Filing with the Unternehmensregister: How it works
Filing with the Unternehmensregister is digital, but not automatically simple. This guide explains obligations, process and costs, and shows how to get to the XML file with your AI assistant and Uregistry.
Publication vs. Deposit
All corporations and the GmbH & Co. KG must disclose. Micro companies may choose deposit instead of publication. Size also decides which documents to file.
Source: Publikations-Plattform, Annual Report Disclosure Rules
| Publication | Deposit | |
|---|---|---|
| For whom? | All companies obliged to disclose; mandatory from the small size class up | Micro companies only, by choice (§ 326 (2) HGB) |
| Who can see the data? | Everyone, freely searchable | Not searchable; any registered user gets a copy on request (€1.00) |
| Which documents? | Depending on size: balance sheet, notes, P&L, management report, audit opinion | Balance sheet only; no notes if the § 264 (1) s. 5 HGB details are shown below it |
| Fee | By size class | Same as publication |
Who must disclose?
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 Publicity Act (PublG), a company must disclose if on one balance sheet date and the two following it meets two of three criteria: total assets above €65m, revenue above €130m, more than 5,000 employees on average.
The obligation starts with registration, whether or not the company is already trading or aims for profit. Non-profit companies must disclose too. Sole traders and partnerships with a natural person as fully liable partner do not, unless the PublG applies.
Source: Publikations-Plattform, Annual Report Disclosure Rules
ESEF vs. HGB-XML in detail →What must you disclose?
The scope depends on the size class. A class applies if two of the three criteria are met on two consecutive balance sheet dates; after a formation or conversion, the first date is enough.
The §§ 267, 267a HGB thresholds are mandatory for fiscal years beginning after 31 Dec 2023. For fiscal years from 1 Jan 2023 they could be applied voluntarily, and only as a whole (Art. 93 EGHGB). Pure holding companies cannot be micro companies (§ 267a (3) HGB).
Source: Publikations-Plattform, Annual Report Disclosure Rules
| Company size | Balance sheet total | Sales revenue | Employees (annual average) |
|---|---|---|---|
| Micro | max. EUR 450,000 | max. EUR 900,000 | max. 10 |
| Small | max. EUR 7.5 million | max. EUR 15 million | max. 50 |
| Medium-sized | max. EUR 25 million | max. EUR 50 million | max. 250 |
| Large | more than EUR 25 million | more than EUR 50 million | more than 250 |
Which documents must be submitted for each company size?
Depending on the company size, the following disclosure facilitations can be claimed:
Source: Publikations-Plattform, Annual Report Disclosure Rules
| Size | Documents to be submitted |
|---|---|
| Micro | Balance sheet. No notes if the § 264 (1) s. 5 HGB details are shown below it. Deposit instead of publication possible. |
| Small | Balance sheet and notes; the P&L is not disclosed and the notes may omit P&L details (§ 326 (1) HGB) |
| Medium | Balance sheet, P&L, notes, management report, audit opinion, supervisory board report if any; § 327 HGB reliefs |
| Large | As medium, without reliefs; more documents depending on legal form |
When do you have to disclose?
Filing is due no later than twelve months after the balance sheet date (§ 325 (1a) HGB). The deadline cannot be extended; filing in time is enough. Capital-market companies have four months.
Special cases and the consequences of missing the deadline are on the deadlines, formats, costs page.
Where and how to file? The Bilanz-Navigator as a guide
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.
The Bilanz-Navigator does not settle whether a company falls under the ESEF format. That concerns domestic issuers, i.e. companies with securities admitted to a regulated market.
Source: Publikations-Plattform, The Unternehmensregister
Open the Bilanz-Navigator →Requirements for submission
Whoever files needs an account on the Publikations-Plattform. One account can have several contact persons.
Every person who files must complete a one-time electronic identification: by video, with the ID card (eID) or via the tax adviser platform. It costs a fee: €7.60 via the tax adviser platform, €12.00 via eID, €22.00 via video (KV 1441). Without identification, no filing is possible.
Companies that do not file, or file incompletely, receive a warning from the Federal Office of Justice with a six-week grace period. Fines range from €2,500 to €25,000; filing after the grace period reduces them to €500 (micro with deposit) or €1,000 (small). Capital-market companies face higher ranges.
The usual route: upload a PDF
Accounts usually exist as PDF or Office files. The Publikations-Plattform accepts them, but converts them into its format for a charge. There is no preview before publication.
Cost structure
The JVKostG fee depends on the size class: €18.50 for micro, €25 for small, €55 for medium-sized. PDF and Office add the conversion charge; every route adds the annual fee of €3 or €6 and the one-time identification.
The fee structure with sources is on the deadlines, formats, costs page; the cost calculator compares your figures.
With your AI assistant to the XML file
Uregistry is an MCP server: you connect it to your AI assistant, such as Claude or ChatGPT, and work in the chat.
The assistant clarifies legal form, fiscal year and size class with you; Uregistry shows thresholds and required parts with their sections of the HGB, and you confirm. Then the assistant transfers the accounts section by section and Uregistry checks each one formally. At the end you see a preview, compare it with the original and receive the XML file.
You upload the file yourself on the Publikations-Plattform. Uregistry checks form, not substance, and gives no advice.
Connect
connector in the assistant
Clarify
confirm the size class
Transfer
checked section by section
Preview
compare with the original
Upload
Publikations-Plattform
Conclusion
Disclosure is mandatory, the conversion charge is not. Filing XML following the schema means paying only the fee and seeing what will be published before you upload.
FAQ
Do these rules apply to all companies?
The disclosure obligation applies to corporations (GmbH, AG, UG), limited liability partnerships (GmbH & Co. KG) and cooperatives. Special company types such as credit institutions or insurance companies have their own regulations. The fee structure varies by company size.
Can subsidiaries be exempt from disclosure?
Yes, under § 264 (3) or § 264b HGB. There is no application to the Federal Office of Justice: the exemption applies by law once its conditions are met. One condition is that the exemption documents are disclosed under the subsidiary in the Unternehmensregister (fee €30).
When does the disclosure obligation begin for a company?
The obligation to prepare and disclose an annual report arises upon registration of the company, regardless of the business purpose and regardless of whether business operations have commenced. Non-profit companies are also subject to the disclosure obligation.
Without liability. Not legal advice. Verify binding requirements with the competent bodies or a qualified legal and tax advisor.