BaFin’s notice of 10 January 2025 says the Digital Operational Resilience Act applies from 17 January 2025. The same notice repeals the capital-management, insurance, and payments IT circulars at the end of 16 January 2025, and it repeals the remaining banking IT circular at the end of 31 December 2026. From 1 January 2027, further institutions apply DORA under the recast of section 1a(2) of the Banking Act. A Frankfurt general counsel who still has ICT contracts without the DORA clauses is not waiting on a strategy paper. The clauses have a statutory date, and the last year of the banking circular is 2026.
The supervisor’s own book is in the same city. The Federal Ministry of Finance, in a notice dated 2 July 2025, records that Frankfurt was announced as the seat of the EU Anti-Money Laundering Authority in February 2024 and that the authority took up operations on 1 July 2025. A compliance officer hiring interim counsel for a sanctions or customer-file surge is hiring next to that authority, not next to a policy blog. The employment base under the banks is Helaba’s forecast, dated 30 October 2025: about 75,500 bank employees in Frankfurt by the end of 2026, growth of about 2 percent, with regulatory demand named as a reason the staffing need rises.
On the funds side, BaFin’s 2025 annual report counts 145 licensed capital-management companies, up from 142, and 6,514 funds with EUR 3,006.2 billion under management. Net inflows in 2025 were EUR 90.6 billion. The same report records that EU securities transactions move to T+1 settlement on 11 October 2027, after the amending regulation was published in the Official Journal on 14 October 2025, and that the ESMA fund-name guidelines have applied since 21 May 2025. A project counsel seat on a fund-name rewrite or a settlement timetable is a dated file. It is not a standing headcount request.
The bar that can take the employed version of that work is counted, not estimated. BRAK-Mitteilungen 3/2026, for the reference date 1 January 2026, puts Frankfurt at 20,649 members, from 20,363 the year before, and at 479 admitted professional-practice companies. The BRAK press release of 15 April 2026, on the same reference date, puts lawyers in all admission types at 167,547 nationally, and Syndikus-only admissions at 8,279, up 9.15 percent from 7,585. The Syndikus growth is the employed bar. It is not a count of people free to start on Monday. An interim who must go on payroll still opens a chamber file under section 46a. The census says the stock exists. It does not say the stock is clear of conflicts or of a notice period.