📚 Transparency register, bookkeeping, accounting, dissolution

What an e.V. must report to the transparency register, when bookkeeping obligations apply and how dissolution works.

transparency register beneficial owner bookkeeping cash-basis accounting dissolution asset lock foundation register

In brief

A registered association must report its beneficial owners to the transparency register. For an e.V. the registering body enters the details under § 20a GwG automatically; board members count as notional beneficial owners. A separate notification under § 20 Abs. 1 GwG is then not required. Changes of board must therefore be properly recorded in the register of associations.

Keep traceable records. The limits for the bookkeeping obligation (€800,000 turnover or €80,000 profit) apply to the association's taxable commercial activity. In addition, the general record-keeping duty under § 63 Abs. 3 AO applies.

Dissolution regularly needs a three-quarters majority. If the association is non-profit, the assets must go to another tax-privileged organisation.

Step by step

Keep board data up to dateRegister changes with the register of associations so that the transparency register is correct.
Keep recordsDocument income and expenditure, receipts and assets in a traceable way.
Give an accountThe board reports to the general meeting; cash audit as set out in the articles.
Prepare dissolutionResolution of the general meeting, liquidation, use of assets as set out in the articles.

Deadlines

3/4 of the votes cast

Majority for dissolution, unless the articles provide otherwise.§ 41 BGB

€800,000 / €80,000

Bookkeeping limits (turnover or profit); for associations relevant for the taxable commercial activity.§ 141 Abs. 1 AO

Watch out – common mistakes

Exceptions under § 20a Abs. 2 GwG: the first case is a change of board that was not registered with the register of associations without delay. Then the association itself must act; further exceptions are in § 20a Abs. 2 GwG.
Automatic registration has applied since 1 August 2021; the initial registration took place by 1 January 2023 at the latest, afterwards on specific occasions (§ 20a Abs. 3 GwG).
Foundation register: the Bundesamt für Justiz gives the start as 1 January 2028 with a registration deadline for existing foundations until 31 December 2028; law firms gave 2026. The Bundesamt für Justiz is authoritative.
The asset lock on dissolution follows from § 55 AO; its absence from the articles endangers non-profit status.

In depth · legal basis, figures and practice – for advisers and professionals

Transparency register

§ 20 Abs. 1 GwG obliges legal entities under private law to obtain details of beneficial owners, keep them up to date and notify them to the transparency register. For the e.V., § 20a GwG applies (since 1 August 2021): the registering body transmits the details automatically, board members count as notional beneficial owners, and the notification duty under § 20 Abs. 1 GwG does not apply. The initial automatic registration took place by 1 January 2023 at the latest, afterwards on specific occasions (§ 20a Abs. 3 GwG). Exceptions are regulated in § 20a Abs. 2 GwG; the first case is a change of board that was not registered with the register of associations without delay.

Bookkeeping and accounting

§ 141 Abs. 1 AO sets bookkeeping limits of €800,000 total turnover and €80,000 profit for commercial traders and farmers and foresters; they apply to the association's taxable commercial activity. Non-profit organisations must also keep proper records (§ 63 Abs. 3 AO). The board's duty to account follows from the law of mandate (§ 27 Abs. 3 BGB) and the articles of association.

Dissolution

Resolution of the general meeting with a three-quarters majority of the votes cast (§ 41 BGB). If non-profit, the assets must go to tax-privileged organisations (§ 55 AO).

Who is responsible

Registration court (register of associations)
Bundesanzeiger Verlag (transparency register)
Competent tax office

Quick questions

Worum geht es bei „Transparency register, bookkeeping, accounting, dissolution“?

What an e.V. must report to the transparency register, when bookkeeping obligations apply and how dissolution works.

Which deadlines and figures matter?

3/4 of the votes cast: Majority for dissolution, unless the articles provide otherwise. (§ 41 BGB)
€800,000 / €80,000: Bookkeeping limits (turnover or profit); for associations relevant for the taxable commercial activity. (§ 141 Abs. 1 AO)

What should I do first?

Keep board data up to date: Register changes with the register of associations so that the transparency register is correct.
Keep records: Document income and expenditure, receipts and assets in a traceable way.
Give an account: The board reports to the general meeting; cash audit as set out in the articles.

What do I need to watch out for?

Exceptions under § 20a Abs. 2 GwG: the first case is a change of board that was not registered with the register of associations without delay. Then the association itself must act; further exceptions are in § 20a Abs. 2 GwG.
Automatic registration has applied since 1 August 2021; the initial registration took place by 1 January 2023 at the latest, afterwards on specific occasions (§ 20a Abs. 3 GwG).
Foundation register: the Bundesamt für Justiz gives the start as 1 January 2028 with a registration deadline for existing foundations until 31 December 2028; law firms gave 2026. The Bundesamt für Justiz is authoritative.

Evidence

GwG §§ 20, 20a, gesetze-im-internet.de, retrieved 20 September 2026
Deutsche Stiftung Engagement und Ehrenamt, "Transparenzregister: Neue Regelungen in Kraft", retrieved 20 September 2026
AO § 141, gesetze-im-internet.de, retrieved 20 September 2026
Bundesamt für Justiz, "Stiftungsregister", bundesjustizamt.de, retrieved 20 September 2026

As of

September 2026 · Sources and method

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