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Soon significantly increased effort for reports to the German transparency register: Update on the expert hearing in the Finance Committee of the German Bundestag

We previously reported here that the German government published a draft of the Transparency Register and Financial Information Act (TraFinG) on February 10, 2021, and what new responsibilities will arise for those responsible for all German companies, including companies under civil law (, as a result of the transformation of the transparency register into a full register.

The draft law was the subject of a hearing in the Bundestag's Finance Committee on April 26, 2021. Although it was welcomed by the majority of the experts, it was also questioned critically in several contributions. What was at stake?

The draft stipulates that all data relating to the beneficial owner, which has so far resulted from other registers, must be actively reported again to the transparency register. In effect, this means that data must be reported twice. This duplication of effort can be avoided and the data can also be recorded more reliably if the so-called once-only principle were to be implemented. This proposal has already been made by the representatives of the notaries and by the Federal Council.

What is the Once-Only Principle?

The once-only principle is intended to ensure better linkage of existing register data with the transparency register and to automatically transfer the required data, where available, from the commercial register or register of associations, for example, to the transparency register. This could also continue the current trend toward digitization.


It is to be hoped that this suggestion will still be followed in the legislative process, as this would significantly reduce the management effort. However, it is then important on the part of the management to ensure beforehand that the data available in the previous registers, with which it was previously possible to invoke the notification fiction, are correct and complete. This is all the more important because if the suggestion is not implemented, the planned deadlines can only be used if the data is complete and correct. Otherwise, one must already actively report to the transparency register in August 2021.


Tatjana Schroeder

Dr. Tatjana Schroeder

Partner (Of Counsel)

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