From January 2025, numerous changes to reporting requirements under the German Foreign Trade and Payments Ordinance (AWV) will enter into force. Violations of reporting obligations constitute administrative offences and may be punished with fines of up to EUR 30,000 pursuant to Section 19(6) of the German Foreign Trade and Payments Act (AWG).
The following key areas are affected by the changes:
Reporting thresholds
- The reporting threshold for transaction reports will be increased to EUR 50,000 (previously EUR 12,500). This does not apply to reports by financial institutions relating to travel transactions or to interest and dividend payments on domestic securities (Section 67 AWV).
- The reporting threshold for stock reports concerning claims and liabilities will be increased to EUR 6 million.
- The reporting threshold for stock reports relating to assets held by residents abroad or by non-residents in Germany will likewise be increased to EUR 6 million.
Reporting deadlines
From January 2025, the reporting deadlines will be standardised.
From the reporting month of January 2025 onwards, the 7th working day will apply as the uniform deadline for submitting transaction reports, irrespective of the type of transaction.
For stock reports relating to claims and liabilities, the deadline will be standardised at the 10th working day.
The reporting deadline for positions in derivative financial instruments will be the 50th working day following the end of a calendar quarter.
The reporting deadline for direct investment positions remains unchanged.
Fields relating to key figures of the German group (total assets, annual turnover and number of employees), which were previously optional, will become mandatory.
New codes for crypto-assets
New codes will be introduced for crypto-assets. These can be found in the Deutsche Bundesbank’s code list.
Replacement of paper-based forms and submission format
The paper-based forms have been replaced in the statutory text by reporting characteristics (data points) in so-called reporting diagrams. From mid-2025, the new reporting diagrams are expected to be available in the General Statistics Reporting Portal (AMS), while the new XML schemas will become mandatory from summer 2026.
In addition, the reporting forms will be renamed:
- The K3 report will become Annex 2 DIREKA1.
- The K4 report will become Annex 3 DIREKA2.
- The Z5 report / Z5a report, sheets 1 and 2, as well as the Z5b report will become Annex 4 AUSWIB1.
- The Z4 report / Z8 report / Z11 report / Z14 report and Z15 report will become Annex 5 ZABILC1.
- The Z10 report will become Annex 6 ZABILC2.
- The Z12 report will become Annex 7 ZABILC3.
Travel-related reports
Payments relating to travel transactions made in banknotes and coins or foreign-currency travellers’ cheques will no longer have to be reported (affecting codes 010 and 011). The reporting obligation under Annex Z13 to the AWV will be abolished entirely.
Changes for maritime shipping
Income from maritime shipping received by residents will no longer be subject to reporting requirements. Income and expenditure from maritime shipping vis-à-vis non-residents must be reported pursuant to Section 67 AWV using the new reporting diagram ZABILC1. The reporting threshold of EUR 50,000 applies.
Further information is available on the website of the Deutsche Bundesbank at the following link:
https://www.bundesbank.de/de/service/meldewesen/aussenwirtschaft/aenderungen-im-meldewesen
By Heiko Panke
