Germany C5
Cloud Computing Compliance Criteria Catalogue (C5) — Federal Office for Information Security (BSI)
Also known as: C5, C5:2020, C5:2026, Cloud Computing Compliance Controls Catalogue, BSI C5
At a glance
- Status
- In force
- Next deadline
- in 204 days
- C5:2026 applies to type 1 reports dated, and type 2 periods beginning, on or after this date; earlier use is allowed (C5:2026 section 3.5) source
- How it is assessed
- An auditor engaged by the cloud provider issues a type 1 or type 2 attestation report under ISAE 3000 (Revised) or a national equivalent; customers should request it every year. source
- Authority
- Published by the German Federal Office for Information Security (BSI); independent auditors engaged by the cloud provider attest compliance, and the BSI is not involved in the audits. source
- Enforced by
- The BSI takes no part in audits and does not evaluate reports; customers must analyse them, and SGB V section 393 makes an attestation a condition for processing. source
- Last change
- None recorded yet
The criteria catalogue that independent auditors use to attest German cloud providers, and the attestation German law requires, or accepts an equivalent of, for cloud processing of health and social data by healthcare providers and health insurers.
Recent changes
No changes recorded yet — we are watching, and nothing has been published.
Key dates
Add these dates to your calendar- in 204 days C5:2026 applies to type 1 reports dated, and type 2 periods beginning, on or after this date; earlier use is allowed (C5:2026 section 3.5)
- C5:2026 version 1.1.0 published with corrections
- C5:2026 version 1.0.0 first published
- Cloud processing of health and social data in German statutory health insurance needs a current C5 type 2 attestation instead of type 1, except for systems in their first 18 months on the market (SGB V section 393(4))
- BSI recommends C5:2020 for audit periods ending on or after this date
Amendments
-
C5:2026 version 1.1.0 ErrataCurrent text
Corrections and editorial adjustments to C5:2026. source
-
C5:2026 version 1.0.0 Major version
A fundamental revision built on C5:2020 and on the EUCS Substantial requirements, with new criteria on topics such as container management, supply chains, post-quantum cryptography, confidential computing, tenant separation and sovereignty. source
More
- Criteria are split into distinct sub-criteria, and additional criteria are classed as either sharpening or complementing a basic criterion.
- Published for the first time also in machine-readable form as YAML files, besides PDF and Excel.
- Also takes into account the CSA Cloud Controls Matrix v4, ISO/IEC 27001:2022 and the NIS2 Directive.
-
C5:2020 Major version
Revised in dialogue with users, auditors, regulators and providers in 2019 and finalised in January 2020, adding product security and government investigation requests as new criteria areas. source
More
- Introduced the option of a direct audit, in which the auditor prepares the system description during the audit.
-
—
C5:2016 Major version
The first edition of the Cloud Computing Compliance Criteria Catalogue. source
Who it applies to
C5 is aimed at professional cloud providers, their auditors and customers; SGB V makes an attestation a condition for cloud processing of German health and social data.
- Audience
- Minimum requirements for secure cloud computing aimed mainly at professional cloud providers, their auditors and customers. source
- Health and social data
- Healthcare providers, health and care insurance funds and their processors may process social and health data in the cloud only with a current C5 attestation on the C5 basic criteria, among other conditions (SGB V section 393(3)); an attestation or certificate to a standard of comparable or higher security level also qualifies (section 393(4)). source
- Customers
- Customers should request and evaluate the C5 report initially and then annually, and check whether their use case needs criteria beyond the minimum. source
- Which edition
- A type 2 engagement whose period starts before 1 June 2027 and ends after it should use only C5:2020; the two editions should not be combined in one engagement. source
How compliance is assessed
An auditor engaged by the cloud provider issues a type 1 or type 2 attestation report under ISAE 3000 (Revised) or a national equivalent; customers should request it every year.
- Attestation, not certificate
- Auditors check whether the criteria are met and, depending on the report type, whether they were met throughout a period; the BSI does not select auditors, take part in audits or evaluate reports. source
- Audit standard
- Conformity assessments are performed in line with ISAE 3000 (Revised) or national equivalents such as German PS 860. source
- Type 1 and type 2
- A type 1 report covers design at a cut-off date and is limited to the first engagement; a type 2 report also covers operating effectiveness over a period of at least three and normally no more than twelve months. source
- Annual report
- Customers should request the C5 audit report initially and then regularly every year. source
Enforcement and penalties
The BSI takes no part in audits and does not evaluate reports; customers must analyse them, and SGB V section 393 makes an attestation a condition for processing.
- BSI role
- The BSI is not involved in selecting auditors or in the audit itself and does not evaluate the reports; customers must analyse them and bear remaining risks. source
- Health sector
- Processing of health and social data in the cloud is permitted only if the attestation exists and the customer criteria in its report are implemented (SGB V section 393(3)). source
Documents
- Standard Kriterienkatalog Cloud Computing C5:2026, version 1.1.0 (PDF)
- Guidance C5:2026 overview and downloads, including YAML and change history (BSI)
- Standard C5:2020 and supporting documents (BSI)
- Guidance Kriterienkatalog C5 - introduction (BSI)
- Law text SGB V section 393 - cloud use in healthcare
Verified against official sources on 18 October 2026. We monitor the official sources for this framework. Watching since 18 September 2026. Subscribe to Germany C5 (RSS)