Germany · Pillar Two · In force

Germany Pillar Two obligations

Germany imposes 3 separate filing obligations under Pillar Two, and access to the filing channel takes 6–8 weeks, stated by the BZSt — ELSTER or BZSt certificate. Checked against the authority on 3 October 2026.

Checked 3 October 2026 Primary-sourced 3 separate filing obligations

Registration with the BZSt can take six to eight weeks. That is the critical path, not the deadline.

Germany also has obligations under e-invoicing. See the e-invoicing page →

Access gate — clear this before anything can be filed

ELSTER or BZSt certificate · 6–8 weeks, stated by the BZSt

Registration form, then a Handelsregisterauszug by email, then the BZSt-Nummer arrives by post and the secret code by email before the certificate can be generated. The BZSt states the whole process can take six to eight weeks.

What is in force in Germany

ChargeLocal nameIn force from
IIRPrimärergänzungssteuerregelung (PES)Fiscal years beginning after 30 Dec 2023
UTPRSekundärergänzungssteuerregelung (SES)Unconfirmed — § 101(2) MinStG not retrievable
DomesticNationale ErgänzungssteuerFiscal years beginning after 30 Dec 2023

The 3 separate filing obligations

Gruppenträgermeldung

Also: GTM

Notification to the BZSt identifying the Gruppenträger of the minimum tax group.

Who files
The Gruppenträger
Deadline
No later than 2 months after the end of the taxable period
Channel
BZSt online.portal, electronic form

Pillar 2 — Verfahren, Bundeszentralamt für Steuern ↗

Mindeststeuer-Bericht

Also: GIR

The GloBE Information Return in XML.

Who files
Each entity with a filing duty; one may be designated to file for the others
Deadline
15 months after the fiscal year; 18 months for the first year. Not before 30 June 2026.
Channel
BZSt online.portal XML upload, or the DIP mass-data interface. A customer test environment exists but does not replace production filing.

Elektronische Datenübermittlung — BZSt ↗

Mindeststeuererklärung

Also: minimum tax return

The self-assessment return, separate from the Bericht.

Who files
The Gruppenträger
Deadline
General return rules under § 149(2) AO — never before the GIR deadline
Channel
ELSTER, to the competent state tax authority — not the BZSt

Pillar 2 FAQ — BZSt ↗

Penalties

Up to €30,000 under § 98 MinStG for intentional or reckless failure to transmit the Mindeststeuer-Bericht. Transitional relief: § 98(1) does not apply to fiscal years beginning on or before 31 Dec 2026 and ending before 1 July 2028, subject to conditions.

What catches groups out in Germany

  • The six-to-eight-week registration window is the single most underestimated item in any German timeline.
  • Two separate authorities: the Bericht goes to the BZSt, the return goes to the state tax office via ELSTER.
  • Business rules have been repeatedly deactivated through 2026 — acceptance requires Accepted status with no RecordError entries.
  • OECD released an updated GIR template on 11 Sep 2026 for fiscal years beginning on or after 31 Dec 2025; the XML schema is being revised.

Recent changes affecting Germany

  • 2026-09-17 — BZSt reports the OECD's 11 September 2026 updated GIR template, applying to fiscal years beginning on or after 31 December 2025; the GIR XML schema is being revised.
  • 2026-08-31 — Rule 60022 found to generate incorrect FileErrors on UPE correction messages omitting the GeneralSection; 70053 to be deactivated and 70030 revised.
  • 2026-08-14 — Rules 70012 and 70037 added to the deactivated list; 70030 and 70053 under review. Acceptance requires Accepted status with no RecordError entries.
  • 2026-08-06 — Kommunikationshandbuch Mindeststeuer-Bericht v1.3 published; data set description v1.3 dated 5 June 2026.

All dated changes →

Common questions

What must be filed in Germany under Pillar Two?

3 separate obligations: Gruppenträgermeldung; Mindeststeuer-Bericht; Mindeststeuererklärung.

When is the Gruppenträgermeldung due in Germany?

No later than 2 months after the end of the taxable period. Filed by: The Gruppenträger. Channel: BZSt online.portal, electronic form.

When is the Mindeststeuer-Bericht due in Germany?

15 months after the fiscal year; 18 months for the first year. Not before 30 June 2026.. Filed by: Each entity with a filing duty; one may be designated to file for the others. Channel: BZSt online.portal XML upload, or the DIP mass-data interface. A customer test environment exists but does not replace production filing..

What access is needed before filing in Germany?

ELSTER or BZSt certificate. Lead time: 6–8 weeks, stated by the BZSt. Registration form, then a Handelsregisterauszug by email, then the BZSt-Nummer arrives by post and the secret code by email before the certificate can be generated. The BZSt states the whole process can take six to eight weeks.

What are the penalties in Germany?

Up to €30,000 under § 98 MinStG for intentional or reckless failure to transmit the Mindeststeuer-Bericht. Transitional relief: § 98(1) does not apply to fiscal years beginning on or before 31 Dec 2026 and ending before 1 July 2028, subject to conditions.

Where this comes from

Every row on this page was checked against the authority's own published page on 3 October 2026. Every row verified against BZSt pages. The 6–8 week lead time is the BZSt’s own wording.

Cite this page

Saurabh Satija, “Germany Pillar Two filing obligations”, https://saurabhsatija.com/pillar-two-germany, accessed [date].

Quotation and citation with attribution and a link are welcome. The underlying data is open as JSON and as plain text.

Other Pillar Two jurisdictions

United Kingdom · Ireland · Netherlands · Belgium · Spain · Italy · Luxembourg · Canada

All 21 entries in the tracker →

How many of these are actually yours?

This page shows what Germany requires. The scoping tool takes your whole footprint and returns every filing it triggers, in deadline order, with the access prerequisites attached. About thirty seconds.

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