A vendor decision you can defend to your Vorstand — and to BaFin.
The hardest part of bringing in a new screening tool is rarely the tool itself — it is the file that justifies it afterward. Indicium reports carry dated sources, a full audit trail and explicit mapping to MaRisk AT 9, DORA Art. 30 and the GwG, so the documentation your second line will ask for already exists when they ask.
Not the tool. The file you build around it.
Your framework, our contract annex.
Every report is built so its documentation slots directly into the file your outsourcing register and your auditor already expect.
| Framework | What it requires | How Indicium documents it |
|---|---|---|
| MaRisk AT 9 | Materiality assessment, instruction, information & control rights, sub-outsourcing oversight | Outsourcing file with control-rights language and a sample register entry |
| DORA Art. 30 | Mandatory ICT third-party contract content, audit & access rights, termination rights | Contract annex plus sample entry for your Art. 28(3) information register |
| GwG §§ 11–14 | Identification, beneficial-owner assessment, ongoing monitoring | Structural look-through up to three levels, dated sources, re-screening |
| Art. 22 GDPR | No solely automated decision with legal effect about a person | Human final review at fixed trigger thresholds, four-eyes principle, audit trail |
Fit and proper concerns the institution's own leadership as well: for the appointment notification under § 24 para. 1 no. 1 KWG, § 25c KWG (executive directors) and § 25d KWG (administrative or supervisory bodies) set the standards – professional qualification, reliability and sufficient time. The suitability guidelines of the EBA and ESMA and the relevant BaFin guidance notes specify how the supervisor interprets these terms and which documents it expects. What should be researched and documented before nomination is covered in depth in our article Fit & Proper at BaFin →.
The honest boundary: what is registered nowhere — unregistered trusts, purely private holdings — no automated check can see from open and licensed sources. Every report states that limit rather than papering over it.
€79 is the automated baseline — not the whole spectrum.
A price that low invites the question every compliance officer is right to ask: can this actually be trusted? The honest answer is that €79 buys the Essential tier of the Software-Report — the fully automated depth that resolves around 70% of routine cases, every source dated and reproducible as of the cut-off date. It is the baseline, not the ceiling.
Where the stakes are higher — a suspicious counterparty, a nested ownership structure, a case that will end up in front of your Vorstand — Hybrid adds documented human review under the four-eyes principle, and Boutique is fully analyst-led. You choose the depth per case; the audit trail records which depth you chose and why. Set against a partner-rate hour of outside counsel, even the analyst-led depth is a fraction of the cost.
"With Indicium, we were able to implement a digital process that provides structured and traceable reports and supports our internal documentation processes. The decisive factors for us were European data residency and the clear consent structure."— Bruno Schneller, Managing Partner, Erlen Capital Management AG
Erlen Capital is a FINMA-licensed asset manager, not a bank — but it operates under the same documentation bar: KYC, anti-money-laundering and ongoing-monitoring duties that must survive internal and external audit. Read the case study →
From the routine onboarding check to the analyst-led escalation.
Can a €79 report really hold up in front of BaFin?+
How does Indicium map to MaRisk AT 9 and DORA Art. 30?+
Where is our data hosted, and what about Art. 22 GDPR?+
What about §43e BRAO and §203 StGB confidentiality for personnel and counterparty checks?+
What happens if we are not satisfied with a report?+
Our reports are tailored to the evidence requirements of regulated institutions: dated, sourced, verifiable. Whether your supervisory authority accepts a check in an individual case is not for us to decide – we provide the basis you can use to evidence it.