Tool 08 · Transparency register
Who stands behind your company?
For companies and their management: whether you must report to the transparency register, whom, and what happens if you do not.
Since August 2021 practically every company must report its beneficial owners itself — the former reference to the commercial register no longer suffices. Many still do not know this, and banks, notaries and business partners now check routinely. Anyone missing or wrongly entered risks a fine. Who actually counts as „beneficial owner" you can settle here in a few steps.
How it is checked. Under §§ 3, 19 and 20 of the German Money Laundering Act (GwG). A beneficial owner is anyone holding more than 25 % of the shares or voting rights or otherwise controlling the company — including indirectly via other companies. If there is nobody, the legal representatives count as beneficial owners. Rule-based AI system, no language model. Chains across several companies are difficult in the individual case; the result is a direction, not an entry.
Not here: trusts and trust-like arrangements (§ 21 GwG) — they need a separate review.
Choose the legal form and answer the questions. You see whether you must report, and whom.
A natural person holds — directly or via other companies — more than 25 % of the shares or voting rights.§ 3(2) GwG. Indirect holdings count where the person controls the intermediate company.
A natural person controls the company in another way — through voting agreements, trusteeship, veto rights or appointing management.§ 3(2) GwG. Control can exist below 25 % too.
The beneficial owners are already entered in the transparency register, and the details are still correct.Changes — for example after a share sale — must be reported without delay (§ 20(1) GwG).
Needed next: Legal form
Belongs to: Corporate & Transactions