Germany – Valuation for lending purposes

Data as of October 2026

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I. THE VALUATION

I.1 Regulatory Framework

a) Is there a legal framework in your Member State for the valuation of real estate for lending purposes (loan origination)? If yes: • Is this framework specifically for the valuation of real estate for lending purposes or are provisions enshrined in a broader piece of legislation? • Is it limited to the transposition of European or International Standards or is it broader in nature? • Please provide references and indicate whether it applies to both residential and commercial property. If there are differences between both property types, please explain.	Germany does not merely transpose EU standards but operates a broader and more detailed national framework, especially for mortgage lending value and covered bonds. A distinction must be made between more fundamental requirements for lending valuation, e.g. qualification and independence of valuers, documentation, etc., on the one hand, and specific methodological requirements within valuation approaches on the other. For the former, the following national requirements are relevant in addition to the European regulations: - Mortgage Credit Directive (2014/17/EU), transposed mainly via the German Civil Code (BGB) and supervisory practice - German Banking Act (Kreditwesengesetz – KWG) - Pfandbrief Act (Pfandbriefgesetz – PfandBG) - Minimum Requirements for Risk Management (MaRisk), issued by BaFin With regard to valuation approaches, the market value, mortgage lending value and property value are used in the banking industry's valuation process. There are numerous requirements for the mortgage lending value in the Regulation on the Determination of the Mortgage Lending Value (Beleihungswertermittlungsverordnung – BelWertV). This is an independent national valuation methodology that is not linked to international standards. There are various national regulatory requirements for market value. It is possible to use international standards. However, the main focus is on market value standardised in § 194 of the German Building Code (BauGB). Its structure corresponds to common international market value definitions. The Federal Valuation Ordinance (ImmoWertV) supplements § 194 BauGB with specific valuation rules for determining market value. However, it is only mandatory for the narrowly defined scope of application specified in the BauGB. While the guidelines on mortgage lending value refer exclusively to lending valuation, the regulations on market value determination are generally applicable guidelines that are used either in full or in part in lending valuation. In principle, the guidelines from all of the above are valid for residential and commercial properties. In terms of the details of the methods, there are some deviations for certain types of properties, e.g. owner-occupied residential properties.
b) If there is no specific legal framework, is the valuation of real estate for lending purposes covered by other means, e.g. self-regulation, sector recommendations or supervisory guidance?
c) Do national valuation standards exist? Is there any cross-reference to European and/or International Valuation Standards (EVS/IVS)?	see a) There is no cross-reference to European and/or International Valuation Standards (EVS/IVS) in the national regulation. However, national valuation are broadly aligned with EVS and IVS but retain distinct national features.
d) How has the regulator in your Member State transposed Article 19(1) of the MCD regarding “reliable standards” for the valuation of residential property (into legislation or delivered through a professional body)? Indicate whether and how “reliable standards” are defined and whether and how the content of those standards are prescribed.	No, the national implementation of the MCD in the German Civil Code (BGB) and the German Banking Act (KWG) does not specify what reliable standards are. Section 18a (7) of the German Banking Act (KWG) states the following: "(7) Credit institutions that grant consumer loans secured by real estate or by a real charge shall 1. use reliable standards when valuing the property and 2. ensure that internal and external valuers who carry out property valuations for them are professionally competent and sufficiently independent from the loan granting process to be able to carry out an objective valuation. [...]" However, Article 19(1) MCD (“reliable standards”) is effectively implemented through a combination of statutory requirements (BelWertV, PfandBG) and supervisory expectations under MaRisk. Reliability is ensured through methodological and documentation requirements.

I.2 Valuation Bases & Methodology

a) What valuation bases (Market Value, Mortgage Lending Value, etc.) are typically used in your Member State for the valuation of property for lending purposes (please disregard at this stage the specific requirements of Art. 229 CRR considering that the Property Value is not an independent basis of value).	Market Value, Mortgage Lending Value
b) Based on what definition? Please provide the definition and reference to where it can be located.	Mortgage Lending Value: Art. 16 (2) Pfandbrief Act: “The mortgage lending value must not exceed the value resulting from a prudent assessment of the future marketability of a property by taking into account the long-term sustainable aspects of the property, the normal regional market condition as well as the current and possible alternative uses. Speculative elements must not be taken into consideration. The mortgage lending value must not exceed a market value calculated in a transparent manner and in accordance with a recognized valuation method.” Market Value Art. 16 (2) Pfandbrief Act: “The market value is the estimated amount for which a property serving as collateral could exchange on the date of valuation between a willing buyer and a willing seller in an arm’s length transaction after proper marketing wherein the parties had each acted knowledgeably, prudently and without compulsion” Art. 194 Building Code: “The market value is determined by the price that could be achieved at the time of the valuation in normal business transactions, taking into account the legal circumstances and actual characteristics, other qualities and location of the property or other object being valued, without regard to unusual or personal circumstances.”
c) In case other valuation bases are used in your Member State for the valuation of property for lending purposes, please specify the effect, if any, on the final valuation.	No further valuation bases. The valuation basis chosen directly affects the final valuation outcome, with Mortgage Lending Value generally resulting in lower, more stable values than Market Value.
d) Depending on the valuation base used, which valuation approaches or methods (comparison, income, cost, etc.) are typically applied in your Member State to value properties for lending purposes in each category?	All three valuation methods (comparison, income, cost approach) are used in both market and mortgage lending value assessments. Owner-occupied residential property is generally valued using the cost value or comparative value. Properties where returns and income are the main focus are valued using the income approach. In addition to traditional commercial properties such as office, retail, hotel, logistics and social properties, this also includes multi-family houses.

I.3 Valuation Report: Form & Content

a) Does the legal or professional framework in your Member State specific to the valuation of properties provide minimum requirements in terms of the form and content of the valuation report? If yes, please indicate what these minimum requirements are.	• 5 (3) BelWertV sets out the content requirements for a valuation report. According to this, the valuer must address the following in the valuation report: - the quality of the property, - the location quality, - the regional property market, - the legal characteristics of the property, - the actual property characteristics, - eligibility for Pfandbrief coverage, - the usability, - the marketability and the - third-party usability. For the valuation, it is essential to obtain comprehensive information about the property being valued, i.e. information in particular about the technical and legal characteristics of the property and its location. In addition to the property documents, the findings from the property inspection are also a source of information. The regulatory requirements for lending valuation do not contain any explicit specifications as to which documents are necessary for a valuation. While some documents are essential for identifying the pledged property (Pfandidentität) and assessing the value of the mortgaged property, such as the cadastral map and an extract from the land register, a decision can be made on a case-by-case basis as to which additional documents are necessary. The key valuation parameters, data and assumptions must be presented and justified in a comprehensible manner in the valuation report.
b) Should the form and content of valuation reports be prescribed, are there differences between residential and non-residential properties? Please describe as appropriate.	In practice, valuation reports for commercial properties are more extensive and detailed than for residential properties due to higher complexity and risk. Where not explicitly prescribed by law, professional standards and lender requirements define typical report content. If a loan can be classified as a small loan within the meaning of § 24 BelWertV and the requirements for the mortgaged property are met, the following relief can be claimed: Instead of a formal valuation report in accordance with § 5 BelWertV, a so-called simplified valuation is sufficient. Extensive textual explanations, e.g. on the assessment of the location quality or the condition of the property, can be omitted and are replaced by standardised text modules and/or assessments based on a selection from predefined scales. Regardless of this, the value-relevant approaches must be justified, albeit in a simplified form.
c) If the form or content of the valuation report are not prescribed, what form does the valuation report typically take? Please specify differences between residential and commercial property valuation reports.

I.4 Technology & Valuation

a) Does the legal or professional framework in your Member State provide specific rules/guidance on the use of digital valuation tools (AVMs, Artificial Intelligence etc.)? If yes, what does this consist of and is it restricted to a particular type of property? Please specify whether there is a correlation with the requirements of Article 208(3a) CRR and of section 7.4 of GLOAM or whether the latter provisions are of stand-alone application in your Member State.	AVMs are primarily applied to residential properties. Commercial property valuation remains largely valuer-driven. Art. 19 (2) BelWertV provides rules on the use of statistical approaches: “(2) Notwithstanding par. 1 sentence 2, in the case of single-family and semi-detached houses as well as of condominiums, the comparative value may also be determined using computer-assisted database-supported valuation models if their suitability and the underlying data comprehensibly derived on the basis of suitable statistical models are validated at least annually by a qualified body independent of the system provider and database provider. The valuation results must also be reviewed by the Pfandbrief bank at regular intervals within the scope of quality assurance; § 24 par. 2 sentence 3 shall apply accordingly with the proviso that, in the case of lendings on single-family and semi-detached houses, the cost approach is to be used for the review. The samples must, in particular, also be representative according to the type and regional location of the properties.” The regulations are viewed as being on top of the regulations at European level from the CRR and EBA GL LOAM and apply explicitly to the determination of mortgage lending values.
b) For what purpose are digital tools and/or AI employed in your Member State? - Mortgage origination, monitoring and review of property values, revaluation etc. - Capital requirements, covered bond funding, securitisation transactions, mortgage portfolio risk management etc.	All of the purposes mentioned in the question are possible; the breadth of the area of application varies from bank to bank.
c) Scope of digitisation: Please determine the scope of automated and digitised tools in your Member State. Are they confined to data collection, do they deliver reliable property values or are they even used to produce full or partial valuation reports including description of locations, infrastructure, building characteristics etc.? If the latter is the case, is internal data used or it is permitted to purchase data from an external data provider?	Subject to European regulations stipulating that the valuer is responsible for the valuation result, the tools provide proposals for valuation results. In addition, some tool providers also offer text modules for specific content of the valuation report that can be accessed. With regard to these textual explanations, there is currently a great deal of momentum, particularly with regard to the use of AI tools. Both, internal and external data is permitted.
d) Quality requirements: How are the reliability of the tools and their outputs assessed, e.g. by controlling the inputs, back-testing, supervision and/or plausibility checks by valuers etc.?	In addition to the requirements of Article 208(3a) CRR and EBA GL LOAM, please refer to the answer to question 1.4. a) in the context of mortgage lending value.
e) Do you foresee an increase in the use of automation and digitisation of property valuation processes in the future? Please describe potential technological developments which could impact the valuation profession and accelerate its transformation, notably through the use of AI.	Continuous development is taking place, particularly in the use of AI for creating the descriptive parts of the report, data research and extracting valuation-relevant information from official documents.

I.5 ESG, climate risk, transformation risk

a) How are ESG factors and climate risk taken into consideration in the valuation process? Do Market Values and/or Mortgage Lending Values reflect the ESG characteristics of properties?	ESG factors are already taken into account in both market value and mortgage lending value, although S and G risks play a subordinate role because, in terms of banking supervision and regulation, they primarily address the corporate level rather than the property level. The prerequisite is that the E-factors are relevant to value. In addition – especially for risks that are not relevant to value – the valuer can act as an information provider for other areas of the bank, such as risk management. The established definitions for market and mortgage lending values offer sufficient leeway and guidelines for taking into account transitional risks as the energy efficiency of buildings as well as location-based physical climate-related and environmental risks. For further details see chapter 4.3. of the following publication: https://www.pfandbrief.de/wp-content/uploads/2025/07/Consideration-of-environmental-risks-in-property-valuation_vdp_7_July_2025.pdf
b) Are there rules in your Member State requiring assessment of EU Taxonomy alignment of a property in the valuation report and the subsequent impact of compliance/non-compliance on property values?	There is currently no explicit legal obligation to assess EU Taxonomy alignment within valuation reports. However, supervisory expectations e.g. under MaRisk require banks to consider ESG risks in collateral valuation.
c) Are digitised tools and AI applied in order to capture and/or measure the impact of ESG factors and climate risk on property values?	Yes, digital tools and geospatial data are increasingly used to capture climate risks such as flooding or transition risks.

I.6 Market Initiatives

a) Please describe any market initiatives which have been undertaken in your Member State (including cross border initiatives) and which have promoted market best practices and/or transparency of valuation practices.

II. THE VALUER

II.1 Regulatory Framework

a) Is property valuation a regulated profession in your Member State (through legal, regulatory or statutory rules)?	No, but there are national requirements for the qualification of valuers in the context of lending (see Question 2.1.c).
b) Is the use of the title of valuer protected in your Member State? If yes, by whom?	No
c) If the title of valuer is not protected in your Member State, how do lenders ensure that they work with ‘qualified’ valuers? Are there ‘professional’ certifications for property valuers in your Member State? If yes, please name them.	In accordance with § 16 of the PfandBG and § 6 of the BelWertV, valuers must have professional experience in the valuation of properties and demonstrate expertise in determining Mortgage Lending Values. The BelWertV assumes that a valuer is sufficiently qualified if they have been appointed or certified as an expert or valuer for the valuation of properties by a state, state-recognised or DIN EN ISO/IEC 17024- accredited body. This includes HypZert GmbH: it is the largest accredited certification body for valuers in Germany with more than 2,400 certified individuals. To register for the certification exams, applicants must demonstrate many years of relevant professional experience, among other things. HypZert valuers are subject to strict professional principles. To maintain their certification, they must undergo continuous further training. Certain concessions apply with regard to qualifications and independence in the small loan sector pursuant to § 24 BelWertV. Other recognised qualifications include RICS and the public appointment and swearing-in of valuers.
d) Is the regulatory or professional framework the same for all valuers, whether they value residential and/or commercial property? Or are there differences? Please describe as appropriate.	Professional requirements are broadly similar for residential and commercial valuers, but complexity and experience requirements differ in practice. Certain concessions apply with regard to qualifications and independence in the small loan sector pursuant to § 24 BelWertV. Valuers in the small loan sector must be sufficiently trained and qualified to determine the Mortgage Lending Value of the relevant properties within the small loan limit.

II.2 Qualification and Independence

a) The qualified valuer • How has the regulator in your Member State transposed the requirements of Article 19(2) of the MCD, of Articles 229(1) and 208(3b) of the CRR regarding the instruction of “professionally competent valuers” or valuers who possess the “necessary qualifications, ability and experience” (transposition through legislation or by self-regulation)? Indicate how professional competence and qualification requirements are prescribed.	The national implementation of the MCD in the German Civil Code (BGB) and the German Banking Act (KWG) does not specify these terms. Section 18a (7) of the German Banking Act (KWG) states the following: "(7) […] 2. ensure that internal and external valuers who carry out property valuations for them are professionally competent and sufficiently independent from the loan granting process to be able to carry out an objective valuation. [...]" However, Article 19(1) MCD (“professionally competent valuers”) is effectively implemented through a combination of statutory requirements (BelWertV, PfandBG) and supervisory expectations under MaRisk. In accordance with § 16 of the PfandBG and § 6 of the BelWertV, valuers must have professional experience in the valuation of properties and demonstrate expertise in determining Mortgage Lending Values. The BelWertV assumes that a valuer is sufficiently qualified if they have been appointed or certified as an expert or valuer for the valuation of properties by a state, state-recognised or DIN EN ISO/IEC 17024- accredited body. (See Question 2.1)
a) The qualified valuer • If professional competence, qualification, ability and experience requirements are not prescribed, what is general practice with regard to professional qualifications?
b) The independent valuer • How has the regulator in your Member State transposed the provision in Article 19(2) of the MCD or in Articles 229(1) and 208(3)(b) of the CRR regarding “sufficient independence from the credit underwriting process” or “independence from the loan processing and loan decision process” (through legislation or delivered through self-regulation)? Indicate whether and how the requirement is defined and whether and how it is prescribed.	The national implementation of the MCD in the German Civil Code (BGB) and the German Banking Act (KWG) does not specify these terms. Section 18a(7) of the German Banking Act (KWG) states the following: "(7) […] 2. ensure that internal and external valuers who carry out property valuations for them are professionally competent and sufficiently independent from the loan granting process to be able to carry out an objective valuation. [...]" However, Article 19(1) MCD (“independence”) is effectively implemented through a combination of statutory requirements (BelWertV, PfandBG) and supervisory expectations under MaRisk. According to § 7 BelWertV, valuers must be independent of the loan acquisition and loan decision-making process, as well as of property brokerage, sales and rentals. They must not have any family, legal or economic relationship with the borrower and must not have any personal interest in the outcome of their valuation report. Certain concessions apply with regard to independence in the small loan sector pursuant to § 24 BelWertV.
b) The independent valuer • If “sufficient independence” is not prescribed, what is general practice to ensure the valuer is unbiased and not subject to undue pressure?

II.3 External vs. Internal

a) Does the legal or professional framework in your Member State specific to the valuation of property for lending purposes lay down rules for banks and lenders as to whom they may use to value properties? • If yes, do credit institutions have the possibility to employ both internal and external valuers? • Is one type of valuer typically employed more frequently than the other?	German banks do not necessarily commission external valuers for Market and Mortgage Lending Value assessments: many credit institutions also employ internal valuers or have valuers in their own subsidiaries. In its high requirements for independence, qualification and experience, the BelWertV does not differentiate between internal and external valuers. The proportion of internal and external valuations varies greatly from bank to bank and is subject to each bank's individual organisation of the valuation process. While some banks use almost exclusively internal appraisers, others outsource the vast majority of their valuations to external valuers.
b) If there is/are no legislation/rules regarding the use of external and internal valuers, what is typical practice?	There is no typical national practice. As described under a), the structure of the valuation process varies greatly in this regard.

a) Does the legal or professional framework in your Member State specific to the valuation of property for lending purposes lay down rules for banks and lenders as to whom they may use to value properties?

• If yes, do credit institutions have the possibility to employ both internal and external valuers?
• Is one type of valuer typically employed more frequently than the other?

German banks do not necessarily commission external valuers for Market and Mortgage Lending Value assessments: many credit institutions also employ internal valuers or have valuers in their own subsidiaries. In its high requirements for independence, qualification and experience, the BelWertV
does not differentiate between internal and external valuers. The proportion of internal and external valuations varies greatly from bank to bank and is subject to each bank's individual organisation of the valuation process. While some banks use almost exclusively internal appraisers, others outsource the vast majority of their valuations to external valuers.

b) If there is/are no legislation/rules regarding the use of external and internal valuers, what is typical practice?

There is no typical national practice. As described under a), the structure of the valuation process varies greatly in this regard.

II.4 Professional Indemnity Insurance

a) Does the legal or professional framework in your Member State specific to the valuation of property for lending purposes require: • Valuers to have professional indemnity insurance cover? • Lenders to use only valuers covered by professional indemnity insurance?	No
b) If there are no such requirements, how are lenders/valuers covered for the risk? • Is/are there legislation/rules in your Member State determining the responsibility of the valuer vis-à-vis his client? If yes, please describe the legislation/rules and the responsibility of the valuer.	it is common practice to work only with valuers who can prove professional indemnity insurance.

III. VALUATION & CAPITAL REQUIREMENT

a) Property Value How are the Property Value requirements of Article 229(1) CRR transposed in your Member State: • by calculating the Mortgage Lending Value • by Market Value adjustments ◦ adjustments determined by the valuer on a single property by property basis ◦ adjustments determined by the credit institution on a portfolio level based on internal historic market data series ◦ adjustments determined by the credit institution on a portfolio level based on data provided by external research institutes or data providers	The national banking supervisory authority has stated that two approaches are possible for the operationalization of "property value" in Germany: - The mortgage lending value pursuant to Section 16 (2) sentences 1 to 3 Pfandbrief Act in conjunction with the Regulation on the Determination of Mortgage Lending Values of Properties (Beleihungswertermittlungsverordnung (BelWertV)) fulfills the requirements of Article 229 (1) CRR in all cases. - Alternatively, the market value can be used as a basis. In a step downstream of the market value determination, this value must be reviewed to determine whether an adjustment is necessary in order to meet the requirements of Art. 229 (1) letter b) CRR III. While the market value is of course determined on a property-related basis, this review and, if necessary, adjustment of the market value can be carried out on a portfolio-related basis using statistical methods of relevant market data. With regard to the second alternative, there are no guidelines as to whether the bank should work with discounts based on internal historical market data series, external research institutes or data providers. All mentioned variants are possible. One widely used methodology is an adjustment approach developed by the Association of German Pfandbrief Banks in cooperation with vdpResearch: vdpResearch
b) Monitoring of property values Has the regulator in your Member State laid down criteria regarding "more frequent monitoring where the market is subject to significant changes in conditions"?	National banking supervisory authorities have stated that events that cannot be captured by general market developments may also necessitate a review of property values. These include technical, economic or environmental disasters such as natural disasters, regional property crises or specific borrower- or contract-related events. Individual institutions must have processes and models in place to identify such review events.
b) Monitoring of property values Has the regulator in your Member State laid down criteria regarding “advanced statistical or other mathematical methods” complying with the technical requirements of Article 208(3a) CRR?	No
b) Monitoring of property values Please provide an overview of the different statistical methods/tools complying with Article 208(3a) CRR applied by lenders in practice.	One of the statistical methods recognised by the national banking supervisory authority is the market fluctuation concept of the German Banking Industry Committee (DK, Deutsche Kreditwirtschaft). This has already proven itself for commercial properties since 2001 and for residential properties since 2007 for the implementation of the monitoring requirements at that time. The DK’s market fluctuation concept covers market developments for commercial property types such as offices, retail, warehouses and hotels, as well as residential property types such as condominiums, single-family, two-family and multi-family houses. With the exception of hotels, market fluctuations are provided for all cities and districts in Germany. For hotels, market developments are measured in selected indicator cities and four major regions in Germany and reported to BaFin. The results are made available to the supervisory authority on an annual basis. In addition to the market fluctuation concept of the German Banking Industry Committee, other statistical methods for monitoring values have been developed in recent years. In addition to institution-specific models, which are strongly oriented towards the respective financing portfolio, there are also cross-institutional products on the market. One example is the property market monitoring service provided by vdpResearch GmbH, which is used by over 90% of German credit institutions.
c) Review of property values and revaluation • Has the regulator in your Member State laid down criteria which define “review” of the property valuation? If so, what are the minimum and maximum periods within which a review must be conducted? Based on which criteria?	Yes, it has to be reviewed whether the original assessments of the framework conditions and the other assumptions about the relevant market on which the valuation reports are based are still valid. If the assumptions and results at the time are no longer accurate, the value of the property must be revalued. In accordance with Article 208 (3) CRR, advanced statistical methods may be used to identify properties that require revaluation.
c) Review of property values and revaluation • Has the regulator in your Member State laid down criteria which define “material decline relative to general market prices”? How are ESG-related considerations assessed as an indicator for a material decline?	Yes, if the regular monitoring reveals indications that the property may have lost considerable value in relation to general market prices, the valuation must be reviewed. The national banking supervisory authorities (BaFin and Bundesbank) have so far interpreted “significant” as meaning that, within a period of up to three years, general market value losses of more than 10% for commercial properties and more than 20% for residential properties have occurred. According to the German Banking Industry (DK), ESG factors do not need to be explicitly addressed in this context. As one of many potentially value-relevant components, they are already included in prices and values to the extent that the market attributes value to them. The above-mentioned statistical methods for monitoring are based on price measurement and therefore already implicitly include ESG factors.
c) Review of property values and revaluation • Please provide a description of how ‘reviews’ are carried out in your Member State, e.g. by a new full-size valuation report, a desk-top valuation, a valuation certificate, a plausibility assessment or alike. What criteria are used to determine how the reviews are to be carried out?	Credit institutions must implement processes for reviewing property values. These are usually differentiated according to risk categories. In some cases, it is also up to the valuer to decide how thorough the review should be, for example, whether a desktop valuation is sufficient or whether an inspection should be carried out. There are no national guidelines on what constitutes a review.
c) Review of property values and revaluation • For the calculation of average values in accordance with Article 229 (1)(e) CRR in the context of upward revisions of values, are there any guidelines from regulators or lenders addressing the data points to be used and the comparability of properties? Please indicate whether there are requirements from regulators or lenders for ‘sufficient data’ and ‘unequivocal increases of value’.	To date, there are no guidelines from national banking supervisory authorities regarding the average value.

IV. VALUATION OF THE COVER POOL

a) Are valuation rules for cover assets provided at national level in accordance with Article 6(5a) CBD? Are they provided by national covered bond legislation or by professional guidance/standards?	Yes, valuation rules are provided by national covered bond legislation in Art. 16 Pfandbrief Act and in the Regulation on the Determination of Mortgage Lending Value (BelWertV).
b) What valuation bases apply for the valuation of cover assets (Market Value, Mortgage Lending Value)?	Mortgage Lending Value according to the Regulation on the Determination of Mortgage Lending Value (BelWertV).
c) In the case of Market Value valuations, are there any prudential or longer term/sustainable features of the property to be considered? If yes, to what extend?	not relevant
d) How is the requirement that the valuation shall be carried out by a valuer who possesses the necessary qualifications, ability and experience transposed in your Member State (Article 6(5b) CBD)? Are there specific qualification requirements for valuers?	See 2.1. c)
e) How is the requirement that the valuer shall be independent from the credit decision process transposed in your Member State (Article 6(5c) CBD)?	According to § 7 BelWertV, valuers must be independent of the loan acquisition and loan decision-making process, as well as of property brokerage, sales and rentals. They must not have any family, legal or economic relationship with the borrower and must not have any personal interest in the outcome of their valuation report. Certain concessions apply with regard to independence in the small loan sector pursuant to § 24 BelWertV.
f) Are there differences in valuation rules and/or qualification requirements with regard to the property type (residential vs. commercial properties) or to the loan amount?	If a loan can be classified as a small loan within the meaning of § 24 BelWertV (residential property, sum of the land charge and the value of rights and encumbrances is less than EUR 600,000, use for commercial purposes is allowed if the income attributable to this use may not exceed one third of the gross income) and the requirements for the mortgaged property are met, the following reliefs can be claimed: - Documentation of the valuation: Instead of a formal valuation report in accordance with § 5 BelWertV, a so-called simplified valuation is sufficient. Extensive textual explanations, e.g. on the assessment of the location quality or the condition of the property, can be omitted and are replaced by standardised text modules and/or assessments based on a selection from predefined scales. Regardless of this, the value-relevant approaches must be justified, albeit in a simplified form. - Regarding the qualification and independence of valuers: Valuers in the small loan sector must be sufficiently trained and qualified to determine the Mortgage Lending Value of the relevant properties within the small loan limit. Furthermore, the valuer must not be the same person who makes the final credit decision or determines the Mortgage Lending Value. Nor may they have any family, other legal or economic relationship with the borrower, nor may they have any personal interest in the outcome of the valuation. There is no requirement to engage a valuer - who is independent of the credit acquisition and credit decision-making process as well as of property brokerage, sale and letting. In order to ensure the correctness of the valuations, valuers who meet the requirements of §§ 6 and 7 BelWertV must review a sufficiently large and representative sample of valuations at regular intervals. - During the inspection: There are exceptions that justify completely waiving an inspection in the case of small loans and further exceptions in which an interior inspection may be omitted.
g) Are there specific monitoring, review and revaluation requirements for cover pool assets at national level (see Article 129(3) CRR referring to Article 208 CRR)?	In addition to Article 208 (3) CRR, § 26 BelWertV also sets out requirements for reviewing Mortgage Lending Values in the context of Pfandbriefe: according to this, a review is required if there are indications that the basis for determining the Mortgage Lending Value has deteriorated to a significant extent. This applies in particular if the general price level on the respective regional property market has fallen to an extent that jeopardises the security of the mortgage. In practice, this requirement can be integrated with the monitoring and review process in the context of Article 208 (3) CRR. Unless owner-occupied residential properties are concerned, a review must also be conducted if the claim secured by the property serving as collateral shows substantial payment arrears of at least 90 days.
h) Do regulators of your Member State provide a waiver from the limitation of calculating average values for cover assets in case of upward revision of values (Article 129(3) second subpar. CRR)?	The national banking supervisory authority BaFin exercises the option under Article 129(3)(2) not to apply the cap under Article 229(1)(e) CRR. Mortgage Lending Value increases are generally not permitted. In practice, there are two exceptions: Value increases are permissible if they result from a revaluation of the mortgage lending value, provided that structural alterations are made to a property which significantly exceed of the value. Furthermore, value increases are possible in the case of new credit decisions.

V. OTHER

REGULATORY HARMONISATION AND NATIONAL DIVERGENCES

1. What challenges does your Member State face in harmonising with EU regulations (e.g. legal, technical, market-related)?	Valuation practices in Germany differ from those in other jurisdictions. These differences relate to both technical details and the legal and institutional framework. The so-called Anglo-Saxon methods and international approaches, which are widely used elsewhere in Europe and are largely driven by the requirements of the EVS, IVS and Red Book, are only used to a limited extent in Germany. National requirements prevail. Organisational peculiarities such as the widespread reliance on internal Valuers are also unique to Germany. In applying EU regulations and in ECB supervision practice it is therefore very challenging to raise awareness of these peculiarities in German valuation practice and to emphasise that a different approach is not necessarily inferior, but can also meet the requirements.

1. What challenges does your Member State face in harmonising with EU regulations (e.g. legal, technical, market-related)?

Valuation practices in Germany differ from those in other jurisdictions. These differences relate to both technical details and the legal and institutional framework. The so-called Anglo-Saxon methods and international approaches, which are widely used elsewhere in Europe and are largely driven by the requirements of the EVS, IVS and Red Book, are only used to a limited extent in Germany. National requirements prevail. Organisational peculiarities such as the widespread reliance on internal Valuers are also unique to Germany. In applying EU regulations and in ECB supervision practice it is therefore very challenging to raise awareness of these peculiarities in German valuation practice and to emphasise that a different approach is not necessarily inferior, but can also meet the requirements.

DATA QUALITY, TRANSPARENCY AND COMPARABILITY

a) What data sources are typically used by valuers in your Member State, and to what extent do they comply with Article 208(3a) of the CRR?	For Monitoring see question IIIb. For valuation purposes: The information on local property markets derived from the purchase price collection by the valuation boards (“Gutachterausschuss”) is a valuable aid in the valuation of properties. Due to their excellent regional and local knowledge, the valuation boards and their offices can often provide information on local conditions or special features of the property market. In addition, there are both cross-bank databases of banking associations and numerous database initiatives by private providers.
b) What measures have been taken to improve transparency and comparability of valuation data within your Member State?	All of the players mentioned under a) – valuation boards, association initiatives and private providers – are continuously developing their databases with the aim of providing up-to-date and granular data for many types of property, thereby contributing to quality development in property valuation.
c) Is there a central database or platform for sharing valuation data in your Member State?	No

EDUCATION, TALENT PIPELINE AND PROFESSIONAL DEVELOPMENT

a) What training programs or continuing education opportunities are available for property valuers in your Member State?	The academies of the banking associations in Germany offer training programmes specifically for valuers for lending purposes to prepare them for the HypZert certification examination (see question 2.1.). In addition, there are numerous training and further education programmes offered by private providers.
b) Is there collaboration between universities, professional bodies, and regulators to ensure a sustainable pipeline of qualified valuers?	Yes, except of regulators. One example is the dual degree programme in property valuation offered by Anhalt University of Applied Sciences in cooperation with HypZert and numerous industry partners such as banks and valuation companies. https://www.hypzert.de/de/duales_studium
c) How does the EU regulatory environment influence the development and attractiveness of the valuation profession?	Due to increased regulatory requirements in property valuation, particularly at EU level, the demands placed on valuers are growing continuously.

FUTURE TECHNOLOGICAL AND REGULATORY DIRECTIONS

1. What technological developments are expected to impact valuation processes in your Member State over the next five years?	The continuous expansion of databases for maximum transparency and the technical possibilities of AI are the main drivers influencing the work of valuers and the professional field of property valuation.