CRD Risk Management
The CRD Directive establishes comprehensive risk management requirements for financial institutions that go well beyond traditional risk control. As a leading consulting firm, we develop tailored RegTech solutions for intelligent risk orchestration, automated ICAAP processes and predictive stress testing frameworks with full IP protection and strategic risk excellence.
- ✓Optimized ICAAP processes with automated capital planning
- ✓Intelligent stress testing frameworks for predictive risk analysis
- ✓Risk governance and appetite management based on machine learning
- ✓Automated SREP preparation with technology-supported documentation
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CRD Risk Management: Governance Framework, Capital Adequacy and Integrated Bank Steering
Why ADVISORI for CRD Risk Management
- Over 50 completed projects in integrated bank management and supervisory risk management since 2010
- Experience with BaFin, Bundesbank and ECB examinations — proven governance evidence and SREP documentation
- Interdisciplinary team of risk managers, regulatory specialists and process consultants
- End-to-end support from gap analysis through implementation to supervisory sign-off
CRD VI & MaRisk 2026: New Requirements
The CRD VI transposition (BRUBEG) and the planned MaRisk revision 2026 raise governance standards for risk management — particularly in ESG risk integration, institution classification and transition planning. Early gap analysis secures compliance.
ADVISORI in Numbers
11+
Years of Experience
120+
Employees
520+
Projects
We follow a structured approach that links regulatory requirements (CRD, MaRisk, EBA guidelines) with the individual risk profile and business strategy of your institution. Every engagement begins with a gap analysis and culminates in an actionable implementation roadmap.
Our Approach:
Gap analysis: benchmarking your existing risk management framework against CRD Art. 74–96, MaRisk AT 4.1 and relevant EBA guidelines
Risk inventory and materiality assessment of all risk types as the foundation for risk strategy and ICAAP
Design and documentation of the risk bearing capacity concept (normative and economic perspective)
Implementation of the three lines of defence model with clear role assignments (CRO, risk controlling, internal audit)
Support during supervisory examinations and SREP preparation with focus on governance evidence
"The intelligent implementation of CRD Risk Management requirements is the key to supervisory excellence and strategic risk superiority in EU banking. Our solutions enable institutions not only to achieve regulatory compliance, but also to develop operational excellence in risk control and capital optimization. By combining deep risk management expertise with advanced technologies, we create lasting competitive advantages while protecting sensitive risk data."

Melanie Düring
Head of Risk Management
Our Services
We offer you tailored solutions for your digital transformation
Risk Management Governance under CRD and MaRisk
Establishing and enhancing the risk management organisation under CRD Art. 74–76 and MaRisk AT 4.1 — from board responsibility through the CRO function to the risk controlling unit.
- Organisational structure: responsibilities, reporting lines and escalation paths in risk management
- CRO function: requirements for independence, qualifications and access to the management body
- Risk controlling function: set-up, staffing and MaRisk-compliant functional separation
- Risk committee: establishment, composition and reporting obligations under KWG § 25d
ICAAP and Risk Bearing Capacity
Designing and enhancing the Internal Capital Adequacy Assessment Process — normative and economic perspective per BaFin/Bundesbank guidance and EBA SREP guidelines.
- Normative perspective: capital planning over the planning horizon with regulatory ratios
- Economic perspective: risk coverage potential, risk measurement and internal capital allocation
- Risk inventory: identification, assessment and documentation of all material risk types
- Capital planning process: linking business strategy, risk strategy and capital requirements
Risk Appetite Framework and Risk Strategy
Developing and operationalising a risk appetite framework (RAF) as the link between business strategy and operational risk management — including limit systems and escalation mechanisms.
- Risk appetite statement: qualitative and quantitative definition of risk tolerance at institution level
- Limit system: deriving risk limits per risk type and business line from the risk appetite
- Monitoring and escalation: early warning indicators, thresholds and defined escalation paths
- Risk strategy: alignment with business strategy and annual review process
Three Lines of Defence and Internal Control
Implementing the three lines of defence model as the governance foundation — with clear delineation between operational risk management, independent oversight and internal audit.
- First line of defence: risk ownership in business lines and operational controls
- Second line of defence: independent risk controlling and compliance function
- Third line of defence: internal audit with risk-based audit plan
- Documentation: functional separations, reporting lines and evidence for supervisory examinations
Integrated Bank Management and Risk Integration
Connecting individual risk management processes into an integrated bank management framework — from risk inventory through capital allocation to risk-based performance management.
- Risk aggregation: consolidating all risk types considering correlations and diversification effects
- Capital allocation: risk-adjusted distribution of economic capital across business lines
- Risk-based steering: RORAC/RAROC metrics for strategic decision-making
- Risk reporting: building MaRisk-compliant risk reporting to management body and supervisory board
CRD VI / MaRisk 2026: Regulatory Adjustments
Supporting the implementation of current regulatory changes — CRD VI transposition (BRUBEG), MaRisk revision 2026, ESG risk integration and new institution classification.
- CRD VI gap analysis: identifying action items from BRUBEG and new KWG requirements
- ESG risk integration: embedding climate and sustainability risks in the risk inventory and ICAAP
- Transition planning: preparing the supervisory transition plan per CRD VI / EBA guidelines
- Proportionality assessment: evaluating requirements under new institution classification (MaRisk revision)
Our Competencies
Choose the area that fits your requirements
The Advanced IRB Approach (A-IRB) allows institutions to estimate all risk parameters internally — probability of default (PD), loss given default (LGD), exposure at default (EAD) and credit conversion factors (CCF) — using proprietary models. ADVISORI guides you from model development through supervisory approval to ongoing validation — for risk-sensitive capital management under CRR III.
The CRD combined buffer requirement defines how capital conservation buffer, countercyclical buffer, systemic risk buffer and G-SII/O-SII buffers interact under a single framework. ADVISORI advises financial institutions on buffer stacking rules, capital distribution restrictions, MDA calculation and capital conservation planning — ensuring full compliance with the CRD buffer framework.
Capital adequacy requirements under the CRD comprise the overall capital requirement from Pillar 1 minimum, SREP capital add-on (P2R), combined buffer requirement, and Pillar 2 Guidance (P2G). We support banks in supervisory capital quantification, preparation for CRD VI changes, and integration of ESG risks into the capital adequacy assessment.
The CRD Capital Conservation Buffer under Art. 129 CRD V/VI requires EU credit institutions to hold 2.5% Common Equity Tier 1 (CET1) capital above minimum requirements. When breached, the MDA (Maximum Distributable Amount) calculation triggers automatic distribution restrictions on dividends, bonuses, and AT1 coupons. ADVISORI advises on strategic buffer management, CRD VI implementation, and regulatory capital planning across the EU framework.
The countercyclical capital buffer under Art. 130 CRD (Directive 2013/36/EU) requires credit institutions to maintain an institution-specific buffer as the weighted average of applicable national CCyB rates. The calculation under Art. 140 CRD considers the geographic distribution of credit risk exposures. ADVISORI supports you with CRD-compliant buffer calculation, ESRB reciprocity requirements and implementation of CRD VI changes effective January 2026.
End-to-end consulting for implementing the CRD credit risk framework: from the reformed Standardised Approach (SA-CR) and Output Floor calculations to ECAI due diligence requirements. We support your institution in the compliant implementation of CRR III capital requirements and the strategic optimisation of your risk weighting.
The Capital Requirements Directive (CRD) is the core EU directive governing banking supervision, governance, and authorization of credit institutions. From CRD IV through CRD V to the current CRD VI, it defines the supervisory framework that each EU member state must transpose into national law. ADVISORI has been supporting banks and financial institutions with CRD implementation for over 14 years.
Fit and Proper ensures that members of the management body, supervisory board and key function holders meet regulatory requirements for knowledge, experience, integrity and time commitment. With CRD VI expanding the scope to key function holders and the revised EBA/ESMA joint guidelines introducing AML/CFT competence requirements, banks face growing complexity in their suitability assessment processes. ADVISORI supports you with systematic implementation of all Fit and Proper requirements across the EU framework.
The CRD defines binding requirements for the internal governance of credit institutions – from the three lines of defence model through internal control systems to the independent compliance function. With the new EBA guidelines (EBA/CP/2025/20) and CRD VI, requirements for risk management governance, control functions, and organizational structures are tightening significantly. ADVISORI supports you with gap analysis, implementation, and ongoing monitoring of your internal governance framework aligned with EBA standards.
Directive 2013/36/EU (CRD IV) together with the CRR forms the regulatory foundation of EU banking supervision under Basel III. We support financial institutions in the full implementation of governance, SREP and Pillar 2 requirements — from gap analysis to supervisory-compliant implementation.
The use of internal models to calculate risk-weighted assets requires supervisory approval from the ECB and national authorities. We guide your institution through the entire IRB approval process — from model development and validation per the revised ECB guide 2025 to successful regulatory approval. With our expertise, you navigate the tightened CRD VI requirements, the output floor and internal model restrictions with confidence.
The CRD establishes binding liquidity requirements for EU banks — from the Liquidity Coverage Ratio (LCR) and Net Stable Funding Ratio (NSFR) to internal liquidity risk management. ADVISORI supports financial institutions with regulatory implementation, liquidity governance and building robust stress testing frameworks.
The Liquidity Coverage Ratio (LCR) requires credit institutions to hold sufficient high-quality liquid assets (HQLA) to cover net cash outflows over a 30-day stress scenario. The minimum ratio is 100%. Under the EU implementation of Basel III through CRR/CRD, Delegated Regulation 2015/61 governs HQLA categories, inflow/outflow rates, and reporting requirements. ADVISORI supports banks with compliant LCR calculation, HQLA optimization, and supervisory reporting.
Professional consulting for the implementation and optimization of market risk management systems in accordance with the requirements of the Capital Requirements Directive (CRD). We support you in meeting regulatory requirements and making strategic use of market risk information.
CRD Net Stable Funding Ratio defines a structural liquidity metric to promote stable funding structures and reduce liquidity transformation risks in EU financial institutions. As a leading consulting firm, we develop tailored RegTech solutions for intelligent Available Stable Funding optimization, automated Required Stable Funding calculation, and predictive NSFR management with full IP protection.
Identify, assess, and manage operational risks under CRR Art. 312§324 and CRD systematically. We guide your institution through selecting the right measurement approach — from the basic indicator approach and standardised approach to the SMA transition under Basel III — and implement OpRisk frameworks with loss databases, RCSA processes, and KRI systems.
CRD outsourcing establishes the strategic foundation for modern banking outsourcing management and defines comprehensive third-party risk management systems, service provider monitoring, and outsourcing procedures for financial institutions. As a leading consulting firm, we develop tailored RegTech solutions for intelligent outsourcing orchestration, automated outsourcing management systems, and predictive third-party excellence with full IP protection.
CRD Passporting establishes the strategic foundation for modern EU Banking Passport operations and defines comprehensive cross-border services, branch systems and international regulatory coordination for financial institutions. As a leading consulting firm, we develop tailored RegTech solutions for intelligent passporting orchestration, automated cross-border compliance systems and predictive EU banking excellence with full IP protection.
Pillar 1 of the Capital Requirements Regulation (CRR) defines the minimum capital requirements for EU credit institutions: 4.5% CET1, 6% Tier 1 capital, and 8% total capital ratio relative to risk-weighted assets (RWA). ADVISORI supports banks with compliant RWA calculation, choosing between the credit risk standardised approach and the IRB approach, and ongoing capital planning.
CRD Pillar 2 defines supervisory review procedures and internal capital adequacy assessments for EU financial institutions. As a leading consulting firm, we develop tailored RegTech solutions for ICAAP automation, SREP optimisation and intelligent supervisory dialogue with full IP protection.
Frequently Asked Questions about CRD Risk Management
What does the risk management framework under CRD Art. 74–96 encompass?
Articles 74–96 of the Capital Requirements Directive (CRD) require credit institutions to maintain a comprehensive risk management framework. The core components are:
In Germany, MaRisk (AT 4.1) specifies these requirements and adds obligations around risk inventory, risk bearing capacity and risk reporting.
How do the normative and economic perspectives of risk bearing capacity differ?
Since the Bundesbank/BaFin guidance of 2018, all German credit institutions must assess their risk bearing capacity from two perspectives:
Both perspectives are brought together in the ICAAP and must be consistent with the risk strategy and capital planning process. BaFin reviews risk bearing capacity regularly as part of the SREP.
What role does the CRO play in the risk management framework?
The Chief Risk Officer (CRO) plays a key role in supervisory risk management. CRD and MaRisk set the following requirements:
Under MaRisk (AT 4.4.1), in significant institutions the risk controlling function must be led by a member of the management board who is not simultaneously responsible for market or trading areas.
How does the three lines of defence model work in banking practice?
The three lines of defence model is the central governance concept for risk management in credit institutions. It structures responsibilities across three levels:
The functional and organisational separation of the three lines is critical. MaRisk (AT 4.4) requires that risk controlling and compliance functions are set up independently from market areas up to the management board level.
What changes with CRD VI and the MaRisk revision 2026 for risk management?
The CRD VI transposition through BRUBEG and the planned MaRisk revision 2026 bring significant changes:
ADVISORI supports institutions with gap analysis, action planning and implementation of these new requirements.
How is integrated bank management linked to risk management?
Integrated bank management connects risk management with profit-oriented bank steering into one coherent management approach:
MaRisk requires these processes to be documented in an integrated bank management concept with the risk bearing capacity process as the central element.
What requirements does MaRisk set for the risk inventory?
The risk inventory is the starting point of the entire risk management process and is governed by MaRisk AT 2.2:
The risk inventory forms the basis for the ICAAP, risk appetite framework and the entire limit system.
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