On January 1, 2025, a number of significant amendments to the Foreign Trade Regulation (AWV) will take effect. The amendments are intended to reduce the administrative burden on entities subject to reporting requirements while increasing transparency and oversight in international payments.
1. Raising the reporting thresholds
Pursuant to Section 67 of the AWV, payments received from abroad and payments sent abroad are generally subject to a reporting requirement to the German Bundesbank. For these transactions, the reporting threshold has been raised from the previous 12,500 EUR to 50,000 EUR. This applies to both individuals and businesses.
For reporting of receivables and liabilities of companies pursuant to Section 66 of the AWV (excluding private individuals), the new threshold of 6 million EUR applies. Previously, this threshold was 5 million EUR. At the same time, the threshold for reporting the assets of German residents abroad and of foreign nationals in Germany pursuant to Section 64 et seq. of the AWV was raised from 3 million EUR to 6 million EUR as well. This is because receivables, liabilities, and assets abroad must always be reported in their entirety. The term “assets” also includes equity interests in foreign companies and funds. In addition to the reporting threshold of 6 million EUR, which is now in effect, the additional reporting threshold remains unchanged: a 10% ownership stake or voting rights share in foreign companies.
These reporting requirements typically apply to international corporate transactions and significant fund investments.
2. Harmonization of Reporting Deadlines
The reporting deadlines have been standardized and changed from calendar days to business days. Transaction reports must now be submitted by the seventh business day of the following month, regardless of the type of transaction, in accordance with Section 71(6) of the AWV. Reports on holdings of receivables and liabilities must be submitted by the tenth business day of the following month, in accordance with Section 71(3) of the AWV. Reports on holdings of derivative financial instruments must be submitted by the 50th business day following the end of the calendar quarter, in accordance with Section 71(4) of the AWV. For holdings resulting from direct investments, the reporting deadline remains unchanged.
3. Revisions to the reporting forms
The Bundesbank’s reporting forms have been updated and renamed. The new forms are designed to streamline data entry and processing. In particular, the requirements for formats and data structure have been updated to reduce the administrative burden and improve compatibility with modern IT systems.
The new regulations introduced specific metrics for crypto assets, enabling better categorization and more accurate tracking of transactions involving digital currencies. This applies in particular to reports that were not previously standardized, which now allow for more transparent collection and processing.
When reporting the foreign assets of domestic companies, the previously optional disclosures regarding the German group’s total assets, annual revenue, and number of employees are now mandatory. As a result, reporting requirements are becoming more stringent, leading to increased administrative burdens for German legal and tax departments within companies.
4. Conclusion
The amendments to the Foreign Trade Regulation, effective January 1, 2025, are intended to significantly reduce the administrative burden on businesses and government agencies. By raising the reporting thresholds and standardizing reporting deadlines, the reporting requirements will be eased, particularly for smaller businesses and private households. At the same time, the new regulations—especially in the area of cryptocurrencies—will ensure greater transparency and oversight in international payments.
Entities subject to reporting requirements should familiarize themselves with the changes well in advance and adapt their processes to the new reporting thresholds, deadlines, and forms. We are happy to provide further information and personalized advice.
We invite you to read our previous post on these reporting requirements in the context of M&A transactions.
