Transparency register

Transparenzregister: Germany's transparency register for GmbH, UG and foreign-owned companies

The Transparenzregister is the German register of the people who ultimately own or control a company, called wirtschaftlich Berechtigte (beneficial owners). Every GmbH, UG, AG and other private legal entity, and every registered partnership, must report them “unverzüglich” (without undue delay) under § 20 GwG, whatever its size and also when the parent is abroad. Filing itself is free at transparenzregister.de. The register charges EUR 19.80 per year for keeping the entry.

Last reviewed: 2026-11-02

I got a bill or an e-mail about the Transparenzregister. Is it real?

Real: a yearly fee notice from the body that runs the register, Bundesanzeiger Verlag GmbH, for EUR 19.80 per year since 2024. Older years cost less (EUR 2.50 up to 2019, EUR 4.80 for 2020, EUR 11.47 for 2021, EUR 20.80 for 2022 and 2023), so a first notice can cover several years. The fee applies even if you never filed, and also in liquidation or insolvency.

Not official: offers that charge money for “the entry” or threaten a fine unless you pay them. In January 2020 the Federal Ministry of Finance warned about e-mails from a sender calling itself “Organisation Transparenzregister e.V.”. They pointed to a look-alike web address, suggested that registration costs money and threatened fines. The ministry's answer: “Die Eintragungen in das Transparenzregister sind kostenlos” (entries in the transparency register are free of charge). Treat any later message with the same pattern in the same way.

How to check: the Federal Office of Administration (Bundesverwaltungsamt, BVA) says the entry is made only at www.transparenzregister.de and is free. Type that address yourself. Do not use a link from the message.

To be clear about ourselves: we are a private software company, not the register. Our filing package, described below, costs money for most users and is optional. You can file on the register site without us.

Who must file, and who does not

Must file: GmbH, UG, AG, SE, KGaA, cooperative, registered association, foundation under private law, OHG, KG including GmbH & Co. KG, partnership company (PartG), registered GbR (§ 20(1) GwG).
No size limit: a one-person UG that never traded has the same duty as a group parent.
No duty: a sole trader, and a GbR that is not registered, because neither is a legal entity or a registered partnership.
German branch of a foreign company: no duty for the dependent branch, according to the BVA's FAQ.
Foreign company itself: only in the real estate cases of § 20(1) sentence 2 GwG, for example when it holds or agrees to buy property in Germany.
The old rule that a shareholder list in the commercial register counted as the report applied until 31 July 2021. The transition period for GmbH and UG ended on 30 June 2022 (§ 59(8) GwG, confirmed in the BVA's FAQ). If you never filed, you are late now.

Who counts as beneficial owner through a parent company

Only natural persons count. A parent company is never the final answer.

Under § 3(2) GwG, a beneficial owner is any natural person who directly or indirectly holds more than 25 percent of the capital, controls more than 25 percent of the votes, or has comparable control. Exactly 25 percent is not enough. For chains, the test has two steps. Step 1: does a company hold more than 25 percent of your GmbH? Step 2: does a natural person control that company, using the concept of dominant influence in § 290(2) to (4) HGB, which usually means a majority of the votes?

Do not multiply percentages. The BVA's own example: GmbH 2 holds 26 percent of GmbH 1. Person A has 60 percent of the capital and 40 percent of the votes in GmbH 2. Person B has 40 percent of the capital and 60 percent of the votes. Both are beneficial owners of GmbH 1, although 60 percent of 26 percent is only 15.6 percent.

Worked example with a foreign parent: a UK Ltd holds 100 percent of your German GmbH. Person X holds 70 percent of the Ltd and person Y holds 30 percent, with normal voting rights. X is reported. Y is not, because Y has no dominant influence over the Ltd, unless an agreement gives Y comparable control. If the UK Ltd held only 25 percent of your GmbH, step 1 would fail and nobody would be reported through it.

Where people live does not matter. The BVA writes: “Es sind also auch ausländische wirtschaftlich Berechtigte zu melden” (foreign beneficial owners must be reported too). They and the shareholders must give the company the data (§ 20(3) GwG). If they do not, the company must ask its known shareholders and document the request (§ 20(3a) GwG).

If no natural person meets the test after a full check, the legal representatives count as deemed beneficial owners (fiktiv wirtschaftlich Berechtigte, § 3(2) sentence 5 GwG). For a GmbH that means the managing directors, including one who lives abroad, and a change of director then means a new report. Stock-listed parents, trusts and voting pools have special rules. Ask a lawyer or Steuerberater about these.

Login, filing and changes

Create an account at transparenzregister.de (“Registrieren”, then confirm your e-mail). In the Einreichungsassistent (filing assistant), enter the company with legal form, register court, register number and seat. Then enter each beneficial owner with the five items in § 19(1) GwG: first and last name, date of birth, place of residence, nature and extent of the interest, and all nationalities. Place of residence means the main home. Send it and keep the confirmation.

Deadlines: there is no day count. “Unverzüglich” means without culpable delay, so treat it as days, not months. The same applies to every change: a share sale, a capital increase that shifts the percentages, a new home address, or a new deemed owner. A report must also cover the whole period since the duty began, according to the BVA, so a late first report does not start today.

Banks, notaries and other obliged entities compare your entry with what they know. If it differs, they must file a discrepancy report (Unstimmigkeitsmeldung).

Extract (Auszug): who can see what

The register is not an open list. Under § 23(1) GwG, inspection is open to authorities and courts, to obliged entities such as banks for their due diligence, and to anyone who proves a legitimate interest. That last group sees less: name, nature and extent of the interest, month and year of birth, country of residence and nationalities. Everyone must register online first (§ 23(4) GwG).

Viewing costs EUR 1.65 per retrieved document, and a printed copy sent by post costs EUR 7.50 (TrGebV schedule nos. 2 and 3). If a bank asks for one, get it from the register itself. A beneficial owner can ask for restricted access in cases of serious danger, or for a minor (§ 23(2) GwG), but this does not bind banks and notaries.

What the fines really are

Not filing, filing late or filing wrongly is an administrative offence. The legal limit is EUR 100,000 for recklessness and EUR 150,000 for intent (§ 56(1) GwG). For serious, repeated or systematic cases it is EUR 1 million or twice the economic benefit (§ 56(3) GwG). The BVA is the authority. It says a reminder before a fine is not part of the law, but it also decides case by case whether a fine is needed.

The numbers people actually meet come from the BVA's Bußgeldkatalog of 5 July 2021: base amount × factor I × factor II × factor III. The base amount is EUR 1,000 for no report, EUR 500 for a wrong one, EUR 200 for a late or incomplete one. Factor I is 1 for recklessness, normally 1.5 for intent. Factor II for a company up to EUR 6 million balance sheet total is the total divided by 6,000,000, minimum 0.01. Factor III is normally 3, and can fall if you make up the missed report.

Worked example: a GmbH with a EUR 600,000 balance sheet total never reported, through recklessness. EUR 1,000 × 1 × 0.1 × 3 = EUR 300. A GmbH with EUR 30 million: factor II is about 2.59, so about EUR 7,760. A very small company with EUR 60,000: the formula gives EUR 30, and the minimum of EUR 50 applies. The catalogue is a guideline, and the BVA can depart from it.

For many foreign groups the larger risk is publicity. Final fine decisions are published on the authority's website with the name of the company or person, normally for five years (§ 57 GwG).

What our module does, what it costs, what it leaves to you

The Transparenzregister module works out your beneficial owners from the shareholdings you enter. You can take a proposal from the commercial register data and confirm it. For a shareholder that is a company, it records the seat country and the person who controls it, including control by votes or other grounds. It names missing data for each person, and it tells you when the data has gaps and a deemed owner cannot be assumed yet. The determination and the checks are free.

The filing package is a German PDF to work through field by field in the register's assistant. The first package per workspace is free. After that it costs EUR 29 once, with no subscription. The binding price appears when you order. The interface is available in English.

You file yourself. The module sends nothing to the register, but it can archive the submitted version as your proof. It does not pay the yearly EUR 19.80, and it gives no legal advice. In the current form you enter one level of company shareholder and its controlling person. For a chain of several companies or a trust, ask a lawyer or Steuerberater to confirm the result. The module is not offered for sole traders and unregistered GbRs, because they have no duty.

Frequently asked questions

My GmbH has one shareholder, who is also the managing director. Do I still file?

Yes. The old exception for shareholder lists ended in 2021. You report yourself as beneficial owner with your percentage. The entry takes minutes, but it must exist.

I got an invoice for EUR 19.80 from Bundesanzeiger Verlag. Should I pay?

That amount matches the official yearly fee in the TrGebV schedule, and Bundesanzeiger Verlag runs the register. Check that the sender is Bundesanzeiger Verlag, that the company name is yours and that the years listed make sense. An e-mail or invoice from another sender that charges for “the entry” is not this fee.

Our parent is in the US and owns 100 percent. Who do we report?

The natural persons who control the US parent, usually through a majority of votes, wherever they live. If the parent's owners are spread out and nobody has control, the German company's managing directors can become deemed owners after a full check. A stock-listed parent needs its own check.

What is the deadline for a new UG?

The law sets no number of days. Report without undue delay after the company is entered in the commercial register. Do it in the same week as your other first steps.

We never filed and it has been years. What now?

File now, covering the whole period. Making up the report can lower factor III in the BVA's fine formula, though nobody can promise that no fine follows. If the BVA has already written to you, speak to a lawyer before you reply.

Primary sources and scope

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