Regulatory self-classification Regulatory self-classification


Following the recent introduction of regulatory requirements concerning the status of parties of financial transactions, it is important for financial institutions to be transparent about their roles. In order to help our clients and counterparties conduct their due diligence processes and increase transparency, this section provides the self-classification information for Commerzbank AG in relation to a number of regulations. In addition, you will also find links to further information on relevant disclosures and documents.


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CRR (Capital Requirements Regulation)

Commerzbank AG is a "Credit Institution" according to Art. 4(1) [EU/575/2013].

Dodd Frank

  • Commerzbank AG is provisionally registered as a Swap Dealer with the U.S. Commodity Futures Trading Commission (CFTC) and the National Futures Association (NFA ID: 0239971).
  • Commerzbank AG is a Foreign Banking Organisation, supervised by the Federal Reserve Bank of New York.

EMIR (European Markets Infrastructure Regulation) – Clearing Obligation

Commerzbank AG is a “Financial Counterparty” (FC) according to Art. 2(8) [EU/648/2012] and as an existing clearing member with a number of CCPs also categorised as:

  • ‘Category 1’ for Clearing Obligations with regards to IRS G4 [Delegated Regulation (EU/2015/2205)] and IRS NOK/SEK/PLN [Delegated Regulation (EU/2016/1178)].
  • ‘Category 2’ for CDS [Delegated Regulation (EU/2016/592)]

EMIR – Bilateral Margining Requirements

  • Commerzbank AG has been subject to variation margin requirements since March 2017 according to Art. 11 EMIR (EU/648/2012) and Delegated Regulation (EU2016/2251).
  • As of 1 December 2020, Commerzbank is, based on aggregate average notional amount outstanding thresholds defined in EU delegated regulation 2016/2251 Art. 36 No. 1 (d), in scope of certain initial margin requirements in the EU.
  • In addition, the bank applies US initial margin regulations for certain counterparties with US-nexus.
  • To facilitate the risk management process of our counterparties Commerzbank AG provides the ISDA Regulatory self disclosure letter here (Section “EMIR”)

FATCA (Foreign Account Tax Compliance Act) / CRS (Common Reporting Standard)

Commerzbank AG qualifies as a Reporting German Financial Institution for purposes of both U.S. FATCA (Foreign Account Tax Compliance Act) and the Common Reporting Standard (CRS). Commerzbank AG, its branches outside Germany and several of its subsidiaries confirm their respective status as a (Reporting) Financial Institution under locally applicable regulations through IRS (U.S. Internal Revenue Service) W forms (follow the link below under “Registration numbers – FATCA/IRS” directing you to the download site).

FinSA – Financial Services Act (Switzerland)

Commerzbank AG is an Institutional Client according to Art. 4(4) FinSA

FinfraG (Finanzmarktinfrastrukturgesetz)

  • Commerzbank AG would be considered a Financial Counterparty+ (FC+) according to FinfraG Art 99 if it would have its registered seat in Switzerland.
  • As a financial institution incorporated in Germany, Commerzbank AG is fully compliant with EMIR [EU/648/2012] and accordingly classified Financial Counterparty (FC) Art. 2(8) [EU/648/2012].

KWG (Kreditwesengesetz)

Commerzbank AG is a "Kreditinstitut" according to §1 Abs. 1 KWG.

MiFID (Markets in Financial Instruments Directive)

  • Commerzbank AG is an "Eligible Counterparty" according to Art. 30 [2014/65].
  • Commerzbank AG is an “Investment Firm” according to Art. 4(1) 2014/65].

As of 20th September 2023, Commerzbank AG is registered as Systematic Internaliser (SI) under the MiFID II/ MiFIR regime in the following asset classes:

  • Bonds (BOND) - venue MIC: CBKG
  • ETCs & ETNs - venue MIC: CBKD

Registration numbers

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  • GIIN: G51Q21.00000.LE.276
  • German VAT Registration Number: DE – 114 103 514

FATCA/ IRS (Foreign Account Tax Compliance Act)

For the list of GIINs attributed to Commerzbank branches and subsidiaries as well as for W-8BEN-E forms please see the “GIIN-List” provided in the sectionInstitutions/Fatca.

REMIT (Regulation on wholesale Energy Market Integrity and Transparency)

Commerzbank is registered with ACER under following ACER code A00037361.DE.

EIC-Code: 37X000000000281H

Dodd Frank

Commerzbank AFG is registered with the National Futures Association (NFA) under NFA ID: 0239971.

Company registration and VAT registration

For the company registration and German VAT number please refer to "imprint"

Supervisory authorities

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Commerzbank AG is incorporated in the Federal Republic of Germany and authorised by Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin; Licence/ registration number 100005)

United Kingdom

  • Commerzbank AG is registered in England and Wales BR 001025 | 30 Gresham Street, London EC2V 7PG.
  • Commerzbank AG is subject to limited regulation by the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA).
  • Commerzbank AG London branch is authorised by UK regulators as a Third Country Branch, and appears on the "UK Financial Service Register" under number 124920.


Commerzbank AG is a "Foreign Banking Organisation" supervised by the "Federal Reserve Bank of New York".

Additional information

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Information on the compliance of Commerzbank with the USA PATRIOT Act can be found in the section About us/Compliance/USA PATRIOT Act.


Information regarding KYC and MLP (Money Laundering Prevention) policies of Commerzbank AG as well as its corporate governance you find under Institutions/KYC & MLP Policies.

Canadian Derivatives Reporting

  • Commerzbank AG has undertaken “deemed” Derivatives Dealer status under the Canadian regulations for reporting purposes in all Canadian provinces.
  • Commerzbank AG is not registered as a Derivatives Dealer in any Canadian province

SFTR (Securities Financing Transactions Regulation)

Commerzbank AG is compliant with EU Regulation 2015/2365 on Securities Financing Transactions and is aware of the general risks and consequences that may be involved in consenting to a right of use of collateral provided under a security collateral arrangement.

Commerzbank AG is a Financial Counterparty under the SFTR. For our counterparties engaging with us in Repo or Securities Borrowing Business we have provided additional information on the Regulatory Disclosures section of the Corporate Clients area of this website.