RACI matrix

RACI is a widely used method for documenting roles. For every activity it names the role that carries out the work, the single role that is accountable for the outcome, the roles whose input is required before a decision, and the roles that are informed afterwards. In a bank it is typically applied to processes, controls, policies and governance decisions, and it complements the organisation chart and the bank’s competence regulations.

Supervisors expect a clear allocation of responsibilities rather than a specific format. MaRisk requires processes, tasks, competences, responsibilities and communication channels to be clearly defined and coordinated, and the written rules to include an overview of the tasks and individual responsibilities of the executive board and the management level directly below it. A RACI matrix is a practical way to make such allocations visible and testable.

Typical mistakes are several accountable parties for one activity, accountability assigned to committees instead of individuals, matrices that are drawn once and not updated after reorganisations, and entries that are not linked to the process steps and controls they describe.

In practice

1. 01
   Assigns exactly one accountable role to each activity, decision or control.
2. 02
   Uses roles rather than names, with a maintained mapping of roles to people and deputies.
3. 03
   Links RACI entries to process steps, controls and policies so that gaps and conflicts become visible.
4. 04
   Checks the matrix for segregation of duties conflicts, for example where one role both executes and approves.
5. 05
   Reviews the matrix after every reorganisation and at least once a year.

Sources

• BaFin Circular 06/2026 (BA), Mindestanforderungen an das Risikomanagement (MaRisk), 30 June 2026 →