On 11 November 2026, the Federal Financial Supervisory Authority (BaFin) imposed administrative fines amounting to €8 million on Deutsche Bank Aktiengesellschaft.

The company had contravened the German Securities Trading Act (WpHG). There were shortcomings in the migration of Postbank customers to the parent company’s shared IT platform (Project Unity).

Specifically, in 2023, Deutsche Bank Aktiengesellschaft failed to put in place appropriate organisational arrangements to deal promptly with the increased volume of customer complaints arising from the migration of customer data. Furthermore, the company failed to execute orders for the transfer of securities accounts without delay.

The fine of €8 million consists of the following: €5.5 million for processing customer complaints too slowly and €2.5 million for delays in transferring securities accounts.

Investment services enterprises must make and implement appropriate arrangements through adequate organisation in order to ensure the proper provision of investment services and to minimise delays in measures to identify and remedy any disruptions to business operations should they arise. Under these obligations, investment services enterprises are also required to put in place appropriate arrangements to deal with customer complaints without delay. This is set out in section 80 (1) sentence 2 no. 1 of the WpHG. The provision stipulates general requirements for comprehensive compliance organisation in investment services enterprises.

Investment services enterprises must also put in place appropriate arrangements to ensure that customer orders are executed without delay. This is set out in section 69 (1) of the WpHG. Orders for the transfer of securities accounts are also considered customer orders and must therefore be executed without delay and within three weeks at the latest.

Bafin may impose a fine if a company violates the organisational obligations set out in the WpHG. The maximum amount for each fine is €5 million or up to 10% of total revenue.