Germany: Updated CRS guidance
CRS newsletter on recent updates to preliminary Exchange List and transition to new BZSt online portal
The Federal Central Tax Office of Germany (BZSt) on April 2, 2025, released common reporting standard (CRS) Newsletter 02/2025 that contains the following updates:
- Preliminary exchange list for 2025: The BZSt published a provisional list of participating and reportable jurisdictions for the 2024 reporting year.
The preliminary Exchange List includes all countries that have committed to the automatic exchange of information on financial accounts in tax matters internationally. It does not yet represent a basis for data transmission in 2025 and is only intended to serve as an aid for the preparation of data by financial institutions. All changes to the final 2024 state exchange list are highlighted in color.
- Moving of the manuals: As part of the transition to the new BZSt online portal and the new mass data interface DIP, documents previously located in the "Manuals" section have been relocated to the "Electronic Data Transmission (BOP / ELMA)" section for improved clarity.
- Transition to the BZSt online portal and introduction of the mass data interface DIP / data set description DIP: Germany is transitioning the CRS data transmission process to the new BZSt online portal and mass data interface DIP, replacing the existing ELMA interface (schema version 1.0). A new section "Electronic Data Transmission (BZSt online portal / DIP)" has been added to the BZSt website.
The existing ELMA interface (schema version 1.0) and the BOP portal are expected to remain operational until November 2025. Notably, there are no plans to transition to ELMA schema version 2.0.
- Exempt accounts under Section 19 Number 34 FKAustG: Reporting financial institutions are required to report specified information for each reportable account. However, exempted accounts under Section 19 Number 34 FKAustG are not considered financial accounts and are therefore not subject to reporting.
- Guidelines for data set transmission and rejection handling: Reporting financial institutions must provide that data records are not reported multiple times unless there are amendments. Amendments to the existing data records should be submitted as correction reports.
Read an April 2025 report prepared by the KPMG member firm in Germany