governance Documentation; BTR 3, AT 4; §39(1) WpIG, §45(1) No.4 WpIG, §47(2) WpIG; SREP (EBA/GL/2022/09) |
| Liquidity Planning | Simple scenarios; overviews if needed | Multi-stage planning short-/medium-/long-term | Planning model, assumptions log; management approvals; BTR 3 |
| Stress Tests | At least 1 adverse scenario/year | Regularly (at least quarterly) & event-driven | Stress test reports, action plans; SREP questionnaire |
| Liquidity Buffer | Adequate, risk-oriented | Defined buffer strategy and monitoring | Buffer policy, limits, KPIs (e.g. survival period) |
| Contingency Plans | Not necessarily in writing | Documented and regularly tested | Emergency/Funding plan, test protocols; BTR 3 |
| Reporting | Lean, qualitative assessment | Comprehensive, quantitative, SREP-compatible | Management reports, board memos; SREP guidelines |
| Documentation & Governance | Clear, risk-oriented | Complete, audit-proof, metric-based | Document control, audit trail; AT 4 |
| Bundesbank Questionnaire | Observe deadline; fill out according to lived processes | Observe deadline; fill out in detail & consistently | NExt Portal upload by 08/12/2025; keep file name; consistent scenarios/processes |
| Common Mistakes | No documented adverse scenario; unclear responsibilities | ILAAP only „on paper“; missing event-driven stress tests; emergency plan without testing | Record corrective actions & responsibilities in the action plan |
| Roadmap | Implement proportionally, document processes succinctly | Establish ILAAP, regularize tests/reporting | Check classification; close gaps; ensure audit capability |
2. What is the ILAAP – and Why Does it Only Affect Medium-Sized WpI?
The ILAAP is the internal process for assessing the adequacy of liquidity.
It includes strategies, procedures, and methods to ensure that your institution is liquid at all times —even in stress situations.
The WpI MaRisk do not explicitly mention the term „ILAAP.“ Nevertheless, they include in BTR 3 (Liquidity Risk) and AT 4 (Risk Management) requirements that correspond to the ILAAP objectives.
The legal basis:
- § 39 para. 1 sentence 3 WpIG: Your funds must be invested in such a way that liquidity is always assured .
- § 45 para. 1 sentence 2 no. 4 WpIG: Liquidity risks must be managed appropriately .
- § 47 para. 2 WpIG: Supervisory assessment of liquidity under SREP.
Concretely, this means:
- Medium-Sized WpI: formal, documented ILAAP is mandatory.
- Small WpI: simplified liquidity management is sufficient—as long as it is supervisory-proof .
ILAAP according to WpI MaRisk 2025: Requirements for Medium-Sized WpI
| Area | What Supervision Asks (Questionnaire) | Expectation for Medium WpI (ILAAP) |
|---|---|---|
| Business Model | OTC activities? Clearing through clearing members? Custody accounts for clients? | Description of markets/trading venues, clearing setup, and custody accounts including liquidity implications in the ILAAP manual. |
| Liquidity Risk Inventory | Which liquidity risks are considered? (e.g. funding risk, market risk, refinancing risk, intraday risk) – table with risk type, amount, limit, calculation method. | Complete risk inventory with limit framework, methods (formulas/parameters), and regular limit monitoring/reporting. |
| Currency Liquidity | Relevance of FX liquidity risks; which currencies are material? | Materiality criteria, currency limits, stress consideration per major currency, consolidation into the overall picture. |
| Intraday Risk (Consideration) | Is intraday liquidity risk (deviations in daily liquidity) taken into account? | Formal anchoring in ILAAP, daily monitoring and thresholds/alarms. |
| Intraday KPI | Is there an internal KPI? How often is it calculated? | Defined KPI (e.g. intraday gap/net cash at risk) with at least daily calculation and management review. |
| Liquidity Resources | Quality/quantity of liquid assets; monetizability (time to liquidity). | Eligibility criteria, haircuts, locations/commitments; clear processes for rapid liquidation. |
| Stress Phases – Monetization | How much can be monetized in stress phases over the timeframes: 1 day, 2 days, 1 week, > 1 week? | Quantified stress test results per bucket (including assumptions/haircuts), action plans for shortfall. |
| Intraday Under Stress | Are intraday availabilities also considered under adverse/stress conditions? | Scenarios (adverse/stress) with intraday forecasts; tests against outflow peaks and cut-off risks. |
| Liquidity Planning | Is there planning in place? How far does the horizon reach? | Rolling planning short/medium/long-term (e.g. daily/weekly/monthly) with documented assumptions. |
| Organization | Which organizational units are responsible for liquidity planning? | Clarified responsibilities (1st/2nd line), escalation paths, and management involvement. |
| Forecast – Risks | Forecast of liquidity risks (t0/t1 etc.) by risk type. | Forecast tables with sums/trends per risk type; alignment with limits and stress results. |
| Forecast – Resources | Forecast of liquidity resources/components (t0/t1 etc.). | Resource forecast (components, amounts, monetization capability) including gap analysis. |
3. Differences Between Small and Medium-Sized Securities Institutions
| Topic | Small WpI | Medium WpI |
|---|---|---|
| ILAAP | Not required | Mandatory |
| Liquidity Planning | Simple scenarios, liquidity overviews if needed | Complete planning short, medium, and long-term |
| Stress Tests | Adverse scenario once a year | Regular & event-driven stress tests |
| Contingency Plans | Not necessarily in writing | Documented & tested |
| Reporting | Lean, qualitative assessment | Comprehensive, quantitative, SREP-compatible |
| Documentation | Clear, risk-oriented | Complete, audit-proof, metric-based |
4. Requirements for Small Securities Institutions
Even without ILAAP, you must meet supervisory minimum requirements :
- Development of conservative scenarios for liquidity management
- Verification of liquidity even in stress situations (BTR 3)
- If necessary: Create liquidity overviews
- Documentation in a streamlined but clear form
Best Practice for Small WpI:
- Annual risk analysis with adverse scenarios
- Early warning indicators such as deposit withdrawal or credit line failure
- Clearly define responsibilities
- Clear liquidity matrix
5. Requirements for Medium-Sized Securities Institutions
For you as a medium-sized WpI, higher requirements apply:
- Formal ILAAP with clearly defined processes
- Detailed liquidity planning on various time horizons
- Regular stress tests (at least quarterly)
- Analysis of refinancing sources
- Strategy for liquidity buffers
- Contingency plans with test runs
- Complete documentation & reporting for supervision
Best Practice for Medium WpI:
- Create an ILAAP handbook
- Actively involve management
- Regularly update stress tests
- Continuously monitor metrics (Liquidity Coverage, Survival Period)
6. The Role of SREP Guidelines
The SREP guidelines of the EBA/ESMA define the framework for how supervision assesses your liquidity management.
Examination focuses:
- Adequacy of liquidity resources
- Effectiveness of control processes
- Ability to remain liquid even under stress
For medium-sized WpI, the ILAAP is a central exam object.
For small WpI: Even without ILAAP, supervision can require detail depth if your risk profile requires it.
7. The Current Bundesbank Questionnaire
The Bundesbank is implementing the new SREP requirements and has sent all WpI a personalized Excel questionnaire .
Procedure:
- Download the template in the NExt portal („Supervisory Surveys“)
- Complete in full according to currently lived processes
- Upload to the NExt portal (not via the dialogue function)
- Keep the file name unchanged, adjust the version number only when corrections are made
Contents of the questionnaire:
- Liquidity risk processes
- Scenario considerations / stress tests
- Liquidity buffers
- Contingency measures
Important: Missing or incomplete answers can lead to supervisory measures .
8. Implementation Steps for Small WpI
- Establish liquidity strategy
- Develop adverse scenario (e.g. deposit withdrawal, credit line failure)
- Implement simple early warning indicators
- Record documentation in the liquidity concept
9. Implementation Steps for Medium WpI
- Create ILAAP Handbook
- Introduce multi-stage liquidity planning
- Conduct stress tests regularly and event-driven
- Develop and test contingency plans
- Establish regular management reporting
10. Common Mistakes and How to Avoid Them
- Small WpI:
- No documented adverse scenario
- Missing responsibilities
- Medium WpI:
- ILAAP only formal, not lived processes
- No event-driven stress tests
- Contingency plans without testing
11. Conclusion – Your Roadmap
- Check now whether you are a small or medium-sized WpI
- Implement the requirements of the WpI MaRisk 2025 proportionately
- Document processes to be supervisory-proof
- Proactively develop liquidity management further
📄 Tip: You can request our free whitepaper on WpI MaRisk 2025 directly here.
📚 WpI MaRisk 2025 – Resources & Practical Guides
🔹 AT Modules – General Part
- AT 2.2 Materiality Test – Your Practical Guide
- AT 4.3.3 Risk Management & Stress Tests
- AT 4.3.3 Stress Tests for Small Institutions
- AT 7.3 Emergency Management – Explained Compactly
🔹 BTO Modules – Organization & Transaction
🔹 BTR Modules – Risk Management
- BTR – General Requirements
- BTR 1 – Risks from Ongoing Activity
- BTR 2 – Other Risks of Ongoing Activity
- BTR 3 – Effectively Managing Liquidity Risks
- BTR 4 – Risk of Disordered Settlement
- Risk Management – Requirements in BT 2, BTR 3 & BTR 4
🔹 Special Topics
- Risk Management according to WpI MaRisk – Practical Implementation
- ILAAP 2025 – Requirements for Small and Medium Institutions