Foreign Trade Reporting Obligations in Germany to Change January 1, 2025

Berlin – Germany's Foreign Trade Ordinance (Außenwirtschaftsverordnung, AWV) is set to undergo substantial changes starting January 1, 2025. These updates, which aim to refine reporting requirements for cross-border capital and payment transactions, could result in penalties if overlooked. Domestic companies are now expected to more closely monitor and report their foreign-related assets and transactions.

The most notable adjustments involve the increase in reporting thresholds. For individual payment reports (Z4 notifications), the threshold has been raised from €12,500 to €50,000. The reporting threshold for aggregated claims and liabilities (Z5 notifications) will increase from €5 million to €6 million. Similarly, the reporting thresholds for German residents' assets abroad (K3 notifications) and foreign residents' assets in Germany (K4 notifications) will be raised from €3 million to €6 million.

Cryptocurrencies are now explicitly included under reporting obligations. The transfer of crypto assets will be classified as a payment, and specific reporting codes have been introduced for various types of crypto and digital assets, such as codes 804, 814, 824, and 834. Additionally, reporting forms are being updated and replaced by new digital "Erhebungsschaubilder" (statistical survey forms) within the General Statistics Portal (AMS), which will become mandatory from mid-2026.

Reporting deadlines have also been harmonized and will now be based on working days rather than calendar days. Transaction reports, for instance, must be submitted by the 7th working day of the following month, while reports on claims and liabilities are due by the 10th working day. The ordinance also specifies that new key figures will be introduced for crypto assets starting January 2025, replacing older codes.