BaFin Issues Circular 12/2026 (WA) on Licensing Procedure for AIF Management Companies Under Section

Key Takeaways

• On September 15, 2026, BaFin published Circular 12/2026 (WA), which addresses the licensing procedure for alternative investment fund (AIF) management companies under Section 22 of the German Capital Investment Code (KAGB).
• Only the title and metadata were available, and the PDF was not accessible, so the specific requirements are unconfirmed.
• Compliance teams at current and prospective German AIF managers should obtain the full text promptly to assess its effect on authorization applications and ongoing licensing obligations.

Deep Dive

On September 15, 2026, BaFin published Circular 12/2026 (WA), which addresses the licensing procedure for alternative investment fund (AIF) management companies under Section 22 of the German Capital Investment Code (KAGB). Only the title and metadata were available, and the PDF was not accessible, so the specific requirements are unconfirmed. Compliance teams at current and prospective German AIF managers should obtain the full text promptly to assess its effect on authorization applications and ongoing licensing obligations.

Because the substance is unavailable, the following cannot be confirmed: new or amended documentation requirements, changes to review procedures or timelines, updated expectations on fit-and-proper assessments, governance, risk management, or capital adequacy, and any transition period or effective date. The circular may consolidate or replace earlier BaFin guidance on the same topic. Teams should verify whether it supersedes earlier circulars or application templates.

Recommended actions: (1) Retrieve the full PDF from BaFin's website, using an accessible version or contacting BaFin if the document remains inaccessible. (2) Perform a gap analysis against current application files, policies, and licensing procedures. (3) For pending or planned applications, confirm with legal counsel and BaFin contacts whether the new procedures apply. (4) Update internal licensing checklists, governance documentation, and regulatory change logs. (5) Brief senior management, the management board, and relevant functions such as risk, legal, and compliance.

Risk implications: The main exposure is the possibility of delay or rejection of license applications, or of a license that does not comply with supervisory expectations, if the circular's requirements are overlooked. For existing licensed entities, the circular may matter for license extensions or changes to business scope. Until the text is reviewed, the impact is best treated as moderate and uncertain, and any deadlines or obligations should be identified quickly.

Source: Federal Financial Supervisory Authority