Changes in the Reporting Requirements of the German Foreign Trade and Payments Ordinance: Simplifications in force since 1 January 2025

As of 1 January 2025, amendments to the reporting requirements of the German Foreign Trade and Payments Ordinance (Außenwirtschaftsverordnung, “AWV”) entered into force through the German Bureaucracy Relief Ordinance (Bürokratieentlastungsverordnung). These changes primarily introduce higher reporting thresholds and harmonize reporting deadlines.

The German Foreign Trade and Payments Ordinance imposes various reporting obligations on cross-border capital and payment transactions to the Deutsche Bundesbank (German Central Bank). These reporting obligations are aimed at statistically recording relevant transactions, as well as claims and asset for Germany’s balance of payments. Violations of the reporting obligations constitute administrative offences that can be punished by a fine of up to EUR 30.000 pursuant to Section 19 (6) of the German Foreign Trade and Payments Act (Außenwirtschaftsgesetz, “AWG”).

A. What you need to know: Key Changes at a Glance

I. Increase in Reporting Thresholds

The reporting thresholds have been raised for the first time since 2000 to reduce the administrative burden on businesses, private households and authorities. While German residents previously had to report foreign payments exceeding EUR 12.500 to the Bundesbank, this is now only required for payments exceeding EUR 50.000. In addition, interest payments on foreign bonds and money market instruments are now entirely exempt from the reporting requirements. Payments for the granting, taking out or repayment of loans with a maximum term of 12 months, as well as payments for the import, export or transfer of goods remain exempt from reporting obligations.

Reporting obligations for existing assets, claims and liabilities remain unchanged. However, claims and liabilities now only must be reported when they exceed EUR 6 million (previously EUR 5 million). Similarly, assets held by German residents abroad or by non-residents in Germany must be reported starting at EUR 6 million. In this respect, the threshold has been doubled; previously assets exceeding EUR 3 million already had to be reported. In addition, previously optional disclosures regarding the total balance sheet, the annual turnover and the number of employees are now mandatory for German companies. The Deutsche Bundesbank expects that these mandatory disclosures will allow for a more accurate assessment of the economic activities of German companies.

II. Reporting Requirement for Crypto Assets

Cryptocurrencies are now explicitly included in the reporting obligations to eliminate ambiguities. While such transactions in certain cases were already subject to reporting obligations prior to the amendment, this clarification aims to provide additional transparency and prevent time-consuming inquiries. Furthermore, four new identification codes (804, 814, 824, and 834) have been introduced to enable a more accurate classification of crypto assets within the balance sheet positions.

III. Harmonisation of Reporting Requirements and Adjustment of Reporting Forms

Moreover, reporting deadlines have been harmonised, simplifying the reporting process. Previously, the reporting deadlines for the various reportable transactions differed significantly in some instances. Therefore, the reporting process was confusing for companies, requiring constant monitoring of potentially relevant deadlines. From now on, the seventh working day of the month will be the unified reporting date for transaction reports. As regards outstanding claims and liabilities, the tenth working day of the month will be the relevant date. An exception exists for derivative financial instruments. Here, the fiftieth working day after the end of a calendar quarter will be decisive. However, the reporting deadline for direct investments remains unchanged. Such reports must be submitted electronically to the Deutsche Bundesbank once per year by companies preparing financial statements, at the latest six months after the balance sheet date. In the case of companies not preparing such statements, reports must be submitted by 30 June of the following year.

In addition, reporting forms will also be adjusted. Fields that were previously optional regarding key figures of a German company, such as the balance sheet total, annual turnover and employee numbers, are now mandatory fields for reporting on foreign direct investments. Moreover, paper-based forms under the German Foreign Trade and Payments Ordinance, which were replaced by electronic data set formats in 2013, will now be permanently removed from the German Foreign Trade and Payments Ordinance. By mid-2025, new survey templates will be available at the General Statistics Reporting Portal (Allgemeines Meldeportal Statistik, “AMS”), while new XML schemas will become mandatory from summer 2026 on.

B. Conclusion

The newly introduced changes to the reporting system of the German Foreign Trade and Payments Ordinance ease the burden on companies in managing the reporting requirements, particularly through the harmonisation of deadlines. In addition, private individuals and small and medium-sized companies can benefit significantly from the higher reporting thresholds. Nevertheless, these changes also mean that companies will need to adapt to revised reporting forms.