Germany's Foreign Trade Ordinance Updates Reporting Thresholds and Forms from January 2025

Germany is set to implement substantial changes to its reporting requirements under the Foreign Trade and Payments Ordinance (AWV) starting January 1, 2025. These updates will affect how companies report their international capital and payment transactions.

A key modification involves the raising of reporting thresholds. For instance, the limit for payment notifications (Z4 notifications) will increase from EUR 12,500 to EUR 50,000. The threshold for reporting claims and liabilities (Z5 notifications) will be raised from EUR 5 million to EUR 6 million. Reporting requirements for assets held by foreigners in Germany and German assets abroad will also see their respective thresholds increase.

Effective January 2025, transfers of crypto assets will be classified as payments subject to reporting obligations. Conversely, interest payments on foreign bonds and money market instruments will no longer be reportable as payments. Furthermore, the introduction of new digital data collection forms will replace the current reporting forms from mid-2025, with mandatory use beginning mid-2026.

Companies engaged in direct foreign investment will face new mandatory fields in their K4 declarations, requiring information on balance sheet total, annual turnover, and employee numbers. Reporting deadlines are also being harmonized and will be calculated based on business days rather than calendar days, with different deadlines for transaction reports and claims/liabilities.