Transparency Register

Publications and updates – We do it for you

The so-called Transparency Register exists alongside the Commercial Register since 1 August 2021 as an additional, fully-fledged register.

Until now, a large number of companies, such as limited liability companies and partnerships, could fulfil their information obligations under the transparency register on the basis of the entry in other registers, e.g. the commercial register. Thus, it was sufficient that the information for the identification of the beneficial owner resulted from the list of shareholders deposited with the commercial register; the transparency register functioned as a mere “catch-all register” for information that was not public elsewhere.

All information on the beneficial owner must however now be made available centrally in the transparency register and kept up to date. The obligated party must report the information electronically to the transparency register within certain transitional periods and keep it up to date in the future.

Procedure for reporting relevant data and updating

1. Verification of beneficial owners

Beneficial owners are, among others, the natural persons who ultimately own or control a company, or at whose instigation a transaction is ultimately carried out or a business relationship is ultimately established. In the case of companies, these are all persons who directly or indirectly hold more than 25% of the capital, hold more than 25% of the voting rights or control the company in a comparable manner. !Attention! Veto rights or special reservations on voting rights can lead to “control”, even if the shareholding is 25% or less. Fictitious beneficial owners (e.g. managing directors of companies without beneficial owners) are also subject to reporting requirements.

2. Information on the beneficial owners

• First name and surname,
• date of birth,
• place of residence,
• the nature and extent of the beneficial interest, and
• all nationalities.

3. Reporting obligations to be fulfilled by …

… 31 March 2022 for stock corporations and partnerships limited by shares (KGaA), among others,
… 30 June 2022 for limited liability companies (GmbH), cooperatives and partnerships,
… 31 December 2022 for foundations, among others.

!Attention! The transitional periods do not apply if there was already an obligation to register prior to the amendment of the law or in cases in which there was an obligation to register prior to the amendment of the law.
or in cases where registration is expressly required (e.g. in the case of bridging aid).

4. Registration with the Transparency Register and Making Notifications

Registration of information to the transparency register is carried out via the website www.transparenzregister.de. Instructions on how to register and submit reports can be found at www.transparenzregister.de/treg/de/Kurzanleitung_Eintragung.pdf.

Our service for the Transparency Register – content and prices

What we can do for you:

• Initial registration of your company with the Transparency Register
• Determination and verification of the beneficial owners
• Preparation and execution of the reports to the Transparency Register
• Annual reminder function with respect to possible changes
• Updating in the event of changes

Annual service fee – fixed price for planning and cost certainty

• We charge our service on the basis of a flat annual fee – so you have cost certainty.
• The annual service fee is calculated on the basis of the number of companies and the number of shareholders to be included in the reports.
• For each company an amount of € 60* and for each natural person an amount of € 20* is taken into account.
• The service fee includes one change per year; further changes are calculated on the basis of the shareholders/companies concerned.

The calculation is as simple as this …

• Number of companies in your structure x € 60*
• Number of natural persons in your structure x € 20*
  = annual service fee