The German reporting calendar for a payment firm
Germany’s defining feature is that two institutions collect, and the split is not intuitive. BaFin supervises; the Deutsche Bundesbank operates much of the collection infrastructure and owns the external-sector statistics outright. A firm that maps its German obligations to “our supervisor” will find half of them missing — and the half it misses is the half nobody sends reminders about.
1. The BaFin and Bundesbank split
| Counterparty | What it collects |
|---|---|
| BaFin | Supervisory returns, notifications and incident reporting |
| Deutsche Bundesbank | Much of the submission infrastructure, plus external-sector statistics under the AWV in its own right |
| FIU | Suspicion reporting through goAML |
| Transparenzregister | Beneficial-ownership data and the discrepancy duty |
2. The inventory
- Supervisory reporting — the return catalogue and the ExtraNet and portal infrastructure through which it is filed.
- AWV external-sector reporting — Z4 and the related payment reports, and the Z5 family of stock reports.
- Suspicion reporting under section 43 GwG — event-driven, with a registration duty that binds even if no report is ever filed.
- Transparenzregister — beneficial-ownership filings and the discrepancy-reporting duty on obliged entities.
- Major ICT incident reporting — event-driven, on the DORA clocks.
- ICT risk reporting under DORA, following the repeal of the previous national framework.
- Fraud reporting and the payment statistics that carry it.
- CESOP — quarterly cross-border payment data.
3. Registration duties that stand alone
Germany has more than one obligation that binds before any reporting does. The clearest is the goAML registration duty, which applies to obliged entities independently of whether a suspicion report is ever filed — a duty that is breached by inaction rather than by a late filing, and therefore one that generates no natural reminder.
The pattern repeats across this cluster and is worth building into any market-entry plan as a distinct workstream: enrolment obligations are not deadlines, they are states, and the control for a state is a periodic attestation rather than a diary entry.
4. Building it
Facts: an EMI licensed elsewhere in the EU establishes a German branch, and the group also owns a small German service company with no licence.
What the analysis produces: the branch drives the supervisory, AML and incident obligations. The service company — with no licence, no supervisor and no reporting team — is nonetheless a German resident, and therefore inside the AWV scoping question for both payment flows and stock positions. That entity is the one that ends up unassigned.
What the practitioner does: scopes the AWV question at group level across every German resident entity, not at licensed-entity level; and sources the AWV data from the ledger rather than from the payments system, since set-offs and compensations are in scope and never appear as payment instructions.
One further planning note: German filings and supervisory correspondence proceed in German, and the technical specifications are published in German. As in Italy, that makes translation capacity a reporting dependency rather than a convenience — particularly around a change like the AWV amendments that came into force in January 2025.
FAQ
Who collects what in Germany?
BaFin supervises and receives supervisory returns and notifications; the Bundesbank operates much of the submission infrastructure and owns the external-sector statistics under the AWV in its own right.
Do unlicensed group entities have German reporting duties?
They can. The AWV obligation attaches to residents rather than to supervised firms, so a German service or holding company can be inside it with no licence at all.
What binds before any filing does?
Registration duties. The goAML registration obligation applies to obliged entities whether or not a suspicion report is ever made.
Where should AWV data come from?
The general ledger rather than the payments system, because set-offs and compensations are within the definition of a payment and never appear as payment instructions.
5. Maintaining it
Two review cycles keep a German calendar current, and they run at different frequencies. The obligation inventory changes rarely and can be reviewed annually — new returns appear when the licence perimeter or the product set changes. The specifications underneath change far more often, and the AWV amendments in force from January 2025 are the current example: the obligation did not move, the forms and guidance did.
The practical consequence is that a German reporting procedure should cite dated versions of the material it relies on rather than referring to guidance generically. When a specification changes, the question “which version were we building against” has to be answerable for every affected reference period — and an undated citation makes that impossible to reconstruct after the fact.
Related: AWV reporting · The Spanish reporting calendar · The Italian reporting calendar
