Transparenzregister: Beneficial Owner Rules & Business Address | Teeberg

Two half-truths circulate about the Transparenzregister and business addresses. One says a virtual business address keeps your private address completely invisible. The other says the Transparenzregister makes every address public anyway. Neither is true. Here's what the register actually stores, who can see it, and exactly where a business address protects your privacy — and where it doesn't.

What Is the Transparenzregister, and What Does It Have to Do With Your Business Address?

The Transparenzregister is a statutory register under the German Anti-Money Laundering Act (GwG), which itself implements EU anti-money-laundering directives — this isn't a uniquely German bureaucratic quirk, every EU member state runs an equivalent register. It's designed to make visible which real person actually stands behind a company. Not the registered managing director necessarily, but the person who economically owns or controls the business. The register is maintained by Bundesanzeiger Verlag, with the Bundesverwaltungsamt (Federal Office of Administration) as the supervisory authority.

Here's the part that matters for your address question: the Transparenzregister is not an address register. It maps ownership and control, not locations. Your company's business address lives in the commercial register, not here. What lives here is the place of residence of the person behind the company. It's a subtle distinction, and a lot of guides blur it.

What You Actually Have to Report

§19(1) GwG lists the required details exhaustively. There are exactly five — no more, no less.

The filing itself happens electronically without delay under §20 GwG, via the Transparenzregister portal. If anything changes — ownership structure, name, legal form — you have to update it without delay too. There's no multi-week grace period; "without delay" means without culpable hesitation.

Who Has to Register — and Who Counts as a Beneficial Owner (UBO)?

§20 GwG covers legal entities under private law and registered partnerships. In practice: almost any company entered in a register. Sole traders and freelancers are not covered.

The most significant recent addition is the eGbR. Since 1 January 2024, the MoPeG reform introduced the Company Register (Gesellschaftsregister), and registering your GbR there automatically triggers a Transparenzregister obligation too. There's no blanket requirement to register every GbR — but in practice you can't avoid it once your GbR wants to acquire real estate or hold a stake in another company.

Which brings up the real question: who actually counts as a beneficial owner (UBO)? §3(2) GwG draws the line at 25%. A beneficial owner is any natural person who holds more than 25% of the capital shares, controls more than 25% of the voting rights, or exercises control in a comparable way. Indirect holdings through a holding company count too.

Example: a UG has three shareholders holding 50%, 30%, and 20%. The first two must be reported, since both exceed 25%. The third shareholder, at 20%, isn't reported — unless they exercise control some other way, such as through a voting agreement. This holds for GmbH, UG, and holding structures alike, no matter how many layers of ownership sit between the individual and the operating company.

If no one clears the threshold after a full review, the fictitious beneficial owner rule under §3(2) sentence 5 GwG kicks in. The legal representative is then treated as the beneficial owner — for a GmbH, that's the managing director. Typical case: a GmbH with five shareholders at 20% each. Nobody crosses the threshold, so the managing director gets reported instead. "Fictitious" doesn't mean optional — this filing is just as mandatory as any other.

How to Register: Step by Step

The filing process itself is straightforward, provided you have the required information ready:

If you're unsure whether your structure is fully and correctly captured, it's worth having your tax advisor or notary check the entry — the fine for getting it wrong sits with your company, not the registry.

Who Can View Your Entry?

The Transparenzregister was open to public inspection until 2022. Following a ruling by the European Court of Justice on public access, that access was scaled back. §23 GwG now defines three groups with viewing rights.

A curious competitor or a random website visitor can no longer access your data without justification. That's the good news. The less good news: anyone who can establish a legitimate interest sees your name, date of birth, and place of residence — that's the full extent of what's public, no more.

For exceptional cases, §23(2) GwG allows you to apply to restrict access. This is possible where overriding, protection-worthy interests exist — for example, a concrete risk of certain crimes like extortion or coercion, or if the beneficial owner is a minor or lacks legal capacity. This restriction has no effect against authorities, courts, notaries, and GwG-obligated entities. General unease isn't enough as a justification — you have to substantiate the actual risk.

Germany's Transparenzregister vs. the UK's PSC Register

If you've registered a UK company, you'll recognize the concept — the "People with Significant Control" (PSC) register works on similar principles, with a few meaningful differences.

General orientation based on current German and UK statutory frameworks, as of 2026. Not legal advice for either jurisdiction.

What a Business Address Does Here — and Where It Doesn't Help

Here's where it gets concrete, and where the industry oversells. A business address is an effective tool for keeping your residential address out of the publicly accessible registers. It is not a tool for becoming invisible in the Transparenzregister.

In practice, for a founder based in Berlin: the Impressum and commercial register show the Berlin business address. The Transparenzregister shows their name, date of birth, extent of ownership, and the place of residence "Berlin." What appears nowhere publicly is their residential address with street and house number. That's the real protective effect — no more, no less.

If you want to know which address goes where and what the registration court checks for, our guide to commercial register entry with a registered office and virtual office covers that in detail. For when an address actually counts as legally servable, see our article on what's allowed in your Impressum, including the rules around c/o addresses.

Fines, Fees, and Common Mistakes

The penalties under the Anti-Money Laundering Act are not toothless. §56 GwG provides for fines of up to €150,000 for intentional violations, and up to €100,000 for negligence. For serious, repeated, or systematic violations, the range increases to up to €1 million or twice the economic benefit gained. For companies, the fine can reach up to €5 million or 10% of the prior year's turnover — whichever is higher.

The ongoing costs, by contrast, are modest. Bundesanzeiger Verlag charges an annual fee for maintaining the register, set at €20.80 per year under the Transparency Register Fee Ordinance since 2022. It applies even if your reporting obligation is already satisfied through automatic transfer from the commercial register. The invoice arrives unprompted by post or email.

A Berlin Business Address for Your Commercial Register Entry and Impressum

Teeberg is based at Kollwitzstraße 76 in Berlin Prenzlauer Berg. Not an anonymous letterbox — a real office with a team on-site that receives your mail. The address is suitable for the commercial register and Impressum, there's no minimum term, and you can cancel monthly.

* Prices for annual billing, plus VAT, as of 2026. Monthly billing available.

Frequently Asked Questions About the Transparenzregister and Business Addresses