Filing with the Unternehmensregister: How it works

Whether a annual report must be published or only deposited depends on the size and legal form of the company. The company size also determines which specific data must be disclosed.

Companies of the following legal forms must disclose accounting documents and company reports:

Corporations such as AG, KGaA, SE, GmbH and UG (limited liability), registered cooperatives (eG), limited liability commercial partnerships without a natural person as fully liable partner (e.g. GmbH & Co. KG, UG & Co. KG), mutual insurance associations (VVaG) and domestic branches of corporations headquartered in another state.

Special company types such as credit and financial services institutions, insurance companies or energy and telecommunications companies are subject to disclosure under their respective special laws. Under the Publizitätsgesetz, other companies may also be subject to disclosure if they meet certain size criteria.

Under the Publizitätsgesetz, companies are generally subject to disclosure if they meet 2 of the 3 following criteria in 3 consecutive financial years: balance sheet total over EUR 65 million, sales revenue over EUR 130 million, average of over 5,000 employees.

The obligation to prepare and disclose an annual report arises upon registration of the company, regardless of whether business operations have commenced or whether profit-making intent exists.

The extent to which you must disclose accounting documents depends, among other things, on the size of your company. 2 of the 3 criteria must be met at the balance sheet dates of two consecutive financial years.

The thresholds pursuant to §§ 267, 267a HGB (new version) apply to financial years beginning after 31.12.2022:

Depending on the company size, the following disclosure facilitations can be claimed:

As a general rule, the documents must be submitted no later than 12 months after the balance sheet date. A shorter deadline applies to capital-market-oriented capital companies.

The exact deadlines, legal bases and special cases are summarised on the deadlines, formats, costs page.

Which disclosure medium applies and whether disclosure or deposit is relevant is clarified by the Bilanz-Navigator on the Publikations-Plattform. It guides the assignment based on your individual case — the requirements of the register-leading body remain authoritative.

Since the DiRUG (Act Implementing the Digitalisation Directive) took effect, financial statements and company reports for financial years beginning after 31 December 2021 must be transmitted to the Unternehmensregister; for financial years beginning before 01 January 2022 the Bundesanzeiger remains the disclosure medium. Both media are operated by Bundesanzeiger Verlag.

Transmission is electronic, via the Publikations-Plattform (www.publikations-plattform.de) or via a software interface (web service). Paper filing is not provided for.

Note: the Bilanz-Navigator clarifies the assignment within HGB disclosure, not the separate question of whether a company is subject to the ESEF regime (iXBRL) — that is a matter for capital-market-oriented issuers.

To submit data to the Unternehmensregister, registration on the Publikations-Plattform is required. A one-time registration is sufficient, even if you publish for several subsidiaries or as a submitter for third parties.

Additionally, since the DiRUG, all submitters of accounting documents must complete a one-time electronic identity verification. Without prior identification, no annual report can be submitted to the Unternehmensregister. Video-supported methods, eID (identity card with online function) and identification via tax advisor platform are available.

In the event of violations of the disclosure obligation, the Bundesamt für Justiz initiates administrative fine proceedings. Fines for omitted or incomplete disclosure range from at least EUR 2,500 to a maximum of EUR 25,000. For issuers and capital market-oriented companies, an increased fine framework applies.

Today, documents mostly exist as PDF or Office files and must first be converted into the required XML — which creates effort and can trigger additional costs.

The costs consist of the statutory fee under JVKostG and, depending on the format, additional conversion-related charges. Submitting directly in XML avoids these surcharges.

The detailed fee structure with examples is on the deadlines, formats, costs page; the cost calculator compares your specific parameters.

Uregistry helps teams move from existing reporting documents to a structured XML-first workflow.

The process: Upload PDF, Excel or Word → automated extraction and structuring → XML generation → review and correction → submission.

Depending on document complexity, this runs either as a self-service flow or with additional expert review.

Publication and deposit are digital processes, but that does not make them automatically efficient. Starting from scattered PDFs or Office files risks avoidable conversion costs and manual effort.

A structured XML-first workflow makes submission more predictable, less manual and often more cost-effective.