Buying German property through a company or trust: the beneficial ownership register requirement

If you're buying German property as a private individual, this article doesn't apply to you. But if you're purchasing through a foreign company, a trust, or another legal entity, a reform that took effect on 1 January 2026 added a step that can stop your notary appointment in its tracks if you haven't prepared for it: verifying your entity's registration in Germany's Transparenzregister, the beneficial ownership register. This guide covers what changed, who it affects, and how to avoid it delaying your purchase.

The Transparenzregister is Germany's electronic register of beneficial ownership, run under the Geldwäschegesetz (GwG, Germany's anti-money-laundering law), which itself implements EU anti-money-laundering directives. Its purpose is straightforward: for any legal entity, a register shows the natural persons who actually own or control it, the wirtschaftlich Berechtigte (beneficial owners), rather than just the entity's name on paper.

Notaries in Germany are classified as obligated entities under the GwG. That means they carry specific anti-money-laundering duties, including verifying beneficial ownership information, whenever they handle a transaction that could otherwise obscure who's really behind it. A property purchase by a company or trust is exactly this kind of transaction.

A reform of the GwG, implemented through the Transparenzregister- und Finanzinformationsgesetz, tightened the reporting duty for beneficial owners and, specifically relevant here, formalised the notary's obligation to check the register before certifying a property purchase contract involving a legal entity. As of 1 January 2026, notaries must verify that the acquiring company (Erwerbergesellschaft) is properly registered in the Transparenzregister as part of handling the purchase.

This builds on an existing requirement rather than creating one from nothing: since August 2021, there's already been a duty to obtain a Transparenzregister extract for these transactions regardless of whether beneficial ownership information could technically be pulled from another register. The 2026 reform sharpens this specifically around property purchases and the notary's role in checking it.

This requirement applies when the buyer is a legal entity, not a private individual. In practice, that covers a foreign company purchasing German property, a trust or foundation structure, a GmbH or other corporate vehicle set up to hold the property, and similar arrangements where the "buyer" on paper isn't a natural person.

If you're buying in your own name as an individual, even as a foreign national, none of this applies to your purchase. This is squarely a consideration for buyers using a corporate or trust structure, often for tax planning, liability separation, or inheritance purposes.

This is the part worth planning around. If your entity's beneficial ownership isn't properly registered and current in the Transparenzregister, the notary is legally barred from certifying the purchase contract. Not delayed, barred. Your Notartermin, however carefully everything else has been prepared, cannot proceed to a valid signing until this is resolved.

Because updating or completing a Transparenzregister entry isn't instantaneous, particularly for a foreign entity establishing its first German-relevant registration, this is not something to leave until the week of your appointment. A reasonable rule of thumb is to confirm your entity's registration is current at least a month before you expect to sign, giving enough buffer for any corrections or first-time filings to process.

There's a practical relief built into the law. Under § 12(3) of the GwG, if the beneficial ownership information the entity provides to the notary matches what's already in the Transparenzregister, and there's no indication the information is inaccurate or any elevated money-laundering risk, the notary doesn't need to take verification steps beyond checking the register itself. In other words, if your registration is accurate and current, this becomes a quick check rather than an extended process. The friction only arises when the register is out of date, incomplete, or doesn't match what's being represented to the notary.

Confirm your entity's Transparenzregister status well before you're ready to make an offer, not after you've found a property. If your entity has never registered, or its beneficial ownership details have changed, for example a change in shareholders or trustees, start that update immediately, since first-time or corrected filings take longer than a routine check. Keep documentation of your entity's ownership structure ready to share directly with the notary's office, since consistency between what you tell the notary and what's on the register is exactly what triggers the streamlined path described above. And flag to your notary early, when you first engage them, that you're purchasing through an entity, so they can factor this verification into their own timeline rather than discovering the issue when they try to schedule your appointment.

For the individual expat buyer, this is genuinely not something to worry about. But for anyone structuring a German property purchase through a company or trust, whether for a single property or as part of a broader investment approach, this is now a concrete, dateable item on the pre-purchase checklist, and one that's easy to miss because it sits outside the property search and financing process entirely. Raising it with your notary and, if relevant, your tax or legal adviser at the very start of the process avoids it becoming the reason your signing date slips.

For the broader purchase process, see our guide to buying property in Germany as a foreigner. And for what else the notary handles at the signing itself, see our guide to the notary appointment.

As of September 2026. This reflects the Transparenzregister- und Finanzinformationsgesetz reform effective 1 January 2026. This is a summary of a specific anti-money-laundering requirement, not legal advice. If you're purchasing through a company, trust, or similar structure, confirm current requirements with a German notary or lawyer before you begin.