Millionenkredit reporting under § 14 KWG ends in 2026

A German reporting regime that has run since the 1930s is being switched off, and the date was chosen so that one last quarter-end never arrives. The Millionenkreditmeldung under § 14 KWG — the quarterly return through which German institutions tell the Bundesbank about every borrower owing a million euro or more — ends on 30 December 2026. Around 3,200 reporting entities are affected. This piece sets out what the return is, how it differs from the large-exposure regime it is constantly confused with, what the Bundesbank sends back, what the law that abolishes it actually did, and which obligations survive untouched.

1. What a Millionenkredit is

A Millionenkredit under § 14 of the Kreditwesengesetz exists where the credit granted to a single borrower, or to a group of connected borrowers, amounts to at least EUR 1.0 million. Institutions in scope notify the Deutsche Bundesbank’s Evidenzzentrale — its central clearing point for these credits — on a quarterly basis, for each observation period.

The reporting population is wider than “banks”. It takes in credit institutions, financial services institutions falling within the categories listed in § 1(1a) sentence 2 nos. 4, 9 and 10 KWG, financial institutions within the meaning of article 4(1)(26) of Regulation (EU) No 575/2013 — factoring undertakings prominently among them — and entities covered by § 2(2) KWG. A parent undertaking also reports the borrowers of the group entities attributed to it, so the return consolidates upward rather than stopping at the legal entity that booked the loan.

The aggregation unit is not the contract and not the legal entity. It is the Kreditnehmereinheit, the borrower unit, built through the cross-reference in § 19(2) KWG, which treats several debtors as one borrower where the prescribed links between them exist. A million euro spread across four companies under common control is a Millionenkredit; the same amount across four unconnected customers is not.

2. Millionenkredit is not Großkredit — and only one of them is ending

The two German large-credit concepts sit next to each other in the same regulation and are routinely conflated. They are different instruments with different thresholds, different legal bases, and now different futures.

The distinction is worth holding precisely because the abolition is easy to over-read. A large exposure is about whether you are too concentrated in one name. A Millionenkredit is about whether the market is too concentrated in one name — a question no single lender can answer from its own books, which is exactly why the Bundesbank collected it centrally.

3. How the return works today

A submission has two halves that travel by different routes, which is the operational quirk most newcomers to the return trip over.

Betragsmeldungen — the numerical amount reports — are transmitted electronically, either through the Deutsche Bundesbank’s ExtraNet or through a capture platform (Erfassungsplattform). Stammdaten — the master data on individual borrowers and on borrower units — follow a different and markedly older path: they are submitted in paper form, in accordance with Annexes 2 to 6 of the Groß- und Millionenkreditverordnung (GroMiKV), the regulation supplementing the large-exposure provisions of the CRR and the million-credit provisions of the KWG.

Reporting is quarterly, with submission deadlines falling on the 15th business day of January, April, July and October — which places the reference dates at the four quarter-ends.

4. The Evidenzzentrale sends something back

The return is not a one-way filing, and this is the feature that makes its abolition a real change rather than pure administrative relief. The Evidenzzentrale aggregates the individual submissions of every reporting lender, calculates each borrower’s total debt across all of them, and notifies each participating lender of its own borrowers’ aggregate indebtedness.

What comes back covers the borrower’s total indebtedness, the total debt of the borrower unit, the number of institutions participating in lending to that borrower, and data on the forecast probability of default as reported by lenders. A German lender therefore learns two things it cannot derive from its own systems: how many other institutions are lending to the same name, and how the rest of the market grades that name’s default risk.

§ 19(2) KWG constrains what may be disclosed: where several debtors are treated as a single borrower, individual debtor information is disclosed only to those institutions that financed them. The aggregate is shared; the attribution is not.

5. What the law actually did

Bundesbank and BaFin jointly proposed discontinuing the million-credit reporting regime, in announcements published on 25 August 2025. Their reasoning was proportionality: the double burden in reporting was no longer justified, because the supervisors now obtain the necessary information from other sources. Two were named — the ECB’s granular credit data statistics, AnaCredit, and the securities holdings statistics.

The legislative vehicle was the Standortfördergesetz (StoFöG), the act promoting private investment and the financial centre. The Bundesrat adopted it on 30 January 2026, and BaFin confirmed the abolition the same day; it was promulgated in the Bundesgesetzblatt 2026 I no. 33 of 9 February 2026. The discontinuation takes effect on 30 December 2026, and around 3,200 undertakings currently subject to the obligation fall out of scope.

The chosen date rewards a second look. Millionenkredit reference dates fall at quarter-ends, and 30 December sits one day before the 31 December quarter-end. The effect is that the fourth-quarter 2026 reference date never arises, which leaves 30 September 2026 as the last ordinary Millionenkredit reference date — and the January 2027 submission window, which would otherwise have carried it, simply does not open. Firms should confirm the final submission mechanics against Bundesbank communications for their own reporting profile, but the shape of the wind-down follows directly from the date.

6. Why AnaCredit could absorb it

The substitution argument rests on granularity. AnaCredit collects loan-by-loan data on credit granted to legal entities from a debtor total commitment of EUR 25,000 — two orders of magnitude below the million-euro threshold, and with far more attributes per exposure. Anything the million-credit return could show about a corporate borrower, the European collection can show in more detail.

The substitution is not total, and the gap is worth naming because it explains what German supervisors have accepted losing. AnaCredit covers credit to legal entities; lending to natural persons remains outside it. Nor is the Evidenzzentrale’s distinctive product — the return notification telling each lender the borrower’s market-wide total, the count of lenders and the market’s default-probability view — a feature of AnaCredit, which flows to the central bank rather than back to the reporting institutions in that form. Institutions that used the Rückmeldung as a credit-monitoring input, rather than treating the return as pure compliance overhead, lose that input.

7. Three scenarios for the wind-down

The factoring company that assumed this was a bank rule. A factoring undertaking treats § 14 KWG as applying to credit institutions and never established a reporting line. Facts to rule: financial institutions within article 4(1)(26) CRR — factoring undertakings expressly among them — are in the reporting population. What the reporting owner does: confirm historical compliance for periods still open rather than assuming the coming abolition cures it, because the obligation runs until 30 December 2026 and sanctions attach to past periods regardless of the end date.

The group that decommissions the wrong pipeline. A banking group reads “large credit reporting abolished” and schedules its Großkredit reporting for retirement alongside the Millionenkredit feed. Facts to rule: only the § 14 KWG million-credit return ends; article 394 CRR reporting and the 25% Tier 1 cap are unaffected. What the change owner does: separate the two work items explicitly in the decommissioning plan, and keep the CRR feed, its data lineage and its controls in production.

The credit team that lost its market view. A mid-sized lender’s watchlist process uses the Evidenzzentrale notification — specifically the count of lenders to a name — as an early indicator of a borrower gearing up across the market. Facts to rule: that notification ends with the regime, and AnaCredit does not return an equivalent to reporting institutions. What the credit risk owner does: identify every downstream process consuming the Rückmeldung before the last one arrives, and decide deliberately what replaces each — rather than discovering the dependency when a quarterly file fails to land in 2027.

8. What to do, today

• Keep filing. The obligation runs until 30 December 2026, and an announced abolition is not an amnesty for open periods.
• Write the two regimes into the decommissioning plan as separate line items, so no one retires article 394 CRR reporting by association.
• Trace every downstream consumer of the Evidenzzentrale notification — watchlists, limit reviews, PD benchmarking — and decide what replaces each before the last one lands.
• Confirm your entity type against the reporting population rather than against the word “bank”; factoring undertakings and several categories of financial services institution are in scope.
• Check that the Kreditnehmereinheit logic in your reporting stack is retired with the regime and not silently reused elsewhere, since § 19(2) grouping also feeds the large-exposure calculation that survives.
• Confirm the final submission mechanics for your reporting profile against Bundesbank communications, and plan on 30 September 2026 being the last ordinary reference date.
• Redirect the freed capacity to AnaCredit data quality rather than banking it — the supervisory expectation is explicitly that AnaCredit now carries the load.
• If you are a payment or e-money institution without a lending book in Germany, confirm you were never in the population before scheduling any work at all.

Related: AnaCredit across national central banks · German supervisory reporting — Bundesbank ExtraNet · AnaCredit phases 1, 2 and 3 · AnaCredit for payment firms