Action Plan against Tax and Financial Crime: What businesses should be prepared for

With their action plan to combat tax and financial crime, the Federal Ministry of Finance (BMF) and the Federal Ministry of Justice (BMJV) have set out proposals for the future direction of the government’s measures to tackle these offences. According to the plans, tax offences are to be detected earlier in future, data is to be utilised more extensively, and sanctions are to be applied more consistently.

So far, however, this is merely a political declaration of intent. Most of the 26 measures initially require a legal basis or extensive technical and organisational implementation. Nevertheless, the action plan contains indications of which issues may come into sharper focus in future.

The plan does not stand alone. Back in February 2026, the Federal Government had already presented an action plan against organised crime. On 12 August 2026, the Federal Cabinet approved a government draft of the Customs Financial Justice Act (ZFG), which is intended to realign the organisation and powers of the customs administration in the fight against financial crime. Added to this are European initiatives to combat money laundering, including the new Anti-Money Laundering Authority (AMLA) in Frankfurt. Against this backdrop, it is already worth companies taking a look at the political signals today.

More data and greater connectivity as a guiding principle

The action plan focuses on greater pooling of data, expertise and responsibilities. According to the proposals, tax and financial crime is to be tackled in future less on the basis of individual administrative structures and more through joint information-sharing and analytical approaches.

The measures envisaged include, amongst others:

Establishment of a Joint Centre for Combating Tax and Financial Crime within the Customs Service
closer cooperation between the tax investigation service, customs, the Financial Intelligence Unit (FIU) and other authorities
joint data platform run by the federal and state governments
AI-powered data analysis for the detection of suspicious patterns
Expansion of blockchain analysis for crypto transactions

The approach is based on the premise that complex financial crime leaves behind extensive digital traces, yet this information has often not been collated to date. The planned tools are intended to enable such anomalies to be identified more quickly in future and to provide greater data-driven support for investigations.

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VAT fraud is coming under greater scrutiny

The planned electronic VAT reporting system deserves particular attention. The background to this is the considerable damage that cross-border VAT fraud schemes, known as ‘carousel schemes’, have been causing for many years. Timely reporting of transactions could help to identify suspicious patterns at an earlier stage. It remains to be seen, however, whether Germany intends to introduce national reporting obligations that go beyond the European requirements of the ViDA reform already agreed upon – for example, for domestic transactions or ahead of the European timetable.

Further data-related measures include:

Expansion of data collection at federal level, including purchased data sets (‘tax CDs’)
Introduction of a mirror server requirement for certain companies to ensure domestic access to tax-relevant data
Extension of the retention periods for accounting documents to 15 years

In line with the logic of the action plan, these initiatives aim to provide public authorities with better access to tax-related information in order to assist in the detection of tax and financial crime.

Deterrence is to be strengthened

In addition to improved detection, the action plan also provides for various measures in the area of enforcement. These include, amongst others:

stricter penalties for organised tax crime
the reintroduction of a criminal offence for particularly serious tax evasion
a public register of companies with serious tax offences
simplified asset recovery

Also noteworthy is the announced reform of voluntary disclosure. The action plan refers to the abolition of immunity from prosecution ‘in its current form’. However, it remains unclear what specific changes this might entail. As recently as April 2026, the Federal Ministry of Finance (BMF) had announced that it would only remove the immunity from prosecution above certain thresholds; this specific provision is no longer included in the action plan.

What businesses should keep an eye on

At present, the action plan does not yet give rise to any immediate new obligations. Nevertheless, the general direction is clear: tax crime is to be combated increasingly using the same tools as those employed against money laundering, organised crime and other forms of serious economic crime.

For many companies, the potential risk lies less in deliberate breaches than in unwitting involvement in problematic business structures, for example through VAT fraud in supply chains, fictitious or circumventing transactions, or money-laundering activities by business partners.

Should the proposed measures be implemented, anomalies in business relationships could be detected more frequently, and companies could increasingly be confronted with requests for information or other investigative measures. This can significantly disrupt business processes and damage a company’s reputation, even if suspicions are later found to be unfounded. This makes robust compliance structures, effective third-party risk management and risk-based business partner due diligence all the more important.

Entscheidend bleibt die Umsetzung

Ob der Aktionsplan tatsächlich einen Wendepunkt markiert, wird sich erst in den kommenden Gesetzgebungsverfahren und bei der praktischen Umsetzung zeigen. Der politische Kurs ist allerdings bereits erkennbar: Steuer- und Finanzkriminalität sollen früher entdeckt, Daten systematischer genutzt und Ermittlungsressourcen stärker gebündelt werden. Für Unternehmen liegt die zentrale Botschaft deshalb weniger in einzelnen angekündigten Strafverschärfungen als vielmehr in einem veränderten Ermittlungsansatz, der Auffälligkeiten früher und über bislang getrennte Datenbestände hinweg sichtbar machen soll.

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