ED17 - Transparency Register: Carrying out the notification via transparenzregister.de

Problem

The determination is complete (ED04, ED12) — but the transmission to the Transparency Register is a separate procedural step with pitfalls of its own:

• Where and how exactly? The notification is made electronically via www.transparenzregister.de — operated by the Bundesanzeiger-Verlag as the register-maintaining body. Paper is not provided for.
• Initial notification or follow-up filing? Changes must be submitted as a follow-up filing — not as a correction (that would overwrite the entry instead of supplementing it). Anyone who confuses the two destroys the chronological history in the register.
• Validity date: The notification must cover the period since 01.10.2017 (or the later formation) without gaps. The decisive date is the one on which the constellation with the current beneficial owners first existed — if it reaches back that far, "before 01.10.2017" may be specified.
• Fees overlooked: An annual fee is charged for being entered in the register (from fee year 2024: 19.80 EUR plus VAT) — it accrues even when (previously) no active notification was made because of the notification fiction. The invoice typically arrives together with the publisher's annual financial statement disclosure invoice — and is sometimes overlooked there.
• Without undue delay: The transmission must be made without undue delay (§ 121 Abs. 1 S. 1 BGB). The Federal Office of Administration does not as a rule understand this to mean: wait for the commercial register entry first and then notify.

Core message

Execution is a second, separate step after the determination — with its own artifact and its own proof:

1. Electronic transmission: All details (ED04: name, date of birth, place of residence, all nationalities, nature and extent of the economic interest, validity date) are transmitted via the portal of the Transparency Register to the register-maintaining body.
2. Pre-incorporation company (i. Gr.): notification under "Sonstige Rechtsgestaltungen" with the name suffix "i. Gr."; after the commercial register entry, the entry (commercial register number, register court) is subsequently submitted as an amendment notification — the beneficial owner data is carried over automatically.
3. Changes: Any change to the details or the ownership structure must be submitted as a follow-up filing without being prompted (ED18 for the triggers in detail).
4. Fees: Annual register fee (§ 24 GwG, fee ordinance) — track it as a recurring burden in the repo's deadline calendar (ED09), not as a surprise.
5. Proof: The transmission is documented in the repo — with case number, date, and reference to the determination. This makes the notification obligation (§ 20 Abs. 1 GwG) demonstrably fulfilled.

Compliance by Design: Two artifacts, one chain: wb_ermittlung.json (ED12) substantiates what is reported; wb_meldung.json documents that and when it was reported — including the case number. The pre-commit hook can check: Does a new determination have a notification? Does the notification have a determination as its source? The chain is thus machine-checkable.

Process: from determination to entry

The notification artifact

{
  "$schema": "https://gitcover.org/schemas/wb-meldung-1.0.schema.json",
  "V7GUID": "WB_MELDUNG",
  "uuidV7": "01a065f3-dbbd-7000-8000-000000000003",
  "tenant": "ORG-1",
  "art": "erstmeldung",
  "grundlage": {
    "ermittlung_uuidV7": "01a065f3-dbbd-7000-8000-000000000001",
    "ermittlung_sha256": "…"
  },
  "gueltig_ab": "260901",
  "uebermittelt_am": "260920",
  "vorgangsnummer": "TR-2026-XXXXXXX",
  "weg": "portal",
  "gemeldete_wb": [
    { "person": "E1", "typ": "mittelbar",
      "art_interesse": "mittelbare Kontrolle über ORG-5",
      "umfang": "100 % an ORG-5" }
  ],
  "obsolescence": { "status": "active", "superseded_by": null, "superseded_at": null }
}

Field discipline: uebermittelt_am and gueltig_ab are domain data (transmission date, start of the constellation) — the capture time of the artifact is embedded in the uuidV7 (ED03).

Linkage with the series

Risk leverage

Harness requirement (preview)

The complete requirements list in Harness-Anforderungen.md.

Sources

• Money Laundering Act (GwG): § 20 Abs. 1 (notification without undue delay), § 19 (notification content), § 24 (fees), § 21 (legal arrangements)
• Federal Office of Administration (ed.): Information sheet on the notification obligation (as of 01/2025) and FAQ — www.transparenzregister.de
• Transparency Register Fee Ordinance (TrGebV) — fees per fee year (2024: 19.80 EUR)
• § 121 BGB (without undue delay)

Source topology and CDN reference links

Note: This assignment of sources, mirror, and community hub reflects the current state and may change. Please check the respective canonical source on gitcover.org for the current state.