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Risk Management Officer

Operates the enterprise risk management system: risk identification, assessment and treatment, early-warning indicators, and aggregated reporting to the board in line with ISO 31000 and the KonTraG duty of care.

Focus areas
Risk registerEarly warningISO 31000Board reporting
Legal basis

ISO 31000 · § 91 AktG (KonTraG)

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What is a Risk Management Officer?

A Risk Management Officer operates the enterprise risk management system: the structured identification, assessment, treatment and monitoring of the risks that could threaten the company's objectives or its continued existence. The role turns scattered risk knowledge into a coherent, comparable picture that the management board and the supervisory bodies can act on.

Two references anchor the role. ISO 31000 is the international standard on risk management; it provides the principles, the framework and the process from risk identification through analysis, evaluation and treatment to monitoring and review. It is a guidance standard, not a certifiable specification, and it gives the officer a common language and method. The legal anchor in German law is Section 91 Para. 2 of the Aktiengesetz (AktG), introduced by the Gesetz zur Kontrolle und Transparenz im Unternehmensbereich (KonTraG). It obliges the management board of a stock corporation to take suitable measures, in particular to set up a monitoring system, so that developments endangering the continued existence of the company are recognised early. The duty of care of the board under Section 93 AktG reinforces this.

The officer maintains the risk register, defines and tracks early-warning indicators, coordinates the assessment of likelihood and impact, oversees the treatment of significant risks, and aggregates the picture into reporting for the board. The function is closely linked to the internal control system and, where relevant, to compliance and internal audit. For listed and larger companies the risk reporting also feeds the management report and the work of the auditor, who reviews whether the early-recognition system under Section 91 AktG is suitable.

Duties of the Risk Management Officer

  • Maintain the enterprise risk register and the risk taxonomy across the organisation
  • Run the risk process of ISO 31000: identification, analysis, evaluation, treatment and monitoring
  • Define and track early-warning indicators that signal threats to continued existence under Section 91 AktG
  • Coordinate the assessment of likelihood and impact and the prioritisation of risks
  • Oversee the treatment of significant risks and follow up on mitigation measures
  • Aggregate the risk picture into periodic reporting to the management board
  • Link risk management with the internal control system, compliance and internal audit
  • Support the management report and the auditor's review of the early-recognition system
  • Promote a risk culture and train risk owners across business units

Appointment of the Risk Management Officer

The legal obligation under Section 91 Para. 2 AktG rests on the management board itself: the board must take suitable measures, in particular establish a monitoring system, so that existence-threatening developments are recognised early. The board cannot delegate the responsibility, but it routinely delegates the operation of the system to a risk management officer or a risk management function. Listed and larger companies typically appoint a dedicated officer; in groups the duty radiates to material subsidiaries.

There is no statutory qualification profile. In practice the officer combines knowledge of the risk process under ISO 31000, of the business and its risk drivers, and of the controls and reporting lines, often supported by a recognised risk-management or controlling background. The board should define the officer's mandate, reporting line and access to information, ideally with a direct line to the board.

The scope follows the company's legal form and size. Beyond the AktG, the GmbH-Geschäftsführer derives comparable duties from the general duty of care, and listed companies face additional requirements from the management-report and audit framework. The appointment, the mandate and the description of the risk-management system should be documented, because the auditor reviews the suitability of the early-recognition system and the supervisory board monitors it.

  • The company is a stock corporation subject to Section 91 Para. 2 AktG
  • Listed status brings management-report and audit requirements on the risk system
  • Group structure radiates the early-recognition duty to material subsidiaries
  • Size, complexity or capital-market access raises the need for a formal risk system
  • The supervisory board or auditor requires evidence of a suitable monitoring system

Industries and Sectors

  • Listed stock corporations and groups
  • Banking, insurance and financial services
  • Manufacturing and industrial groups
  • Energy, utilities and infrastructure
  • Pharmaceuticals and life sciences
  • Technology and telecommunications
  • Logistics, transport and supply chains
  • Public-sector enterprises and foundations
CIVAC

How CIVAC supports the Risk Management Officer role

CIVAC gives the risk management officer a structured register that holds each risk with its assessment, owner, treatment measures and early-warning indicators in line with ISO 31000. Recurring activities such as risk reviews, indicator updates, mitigation follow-ups and board-reporting cycles are scheduled as tasks with due dates and reminders, so the monitoring system required by Section 91 AktG keeps running rather than going stale between reports. Treatment measures are tracked to closure and linked to the responsible risk owner. The documentation of the risk-management system, its versions and the reporting history is held centrally, ready for the supervisory board and the auditor reviewing the suitability of the early-recognition system.

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