On 1 September 2025, the new Regulation on the Reporting Obligation under the German Anti-Money Laundering Act (GwGMeldV) was published. It will enter into force on 1 March 2026 and introduces significant changes for obliged entities under the German Anti-Money Laundering Act (GwG). The Regulation governs the digital transmission of suspicious activity reports and defines the format and required content of electronic reports submitted in fulfilment of the reporting obligation under Sections 43 and 44 GwG.
This article is a continuation of our previous post dated 6 May 2025.
Purpose and necessity of the Regulation
Although suspicious activity reports are already transmitted electronically to the Financial Intelligence Unit (FIU) via the goAML IT system, binding and specifically defined requirements for form and content have been lacking.
With the introduction of the GwGMeldV, the legislator aims to standardise, unify and fully digitise the transmission of suspicious activity reports under Sections 43 and 44 GwG throughout Germany. The new Regulation is intended to create legal certainty and improve both the quality of reports and their processing.
Technical format for the transmission of reports
In future, suspicious activity reports may only be submitted electronically via the data processing system goAML provided by the FIU (Section 2 GwGMeldV). Until now, such an exclusively digital reporting obligation had not been anchored in law, although supervisory authorities have long operated under the principle of electronic reporting.
The GwGMeldV now introduces a purely digital reporting channel, thus excluding previously permitted transmission methods such as post, fax or similar manual procedures. Alternative transmission methods may only be used in the event of temporary technical impossibility, and in such cases, the FIU will provide guidance on its website (Section 2 (4) GwGMeldV).
Attachments must be submitted in a format specified by the FIU that is both machine-readable and electronically searchable (Section 2 (3) GwGMeldV). Reports themselves must be transmitted in a machine-readable XML format or alternatively entered directly into the corresponding fields within the goAML online portal (Section 2 (1)-(2) GwGMeldV). Other formats are not permitted.
To avoid undue hardship, an obliged entity may submit an exceptional request to waive the electronic transmission requirement and to use postal delivery instead (see Section 45 (2) GwG).
Minimum content requirements
Section 3 GwGMeldV sets out the required content of a suspicious activity report. This includes, among others:
- Details of the reporting entity (e.g. case number or reference code),
- Grounds for the report (based on FIU guidance),
- Information on any criminal complaints or official enquiries,
- A detailed description of the facts that gave rise to the suspicion,
- Mandatory information such as customer data, the beneficial owner, and the nature and purpose of the business relationship.
Some mandatory content originally included in the draft version of the GwGMeldV was removed from the final Regulation. For example, the requirement to provide the country of birth of the customer was dropped – a welcome change, given that under current law it is not clearly stipulated whether obliged entities are even permitted to collect this information (cf. Section 11 (4) no. 1 lit. b) GwG: “place of birth”).
Conclusion
The introduction of the GwGMeldV entails considerable organisational and financial adjustments for obliged entities. In addition to upgrading their IT infrastructure and internal processes, entities must ensure compliance with enhanced data transmission security requirements and train relevant staff accordingly. The one-off cost for this transition is estimated at around €727,000 (GwGMeldV-E dated 22 April 2025, p. 8).
Obliged entities should use the time until 1 March 2026 to adequately prepare for the Regulation’s entry into force.
However, the longevity of the reporting standard established under the GwGMeldV remains uncertain. From 10 July 2027 onwards, the forthcoming EU Anti-Money Laundering Regulation will largely replace the GwG and the GwGMeldV. Under this Regulation, the newly established AMLA will be responsible for developing EU-wide standardised reporting formats. Whether these EU standards will align with those defined in the current GwGMeldV remains to be seen.
