Reporting Obligations to the Transparency Register

Since August 1, 2021, the Transparency Register has been maintained as a full register. All entities subject to transparency requirements must actively report their beneficial owners – even if they are listed in other registers. The Federal Gazette is currently requesting companies to submit their reports.

Who is required to register?

All “entities subject to transparency requirements” under the Money Laundering Act must register: GmbH, UG, AG, KGaA, registered associations, cooperatives, partnerships, as well as certain foundations and trust-like arrangements. Unregistered civil law partnerships (GbR) are exempt.

What must be registered?

The “beneficial owners” must be registered – natural persons who own or control the company. Required information includes: first and last name, date of birth, place of residence, nature and extent of beneficial interest (e.g., shareholding, voting rights), and citizenships.

Why are reminder letters being sent now?

Since the abolition of the notification fiction, entries in other registers are no longer sufficient – every company must actively report. Many must catch up on their reporting, which is why the Federal Gazette is sending reminder letters.

Who must take action?

Legal representatives are obligated (managing directors, board members, association boards, administrators/trustees). They must identify beneficial owners, collect data, and submit it electronically without delay.

Consequences of non-registration

Missing or delayed reports constitute administrative offenses. Fines can reach six figures, and in severe cases even millions. Final fines may be published (“naming and shaming”) – causing significant reputational damage.

Do you require assistance with registering your company in the transparency register? Please provide us with your legal form and shareholding structure. We will clarify the necessary details and take care of the registration.