Letter from the Bundesamt für Justiz

Androhung eines Ordnungsgeldes: what this letter means and what to do in the six weeks

An Androhung eines Ordnungsgeldes is a formal warning from the Bundesamt für Justiz (Federal Office of Justice, BfJ): your company has not filed its annual accounts, and an administrative fine of at least EUR 2,500 follows unless you file or object within six weeks of delivery. If you file complete, adopted accounts inside the six weeks, the proceedings end and no fine is set. The EUR 103.50 costs on the letter stay payable either way.

Last reviewed: 2026-11-02

The German words on the letter

Phrases from § 335 HGB and from the BfJ's own pages. The layout of your letter may differ.

Androhung / Androhungsverfügung

The threat order. It names the amount that will be set if you do not act. You do not owe that fine yet, but you owe the costs from now.

Ordnungsgeld

Administrative fine for not filing. It is at least EUR 2,500 and normally at most EUR 25,000 (§ 335(1) HGB).

„innerhalb einer Frist von sechs Wochen vom Zugang der Androhung an“

Within six weeks from the day the threat reached you. The BfJ also calls this the Nachfrist (extra period).

„mittels Einspruchs“

By objection (Einspruch). Use it to argue that you did not have to file, or to contest the costs.

Offenlegung

Company Register filing. It means sending the accounts electronically to the body that runs the Unternehmensregister. The BfJ does not accept accounts itself.

Kassenzeichen

Payment reference. In the BfJ's words, every fine gets its own Kassenzeichen (“Jedes Ordnungsgeld erhält dabei ein eigenes Kassenzeichen”). Quote it when you pay.

Is the letter real?

“Bundesamt für Justiz” and “Bundesjustizamt” mean the same office, which is based in Bonn. It also has other tasks, so read the subject line. This page covers the filing fine under § 335 HGB only.

The BfJ warns about false letters and e-mails that claim to come from the Bundeszentralamt für Steuern (Federal Central Tax Office) and demand money for accounts that were not published. Its wording is: “Diese Schreiben sind nicht authentisch” (these letters are not genuine), and “Betroffene sollten nicht auf diese Schreiben oder E-Mails reagieren” (people affected should not respond). So a filing fine that names the tax authority as sender is a warning sign. If you are unsure, call the BfJ's central number from its website, +49 228 99 410-6500.

Second check: search for your company on unternehmensregister.de and bundesanzeiger.de. If the accounts for the named year are there, go to the objection section below.

What to do on which day

Example: the letter is delivered on Tuesday 3 November 2026. Six weeks end on Tuesday 15 December 2026. If the last day is a Saturday, Sunday or public holiday, the period runs to the next working day (§ 222 ZPO through § 16 FamFG).

Day of delivery: write the date on the letter and keep the envelope. With formal delivery into a letterbox, the postal worker notes the date on the envelope (§ 180 ZPO). This date starts your six weeks, not the date printed on the letter.
Same day: find the financial year in the letter. Each year has its own procedure, so a letter for 2023 says nothing about 2024.
Days 1 to 3: open your filing access at publikations-plattform.de. Under § 3a URV, the person who will submit must pass an electronic identity check first. Do this before the accounts are finished. For questions about the filing itself, the BfJ points to the Bundesanzeiger's free service line 0800 1234339.
By the end of week 3: finish the accounts for that year. A micro company files only the balance sheet and may deposit it (§ 326(2) HGB). A small company files the balance sheet and notes (§ 326(1) HGB). Medium and large companies file more.
By the end of week 4: have the shareholders adopt the accounts, and have every managing director sign. The BfJ states that provisional accounts do not meet the duty. See our guide to the Feststellung.
Week 5 at the latest: submit, and keep the confirmation with date and time. Do not plan for the last day, because proceedings continue if documents are missing. You do not need to tell the BfJ that you have filed.
Any time in the six weeks: pay the EUR 103.50 under the Kassenzeichen. This is a EUR 100 fee plus EUR 3.50 for delivery. If you do not pay, the Justizbeitreibungsstelle (collection office) adds a EUR 5 reminder fee, which is why people also see EUR 108.50 in reminders.

What each outcome costs

You file in full within six weeks

The proceedings end. No fine. You still pay the EUR 103.50 costs. Filing on time does not remove them.

You file after six weeks, before the BfJ decides

A fine is still set, but § 335(4) HGB requires a reduction: EUR 500 for a micro company that used the § 326(2) deposit, EUR 1,000 for a small company, EUR 2,500 if a higher amount was threatened. It can be lower still if you missed the date only slightly.

You do nothing

The threatened fine is set, and the same letter comes again with a new threat. The BfJ normally raises the amount step by step. Each further fine carries another EUR 100 fee (JVKostG no. 1211). This repeats until the accounts are filed.

You pay the fine but still do not file

This solves nothing. In the BfJ's words: “Die Zahlung eines früheren Ordnungsgelds hindert die Festsetzung weiterer Ordnungsgelder nicht” (paying an earlier fine does not prevent further fines). Unpaid amounts go to enforcement, up to a bailiff.

When an objection (Einspruch) makes sense

An objection must reach the BfJ within the same six weeks. The BfJ attaches an Einspruchsformular (objection form) to the letter and offers it on its website, in German only; the objection can also be sent electronically. The key point: the objection has no suspensive effect (§ 335(3) HGB). The six weeks keep running while the BfJ reads it. So if there is any doubt, file the accounts as well.

It can fit when the accounts were already filed on time, when the company had no duty for that year, or when the letter reached the wrong person. One real exemption is § 264(3) HGB for a subsidiary included in the group accounts of a parent based in the EU or EEA, with all its conditions met. A US or UK parent does not give this exemption.

It does not fit these reasons: no money, no business activity, liquidation, a tax extension from the tax office (Finanzamt), or an unfinished audit. § 335(1) HGB says unfinished preparation does not stop the procedure, and the duty lasts until the company is deleted from the commercial register.

Once a fine has been set, the next step is a complaint (Beschwerde) within two weeks, decided by the regional court for the BfJ's seat (§ 335a HGB). If you were prevented from acting through no fault of your own, for example by serious illness with a medical certificate, you can ask for Wiedereinsetzung (restored rights) within two weeks after the obstacle ends. These steps have short deadlines. A lawyer can act for you, and § 335(2) HGB also permits a tax advisor (Steuerberater) or Wirtschaftsprüfer.

If you are several years behind

Expect one procedure per year, each with its own letter, costs and Kassenzeichen. Filing 2024 does not stop the procedure for 2023. Prepare the oldest year first, because each year's opening balances are the closing balances of the year before. A year with a running letter still has to meet its six weeks.

Worked example for a micro GmbH with three open years. In our software, the first annual accounts on an account are free and each further micro-size year costs EUR 250, so EUR 500 in total. The register charges EUR 18.50 per micro filing (JVKostG no. 1420), so EUR 55.50, plus a yearly register fee of EUR 3 (no. 1410). BfJ costs and any fines come on top, and no software changes them. A Steuerberater may be the better choice if the books themselves are missing.

One more trap: if the BfJ has no data on your size, it can ask for your balance sheet total, revenue and staff numbers (§ 335(6) HGB). If you do not answer, it assumes you cannot use the size-based reliefs.

If you are a foreign managing director

The law addresses the members of the management body, so the letter can name you personally, and the company can get its own (§ 335(1) HGB). Fees arise separately per person. Living outside Germany changes none of this.

Post: the six weeks run from delivery, and mail may sit at a German address. Arrange now who opens it and sends you a scan the same day. A representative's fault counts as your own (§ 335(5) HGB), and courts have said a company must monitor the adviser it engages.

Identity: § 3a URV accepts a German eID, an eID from another EU state at assurance level “high”, or an identification method offered by the register operator. If you have none of these, ask early. The person who submits does not have to be you, so a German-based colleague or adviser can pass the check and file.

Language: the accounts must be in German and in euros (§ 244, § 325(1) HGB). The BfJ's forms and information sheets are in German too.

What our software does here, and what it does not

The annual accounts module prepares the German statements from your trial balance or bookkeeping, for the size class of that year, and produces the disclosure file. The interface can be English. The statements and the filing file stay German, as § 244 HGB requires. First annual accounts are free, once per account. After that, prices are EUR 250 micro, EUR 500 small, EUR 2,500 medium and EUR 5,000 large.

You submit the file yourself on the platform with your own access. We do not contest, reduce or waive a fine, we do not talk to the BfJ for you, and we do not read or translate your letter. The software gives no individual tax or legal advice.

Frequently asked questions

I got a letter from the Bundesamt für Justiz about my GmbH. Do I have to pay EUR 2,500 now?

No. Read the amount as a threat. You pay it only if you do not file or successfully object within six weeks of delivery. What you must pay now is the EUR 103.50 costs. These stay payable even if you file on time.

When does the six week period start if the letter sat at my office while I was abroad?

It starts when the letter is delivered to the address, not when you read it. Being abroad is not automatically an excuse. Wiedereinsetzung needs a situation where you were prevented through no fault of your own, and the request has a two-week limit once the obstacle ends.

Can I ask for more time?

No. The BfJ writes: “Eine Fristverlängerung für die Einreichung des Jahresabschlusses kann nicht gewährt werden.” A tax extension from the Finanzamt has no effect on this deadline.

My UG never traded. Why this letter?

A dormant UG must still file accounts each year until it is deleted from the commercial register. A micro UG can usually deposit only the balance sheet.

Can I just send the accounts to the Bundesamt für Justiz by post or e-mail?

No. The BfJ says that sending them to it is not possible and does not count. They must go electronically to the body that runs the Unternehmensregister, through publikations-plattform.de.

Primary sources and scope

Authoritative references for the key claims on this page. Check the current text before making a filing or accounting decision.