Transparenzregister.
The UBO filing every German entity owes.
Vollregister since 2021. €150,000 fines. Name-and-shame publication for late filers. Who, what, when, how.
Since the 2021 reform, the Transparenzregister is a Vollregister, a full register, not just a backup. Every German legal entity must file its beneficial owner (UBO) data under § 20 GwG, without undue delay after founding, and keep it current. Miss it and § 56 GwG fines start at €150,000, escalating to €1,000,000 or twice the transaction benefit for willful violation. Published on the register website, name and shame.
Who must register
GmbH, UG, AG, KGaA, SE, eingetragene Genossenschaft, eingetragener Verein, OHG and KG registered at HR, PartG, trusts with German nexus, foreign entities holding German real estate (since 2022). In short: nearly every structured entity.
Who is a UBO (§ 3 GwG)
Natural person ultimately owning or controlling the entity. § 3 GwG defines: >25% direct or indirect ownership, >25% voting rights, or comparable control. If no natural person clears 25%, the "fictive UBO" is the legal representative (typically Geschäftsführer).
Data filed
Name, date of birth, place of residence (city + country, not street), nature and scope of economic interest, citizenship. Does not include passport numbers or exact addresses.
Deadlines
New entity: without undue delay after founding (practically 2 to 4 weeks). Change in UBO: without undue delay after the change takes effect. Real-estate foreign entity: at acquisition.
Filing from abroad
Online at transparenzregister.de. Accept the legal-agent role via e-mail verification. Submit UBO data. Annual review confirmation. Non-resident UBOs can file remotely; no DE residency required.
Post-CJEU public access reality
CJEU ruling C-37/20 (November 2022, Luxembourg Business Registers) narrowed public access. DE currently requires "legitimate interest" for third-party lookups in parts of the register. UBO data is not fully open to the internet public post-ruling; journalists, NGOs and obliged entities still have access.
Fees
No direct filing fee beyond annual maintenance charge (~€20-30/year) from Bundesanzeiger Verlag.
Frequently asked questions
What is the German Transparenzregister?
The federal UBO register under §§ 18-26a GwG. Since 2021, a Vollregister, it holds UBO data for all German entities, not just a backup to other registries.
Does my newly-formed GmbH have to register?
Yes. Every GmbH, UG, AG and similar entity must file without undue delay after founding.
Who counts as a beneficial owner (UBO)?
Natural person with >25% ownership, voting rights, or comparable control. § 3 GwG.
What happens if no shareholder owns more than 25%?
The legal representative (Geschäftsführer) is the fictive UBO under § 3 (2) GwG.
How fast must I file after forming my GmbH?
"Ohne schuldhaftes Zögern" (without culpable delay). Practically 2 to 4 weeks is the maximum considered compliant.
What fines apply for late or missing UBO notifications?
Up to €150,000 for negligent violations. Up to €1,000,000 or twice the transaction benefit for willful. Published on the register (§ 57 GwG).
Can my UBO data be viewed by the public?
Access was narrowed by CJEU C-37/20 in November 2022. DE now requires legitimate interest for third-party access; obliged entities (banks, lawyers) retain access.
How do I file from abroad?
Online at transparenzregister.de, same procedure for DE and non-DE UBOs.
Does the Handelsregister shareholder list replace the Transparenzregister entry?
Since 2022, no. Mitteilungsfiktion was narrowed; most entities must file separately.
How much is the annual Transparenzregister fee?
Approximately €20-30 per year, invoiced by Bundesanzeiger Verlag. Verify current fee at filing.
What happens if my UBO changes after registration?
File an update without undue delay. Same rules as initial filing; same fine regime applies.
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