Germany implements new UBO reporting obligations for foreign entities with direct or indirect ownership in German real estate

The German Sanctions Enforcement Act II, which came into law on 28 December 2022, introduces new obligations for non-German entities to report their so-called “Ultimate Beneficial Owner(s)” (UBO) to the German UBO register, if they either directly or indirectly (via shares) own German real estate. This is highly relevant for German inbound structures and fund structures with German real estate in light of the high penalties that can be imposed in case of non-compliance.

Under the old provisions, …