Starting with the 2025 reporting year, FACTA and CRS reports can be submitted exclusively through the BZSt online portal
For years, international standards for the automatic exchange of information on financial accounts have presented financial institutions with complex legal and technical requirements. With the transition of the reporting procedure for FATCA (Foreign Account Tax Compliance Act) and CRS (Common Reporting Standard) in Germany to the BZSt-Online.Portal starting with the 2025 reporting year, the need for action is becoming more urgent: The existing technical infrastructure is being replaced—adjustments to systems and processes are necessary to ensure continued compliance with reporting requirements.
The U.S. Foreign Account Tax Compliance Act (FATCA) is based on a bilateral agreement between the United States and Germany. Under this agreement, German financial institutions are required to identify accounts held by individuals subject to U.S. tax and to report the relevant information. The Common Reporting Standard (CRS) was developed by the Organization for Economic Cooperation and Development (OECD) and represents a global, multilateral standard for the automatic exchange of tax-related financial information.
Both sets of regulations share a common goal: to curb international tax avoidance and tax evasion by ensuring greater transparency regarding foreign accounts. Investors and family offices are familiar with these two disclosure requirements from KYC processes as part of their onboarding procedures for private equity funds.
Financial institutions headquartered or having a branch in Germany—including banks, certain insurance companies, and investment firms—are required to review their clients for potential tax liability in the United States or other CRS participating countries. If this review identifies reportable financial accounts or equity interests, this information must be reported annually to the Federal Central Tax Office (BZSt). The deadline for reporting is July 31 of the following calendar year.
Through the 2024 reporting year, returns were to be filed via the ELSTER portal “Mein BOP,” including the ELSTER bulk data interface (ELMA). Starting with the 2025 reporting year, returns may only be filed via the BZSt online portal.
The complete transition to the BZSt online.portal for FATCA and CRS reporting, effective for the 2025 reporting year, will entail technical changes and new internal compliance requirements for reporting financial institutions. This makes it all the more important to take action early, review internal processes, and establish all necessary technical requirements. This will help avoid reporting errors and penalties—and ensure a smooth transition to the new procedure.
