I am currently in the process of incorporating a new company in Germany. Yes.. I’m sure you wonder which sequence of questionable decisions lead up to this very questionable decision, but I won’t bore you with the details. Instead, today, I’ll go ahead and rant about something truly insane: The German Transparency Registry (Transparenzregister).
The further you dig, the more you question how any sane person could have devised this thing, and how on earth we’re expecting sane people to build companies in Germany, given that we throw this sort of insane stuff at them.
But let’s not get ahead of ourselves. Here’s how it works.
The Idea
The idea of the Transparenzregister is generally a good one: Shady people did shady things, and they set up shady companies to obfuscate which humans were actually behind their companies.
So the obvious solution here is obviously more regulation (right?) which makes companies report which human ultimately benefits from their earnings.
So far, so bad. As people say, “the road to hell is paved with good intentions” – and, boy, I don’t know how many turns the people on the transparency registry took to arrive at the very weird and dark place they are at now.
Let’s go through the truly insane aspects step by step:
Insanity #1: Duplication
The obvious solution of any rational human to the “let’s track transparency data” problem would have been to simply extend the existing commercial registry (Handelsregister), add some sort of “Transparency” tab to each entry listed there and chase down the companies to fill out their data.
But, alas, Germany stopped being a country run by rational humans a while ago, so the career-minded bureaucrats devised a plan to launch another, separate registry for transparency data: The transparency registry (Transparenzregister).
Let’s pause here for a moment to fathom the complete insane implications of this: We now almost have a 1:1 ratio of duplicate content. Any data stored in the commercial registry has to be re-entered into the transparency registry – stuff like your company name, address, VAT ID, etc., etc. – no, this doesn’t happen automatically. Yes, you have to do all of it manually. And yes, that’s your job as the business owner. Good luck.
Insanity #2: Submit an application to.. view your own data
Okay. You just won’t be able to believe what comes next.
So you’ve registered and logged into the transparency registry, and you’ve created an entry for your company (95% of the required data here could have been transferred from the commercial registry, but.. we already talked about that).
Now, in the future, you might want to do some sort of company transaction, say, sell your company or so. In Germany, this always involves going to the notary public. Those are the people who charge you hundreds to thousands of Euros for reading out your own contract to you (that’s another story).
Here’s what might happen: Your notary tells you “hey cool, come by next week, and send me your company’s statement (Auszug) from the transparency registry in the meantime”.
You’d be like: Yeah sure, this should be easy.. I’m logged into my account which created the company entries in the transparency registry, so I’m essentially linked to them as an “admin”, so I should be able to download the official statement PDF here, right?
Wrong.
Because.. data protection!
For no obvious reason, you have to submit an application to view a statement of your own data. This is completely insane.
So you have to go through a multi-step form in which you check a checkbox “Selbstauskunft” which literally means that you need access to your own data because you need to provide it to someone else.
But you’re not done yet. Ready?
Insanity #3: Write your own cover letter to view your own data
Here’s the next problem. You need to attach a PDF in which you explain why you need to view your own data (???).
And even this is not the end of it. There’s no freakin’ template for this. So the transparency registry literally expects you to free-form-write something like a cover letter in which you outline that, yes, you need access to the data of your own company, the data you yourself just submitted.
And then please attach it as PDF.
Here’s a screenshot, because I myself would not have believed this otherwise:
Insanity #4: Someone reviews your application to view your own data
But even that is not the end of it. Get this.
Now a human reviews your application in which you requested to view your own data, and in which you attached your free-form cover letter, outlining why you need to view your own data.
This will likely take multiple working days.
The usefulness of this can best be described as “it’s mostly a job creation scheme”.
(Why can’t all the data simply be freely available, just like it’s the case for the commercial registry? I don’t know. You might be asking too many questions here, comrade..)
But all of this is child’s play in contrast to the bureaucratic “grand slam”, which is the biggest and final piece of our tour through the transparency registry.
Are you ready?
Insanity #5: Pay for downloading the PDFs of your own data
Okay, so you’ve entered your company into the registry, you’ve applied for viewing your own data, and you’ve written a free-form cover letter on the reasons why you need access to your own data. And, after a few days waiting time, a friendly German bureaucrat has approved your request to view your own data.
Success!
But wait, where’s your data? Like, where’s the PDF statement which you wanted to download?
Oh right, you don’t get it yet – the fact that your application has been approved now grants you the privilege of putting your own PDF into a virtual shopping cart and paying for it.
Yes, you heard me right: You have to go through all of these steps, only to receive permission to pay for your own PDF in the subsequent checkout process.
Don’t believe me again? Can’t blame you. Here’s how it looks:
And then, after you’ve successfully paid on checkout (they even take credit cards!), you’ve got it: Your company’s official entry in the Transparenzregister.
Good job.
Regardless of what you thought your nationality was, after this right of passage, you are now 100% German.
Bonus: Pay a yearly subscription free
Oh wait, there’s a bonus.
Your company gets to pay for the privilege of being listed in the transparency registry. Every year, you receive an invoice over approximately ~30€ from the “Bundesanzeiger Verlag GmbH”, which is the company behind the Transparenzregister (it’s 100% state-owned).
By the way, it’s not optional.
You see, it’s a legal requirement to enter your company into the transparency registry. Hence, paying for this steaming pile of broken processes is essentially a legal requirement, too.
Wow. What a business model.
If you’re planning to run a company in Germany, I encourage you to run away from Germany instead.
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