Reminder! Expiry of the transitional periods for entry in the transparency register

Have you already notified the beneficial owners of your legal entity to the Transparency Register? Not yet? Then it is high time you did!

With the amendments to the Money Laundering Act (Transparency Register and Financial Information Act) that came into force on 1 August 2021, the notification fictions previously enshrined in Section § 20 Abs. 2 GwG have been abolished without replacement. Thus, all legal persons under private law and registered partnerships are obliged to notify the transparency register.

Important to know: The transitional periods granted by the legislator for registration in the Transparency Register are gradually expiring this year.

Read the important information provided by our lawyer Neele Schröder.

Important facts about registration in the transparency register

When do the transition periods expire?

The transition period depends on the respective legal form of the company:

Aktiengesellschaften, KGaA, SE31 March 2022
GmbH, UG (limited liability), cooperatives, partnerships30 June 2022
All other cases, e.g. OHG, KG,31 December 2022


  • The transitional periods do not apply to those who were already required to register in the transparency register before the statutory changes.
  • They also do not apply in cases where registration is explicitly required (e.g. in the case of bridging assistance).

Unfortunately, our practical experience shows: many associations subject to registration assume that they benefit from the notification fiction and have therefore not yet registered. However, upon examination, it turns out that registration was already required since October 2017.

Therefore, do not wait until the transition period expires, but take action now!

What applies to the association?

The rule for associations is that they do not have to make the declarations themselves, as the data from the register of associations is automatically entered in the transparency register.

But every rule also has exceptions! If an association also has beneficial owners or if not all board members have a residence in Germany and German citizenship, then the association itself must become active and make the entry itself!

Failure to do so may result in heavy fines!

Anyone who misses the deadlines and does not comply with the notification periods must expect heavy fines. In the event of non-compliance with the new notification deadlines, fines can be imposed at the earliest one year after the respective notification deadline. Nevertheless, you should not exhaust these deadlines, but take care of the required notification in good time.

What must be reported?

The register is intended to record the beneficial owners of the associations specified in the law.
Beneficial owners are generally natural persons who either own the association or otherwise exercise significant control over the association.

Of the beneficial owners the following information is to be entered in the transparency register and kept up to date.

  • First and last name,
  • date of birth,
  • place of residence,
  • the nature and extent of the beneficial interest, and
  • All nationalities.

Transparency register and Corona

Many companies are suffering from the Corona pandemic and have claimed emergency aid over the past two years.

In this case, the associations no longer benefit from the transition periods. With the consequence that the notification of beneficial owners must already be made ahead of time. So do not wait to make the notification. We will be happy to help you with this!

My recommendation?

As a result of the abolition of the notification fiction, all companies must now disclose their beneficial owner.

The amendment of the law on the Transparency Register should be taken as an opportunity to review the required information, to make notifications and/ or, if necessary, to make corrections to existing entries.

If you have any questions, please contact me.
I will be happy to assist you!

Questions about the Transparency Register?

Neele Schröder

Neele Schröder
Focus commercial and company law
Authorised signatory ACCONSIS GmbH Rechtsanwaltsgesellschaft

Service phone
+49 89 547143
or by E-Mail