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Transparency register; inspection

The information recorded in the transparency register on the ownership structures - i.e. beneficial owners - of companies, foundations and similar structures can be viewed.

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Procedure details

Information on the beneficial owner (Section 19 GwG) of associations and other legal entities (Sections 20, 21 GwG) is made accessible via the Transparency Register in accordance with Section 23. The Transparency Register can only be accessed electronically via the Transparency Register website (see "Online procedure"). Inspection is only possible after prior online registration (see "Online procedure").

Inspection is carried out electronically via the user account of the respective inspecting party.

Access to the details of beneficial owners in the Transparency Register has been public since January 1, 2020 (Section 23 para. 1 sentence 1 no. 3 GwG).

In the case of legal entities under private law and registered partnerships (Section 20 para. 1 sentence 1 GwG) and trusts (Section 21 GwG), the following institutions and persons are permitted to inspect the register:

  • unrestricted access: supervisory and law enforcement authorities, the Central Office for Financial Transaction Investigations, the Federal Office of Administration, Bundesanzeiger Verlags GmbH, the authorities responsible pursuant to Section 13 of the Foreign Trade and Payments Act, the Federal Central Tax Office and the local tax authorities pursuant to Section 6 (2) No. 5 of the German Fiscal Code (AO), the authorities responsible for the investigation, prevention and elimination of threats, the courts and bodies pursuant to Section 2 (4) GwG
  • Access only on a case-by-case basis and within the scope of their customer due diligence obligations: Obligated parties pursuant to Section 2 (1) AMLA
    (e.g. goods traders who must comply with due diligence obligations to prevent money laundering)
  • restricted access: all members of the public (e.g. non-governmental organizations, journalists and private individuals). However, they can only find out the surname, first name, month and year of birth of the beneficial owner, the country of residence and all nationalities of the beneficial owner as well as the type and scope of the economic interest, unless the other information is already available from other public registers. Due to the ruling of the European Court of Justice of 22.11.2022 (Case C-37/20, C-601/20), members of the public must now justify the request for inspection when submitting the application and demonstrate a legitimate interest in the inspection.

At the request of the beneficial owner, the Bundesanzeiger-Verlag may fully or partially restrict access to the transparency register and the transmission of data, taking into account all circumstances of the individual case, due to overriding interests worthy of protection.

Examples: The beneficial owner is a minor or legally incapable; facts justify the assumption that inspection would expose the beneficial owner to the risk of becoming a victim of fraud, hostage-taking, etc.

An application for inspection of the Transparency Register is only possible via the Transparency Register website (see "Online procedure") (Section 23 para. 1 AMLA in conjunction with Section 5 para. 1 of the Ordinance on the Inspection of the Transparency Register (Transparency Register Inspection Ordinance - TrEinV).

Pursuant to Section 5 (2) TrEinV, the application must specify for which association pursuant to Section 20 (1) GwG or for which legal structure pursuant to Section 21 (1) and (2) GwG and for which period or date the inspecting party is requesting inspection of the transparency register.

  • Proof of identity
    • in the case of a natural person: e.g. a copy of a valid official identity document containing a photograph of the holder and fulfilling the passport and identity document requirement in Germany;
    • a copy of the documents referred to in section 1(1) of the Payment Account Identity Verification Ordinance;
    • a certificate provided for in section 12 (1) sentence 1 nos. 2 to 4 of the GwG
    • in the case of a legal entity: e.g. a copy of an extract from the commercial or cooperative register or of formation documents and
    • the valid identification code for legal entities.
  • Authorities: Confirmation that the inspection is necessary for the fulfilment of their legal duties.
  • Obliged parties according to § 2 GwG
    • Proof that he is an obligated person pursuant to Section 2 GwG and that the inspection is to be carried out in order to fulfill his due diligence obligations in one of the cases specified in Section 10 para. 3 GwG or
    • in the case of repeated requests, it is sufficient to demonstrate the authorization for inspection at the first inspection.
  • All members of the public may submit an application for inspection of the transparency register pursuant to Section 23 (1) sentence 1 no. 3 AMLA.
  • The office keeping the register may request further information to demonstrate the authorization if there is any doubt about the authorization of the person inspecting the data.
    At the request of the office keeping the register, the evidence may also be provided in the form of an affidavit.

The inspecting party or the person acting on behalf of the inspecting party may only use the electronic application forms of the Transparency Register to submit an application (see "Online procedure"). This is the only way to properly apply for access to the Transparency Register (Section 2 (5) TrEinV).

According to Section 2 (4) TrEinV, at least the following data must be provided to the Transparency Register upon registration:

  • if the inspecting party is a natural person,
    • first name and surname,
    • the e-mail address and telephone number and
    • the address and, if different, the billing address
  • if the recipient is a legal entity
    • the company name or the name of the non-natural person
    • the address of the registered office of the non-natural person and, if different, the billing address,
    • the first name and surname of the natural person responsible for registration and

the e-mail address and telephone number of the natural person responsible for registration.

Registration and entry in the transparency register itself is free of charge. In contrast, each legal entity subject to transparency requirements is charged an annual fee for maintaining the register. Since 2022, 20.80 euros have been due.

There are special conditions for associations:
Registered non-profit, charitable and church associations (e. V.) have been able to apply for a fee exemption since January 1, 2020. The prerequisite for this is that the associations submit a certificate from their tax office stating that they are pursuing their tax-privileged purpose. The Bundesanzeiger-Verlags-GmbH has provided a corresponding application form for this purpose, which enables an exemption from fees for the years 2021 to 2023 with just one application (see further links). However, a retroactive fee exemption for the years 2017 to 2019 is not possible, nor is a general exemption without submitting an application.

Section 60b of the German Fiscal Code (AO), which comes into force on January 1, 2024, will change the situation. On this date, the register of recipients of donations will be established at the Federal Central Tax Office. This register will also include the corporations that meet the requirements of Sections 51 to 68 AO (tax-privileged purposes), meaning that from this date, no fees will be charged to associations that are entered in the register of recipients.

The fees for

  • Inspection by retrieving information on the beneficial owner of certain associations: EUR 1.65 per document retrieved;
  • the printout of details of beneficial owners of certain associations: EUR 7.50 per printout plus the inspection fee: If a printout is certified, only the certification fee of EUR 11.20 per certification endorsement is charged in addition to the inspection fee.
  • Registration and identification of beneficial owners pursuant to Section 24 para. 2a GwG for the provision of information pursuant to Section 23 para. 8 GwG EUR 50.00 per registration of a beneficial owner for a legal entity.

If discrepancies are discovered in the course of the money laundering audit by obliged entities or in the course of inspection by authorities, these must be reported to the registrar immediately (Section 23a GwG).

Further information on the subject of discrepancies can be found under the link

https://www.bva.bund.de/DE/Das-BVA/Aufgaben/T/Transparenzregister/_documents/FAQ_transparenz_kachel.html

[Fact sheet of the Federal Office of Administration on the "Transparency Register - Questions and Answers on the Anti-Money Laundering Act (AMLA)" (as of May 5, 2023) under Part 1 Chapter E (Discrepancy reports)].

  • Transparency register; registration

    Certain information on the ownership structures - i.e. beneficial owners - of companies, foundations and similar structures is recorded in the transparency register. Affected parties must provide this information for entry in the transparency register.

Status: 27.05.2025
Editorially responsible for prodecure description: Bayerisches Staatsministerium des Innern, für Sport und Integration
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