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appointment of a compliance officer at management level for non-SME operator

Hello Osapeers,

I have a question regarding the article 11 Risk mitigation. 2. Operators shall have in place adequate and proportionate policies, controls and procedures to mitigate and manage effectively the risks of non-compliance of relevant products identified. Those policies, controls and procedures shall include:
(a) model risk management practices, reporting, record-keeping, internal control and compliance management, including the appointment of a compliance officer at management level for non-SME operators;

This compliance officer, should be a representative for the whole company/one by country/needs to be someone at management level solely/from which department?

We are established in many European Countries with different production plants.

Thanks so much for your help.

Best regards,

Sergio

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Mark Mrosek Answered question November 25, 2025