📚 Transparency register, bookkeeping, accounting, dissolution
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
- 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).
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