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.

Regardless of legal form, special company types are also subject to disclosure, such as credit and financial services institutions, insurance companies, energy sector companies, telecommunications companies and issuers of investment assets. The obligation is governed by the respective special laws.

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:

The submission of documents for the disclosure of the annual report must take place at the latest within 12 months after the balance sheet date. If the financial year corresponds to the calendar year, the report for the 2023 financial year must be submitted to the Unternehmensregister by the end of 2024 at the latest.

A shorter disclosure period of 4 months applies to capital market-oriented corporations (§ 264d HGB). For issuers of investment assets under VermAnlG, a period of 6 months applies.

This list is not exhaustive. The disclosure periods can be found in the respective relevant legal regulations.

Since the DiRUG came into force, accounting documents and company reports for financial years beginning after 31.12.2021 must be submitted to the Unternehmensregister. Documents with a financial year beginning before 01.01.2022 must still be submitted to the Bundesanzeiger. Both disclosure media are operated by the Bundesanzeiger Verlag.

The Bilanz-Navigator, accessible from the Publikations-Plattform homepage, helps determine which disclosure medium to use.

Submission is made via the Publikations-Plattform (www.publikations-plattform.de) or via a software interface (webservice). Submission of documents in paper form is not possible.

Many companies still work with outdated assumptions about the submission process. Those unfamiliar with the current process should familiarise themselves with the new procedures.

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.

A typical process today: Documents are available as PDF or Office files. An order is created on the publication platform, the files are uploaded and, if they are not in the correct format, converted by the register.

The problem is not that companies lack documents. The problem is that existing documents are often not structured for submission. This is where conversion costs and manual effort arise.

The costs at the Unternehmensregister consist of two levels: the statutory fee under JVKostG and, depending on the format, additional conversion charges.

Those who deliver directly in XML format generally only pay the fee. For PDF, Excel, Word or scans, conversion charges are added: 1.75 cents per visible character and 20 euros per graphic, each plus VAT.

An increased rate of 2.50 cents per character applies to scans. A single scanned document can cause the entire order to be billed at the increased rate.

With our cost calculator, you can calculate your specific savings:

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.