This page provides AWS financial institution customers with information about the legal and regulatory requirements in Germany that may apply to their use of AWS services. 


  • Yes. Financial institutions in Germany are permitted to use cloud services, provided that they comply with applicable legal and regulatory requirements, such as those described below. 

  • The Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht) (“BaFin”) and the Deutsche Bundesbank (“Bundesbank”) are Germany’s financial supervisory authorities. BaFin supervises banks and other financial service providers, insurance undertakings and pension funds, stock exchanges, asset management companies and investment funds and securities and other investment companies. The Bundesbank undertakes the on-going supervisions of banks and financial service providers. Certain financial service providers (significant institutes) may be regulated by the European Central Bank.

  • Regulated entities in Germany may be subject to a number of different legal and regulatory requirements, when they use cloud services.

    The German Banking Act (Kreditwesengesetz) (“KWG”) applies to licensed banking and financial services institutions. The requirements on risk management set forth in KWG are further specified in two BaFin circulars: the Minimum Requirements for Risk Management (Mindestanforderungen an das Risikomanagement – “MaRisk”) and the Banking Supervisory Requirements for IT (Bankaufsichtliche Anforderungen an die IT – “BAIT”).

    The German Act on Supervision Insurance Undertakings (Versicherungsaufsichtsgesetz) (“VAG”) applies to insurance undertakings. The requirements for risk management are similar to the requirements for banking and financial services institutions and are also further specified in two BaFin circulars: the Minimum Requirements on Business Organisation of Insurance Companies (Mindesantforderungen an die Geschäftsorganisation von Versicherungsunternehmen, "MaGo") and the Insurance Undertaking Requirements for IT (Versicherungsaufsichtliche Anforderungen an die IT – “VAIT”).

    • The MaRisk or the MaGo respectively contains requirements regarding responsibility for risk management, insurance of continuity and quality of outsourced activities, cooperation with regulators and audit rights, data management, data security and confidentiality.

    • The BAIT or the VAIT respectively, in part, further specifies the MaRisk or the MaGo respectively. It sets forth requirements on technical and organizational measures for IT systems, in particular regarding security and contingency plans.

    There are other relevant EU and German laws and regulations in addition to MaRisk and BAIT, or MaGo and VAIT that pertain to regulated entities’ use of cloud services (e.g., KAMARisk, KAIT, ZAIT). AWS encourages its regulated customers to obtain appropriate advice on their compliance with all regulatory and legal requirements that are relevant to their business, including the MaRisk, BAIT, MaGo, or VAIT and other local regulations, guidelines and laws.

    Customers that have questions about the MaRisk and BAIT or MaGo and VAIT and how these may apply to their use of AWS services, or regarding any regulations, guidelines, and laws that might apply in this context, can reach out to their account representative.

  • AWS is committed to offering customers a strong compliance framework and advanced tools and security measures which customers can use to evaluate, meet, and demonstrate compliance with applicable legal and regulatory requirements.

    Regulated entities who are using or planning to use AWS services can take the following steps to better understand their compliance needs:

    1. Consider the purpose of the workload(s) under consideration and the relevant categories of data in order to anticipate which legal and regulatory requirements may apply.

    2. Assess the materiality or criticality of the relevant workload(s) in light of local requirements. For example, see the materiality assessment considerations in Section AT 9.2 of the MaRisk or the risk assessment in accordance with item 247 of the MaGo.

    3. Review the AWS Shared Responsibility Model and map AWS responsibilities and customer responsibilities according to each AWS service that will be used. Customers can also use AWS Artifact to access AWS’s audit reports and conduct their assessment of the control responsibilities.

    4. Customers that have further questions about how AWS services can enable their security and compliance needs, or that would like more information, can contact their account representative.

  • Regulated entities in Germany using AWS services should also consider applicable privacy requirements, including the General Data Protection Regulation (“GDPR”) and the German Federal Data Protection Act. If customers process or are planning to process the personal data of data subjects in the European Economic Area (EEA), which includes the EU, they should visit AWS’s General Data Protection Regulation (GDPR) Center. More information on these requirements is included in the AWS whitepaper, Navigating GDPR Compliance on AWS.


  • General
  • The following resources are available for download through AWS Artifact. Please note that an AWS account will be required to access AWS Artifact.

    AWS User Guide for Digital Operational Resilience Act (DORA)

    This guide provides information regarding the adoption of Amazon Web Services (AWS) cloud for entities regulated by the European Banking Authority (EBA), the European Insurance and Occupational Pensions Authority (EIOPA), and the European Securities and Markets Authority (ESMA), who are subject to the Digital Operational Resilience Act (DORA).

    The following resources are publicly available:


    Navigating GDPR Compliance on AWS

    This document provides information about services and resources that Amazon Web Services (AWS) offers customers to help them align with the requirements of the General Data Protection Regulation (GDPR) that might apply to their activities. These include adherence to IT security standards, the AWS Cloud Computing Compliance Controls Catalog (C5) attestation, adherence to the Cloud Infrastructure Services Providers in Europe (CISPE) Code of Conduct, data access controls, monitoring and logging tools, encryption, and key management.

    Payment Card Industry Data Security Standard (PCI DSS) 3.2.1 on AWS

    This guide provides customers with sufficient information to be able to plan for and document the Payment Card Industry Data Security Standard (PCI DSS) compliance of their AWS workloads. This includes the selection of controls that meet specific PCI DSS 3.2.1 requirements, planning of evidence gathering to meet assessment testing procedures, and explaining their control implementation to their PCI Qualified Security Assessor (QSA).

    Using AWS in the Context of Common Privacy and Data Protection Considerations

    This document provides information to assist customers who want to use AWS to store or process content containing personal data, in the context of common privacy and data protection considerations. It will help customers understand the way AWS services operate, including how customers can address security and encrypt their content. The geographic locations where customers can choose to store content and other relevant considerations. The respective roles the customer and AWS each play in managing and securing content stored on AWS services.

    AWS Compliance Quick Reference Guide

    AWS has many compliance-enabling features that you can use for your regulated workloads in the AWS cloud. These features allow you to achieve a higher level of security at scale. Cloud-based compliance offers a lower cost of entry, easier operations, and improved agility by providing more oversight, security control, and central automation.

    AWS Operational Resilience

    The purpose of this paper is to describe how AWS and our customers in the financial services industry achieve operational resilience using AWS services.

    Data Classification and Secure Cloud Adoption

    This paper provides insight into classification schemes for public and private organizations to leverage when moving data to the cloud. It identifies practices and models currently implemented by global first movers and early adopters, examines how implementation of these schemes can simplify cloud adoption, and recommends practices to harmonize national requirements to internationally recognized standards and frameworks.

    AWS Policy Perspectives: Data Residency

    This paper addresses: The real and perceived security risks expressed by governments when they demand in-country data residency. Commercial, public sector, and economic impact of in-country data residency policies with a focus on government data. Considerations for governments to evaluate before enforcing requirements that can unintentionally limit public sector digital transformation goals leading to increased cybersecurity risk.

    AWS Risk and Compliance

    This document is intended to provide information to assist AWS customers with integrating AWS into their existing control framework supporting their IT environment. This document includes a basic approach to evaluating AWS controls and provides information to assist customers with integrating control environments. This document also addresses AWS-specific information around general cloud computing compliance questions.

    AWS Security Audit Guidelines

    Guidelines for systematically reviewing and monitoring your AWS resources for security best practices.

  • Compliance Programs
  • C5

    ISO 9001

    PCI DSS Level 1


    ISO 27001



    ISO 27017


    ISO 27018

Review requirements

We are continually adapting to evolving regulations. Check often for updates.

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