Glossary term
BAIT
Also: German Banking Supervisory Requirements for IT
BaFin circular that concretises IT requirements for credit institutions. Specifies MaRisk AT 7.2 for IT strategy, information security, user permissions, project management, application development, and IT outsourcing.
BAIT applies to all credit institutions under the KWG. Supplementary interpretation material to MaRisk, de facto mandatory. Current version: BAIT 2021 with amendments.
Contents: IT strategy and governance, information risk management, information security management, user permissions (incl. joiner-mover-leaver), IT projects and application development, IT operations, outsourcing, critical infrastructures.
In practice
Relationship to DORA: DORA supersedes BAIT in many points but retains a BAIT reference. BaFin examiners work in a transition phase in 2025/2026. Banks must master both DORA and BAIT logic in parallel.
Related terms
VAIT
BaFin circular for insurance undertakings. Counterpart to BAIT in banking, derived from MaGo. Regulates IT strategy, information security, user permissions, IT projects and outsourcing.
DORA
EU regulation on digital operational resilience in the financial sector. Directly applicable since 17 January 2025. Five pillars: ICT risk management, incident management, resilience testing including TLPT, third-party governance, information sharing.
BCM
Discipline for maintaining critical business processes during disruptions. Standards: ISO 22301, BSI Standard 200-4. Mandatory under BAIT/VAIT and DORA Art. 11 in the financial sector.
BSI C5
Cloud audit catalogue of the German BSI that defines minimum security baseline and transparency duties. Evidenced via an ISAE 3000 C5 attestation. De facto standard for cloud procurement in the German market.
AI Act Conformity Assessment
Procedure to demonstrate that a high-risk AI system complies with the EU AI Act before being placed on the market or put into service. Mandatory for all Annex III high-risk systems from 2 December 2027 (postponed from the original 2 August 2026 by the Digital Omnibus, Regulation (EU) 2026/1744).
AI Act Risk Categories
Four-tier classification under the EU AI Act: prohibited (Art. 5), high-risk (Annex I/III), limited risk (Art. 50 transparency), minimal risk. Classification is the first duty; it must be documented and defensible.
Audit-ready decision
A decision whose record is structured, evidence-backed and stakeholder-signed to a level that a third-party auditor, a supervisor or a board reviewer can reconstruct the reasoning without interviewing the original team.
CASB
Security layer between users and SaaS providing visibility (shadow IT discovery), data protection (DLP), compliance, and threat protection across SaaS apps. Four functions per Gartner: visibility, compliance, data security, threat protection.
