German licence and permit records are the authoritative source for one specific question: does this legal entity hold a valid authorisation to conduct a regulated activity in Germany? That question is distinct from who controls the entity. Control sits in the commercial register and the shareholder list. Licence status sits with the competent authority.
The two layers are not linked in any unified database. An international buyer verifying a German target must query both — and must understand that a valid licence does not confirm the identity of the person who actually directs the business.
What German licence records disclose
Germany operates a federal system. Regulatory competence is divided between federal agencies, sixteen state authorities, and thousands of municipal bodies. The result is a distributed landscape of authorisations with no central index.
For major regulated sectors, the following information is typically available from the competent authority:
- Name and registered address of the licence holder
- Licence number and the specific activity authorised
- Date of grant and, where applicable, expiry date
- Conditions attached to the authorisation
- Status: active, suspended, or revoked
The competent authority for financial services is the Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin). BaFin publishes a public database of supervised entities and their authorisation status. For insurance undertakings, the same authority applies. For pharmaceutical manufacturing, the Bundesinstitut für Arzneimittel und Medizinprodukte (BfArM) and state health authorities hold the relevant records. For food business operators, the competent authority is at state level. For trade licences (Gewerbeanmeldung), the municipal trade office (Gewerbeamt) holds the record.
Each authority publishes what its own mandate requires. None publishes what another authority holds.
The control question: what licences do not answer
A licence names the holder. It does not name the person who controls the holder.
In German corporate law, control is exercised through shareholding, through the managing director (Geschäftsführer), and through any shareholder agreement that sits outside the commercial register. The licence record shows none of these. It shows only that the named entity was found fit to hold the authorisation at the time of grant.
Fitness-for-purpose assessments (Zuverlässigkeitsprüfung) are conducted by the granting authority before a licence is issued. The outcome of that assessment — whether the controlling persons were reviewed, what was found — is not published. The assessment is an internal administrative act. Its existence can be confirmed; its content cannot be accessed by a third party through the public record.
This is the first structural gap in the licence layer: the control persons assessed at grant are not disclosed in the public record.
The second gap is temporal. A licence granted when one shareholder held control remains valid after ownership changes, unless the change triggers a mandatory notification or re-assessment obligation. Whether such an obligation exists depends on the sector-specific statute. In some sectors it is explicit; in others it is absent. The licence record itself does not flag whether a change of control has occurred since grant.
Where the sources disagree
A company may appear in the commercial register (Handelsregister) as active and in good standing while its licence has been suspended by the competent authority. The two registers are maintained independently and are not synchronised in real time.
The reverse is also possible: a licence may remain listed as active in an authority's database after the company has been dissolved in the commercial register. Dissolution does not automatically trigger a licence cancellation in every sector.
Where the sources disagree, the disagreement is itself a material finding. It is not resolved by choosing one source over the other. Both statuses are recorded, the date of each record is noted, and the discrepancy is flagged for further inquiry.
| Source | What it shows | What it does not show |
|---|---|---|
| BaFin supervised entities database | Authorisation status for financial services and insurance | Identity of controlling shareholders; outcome of fitness assessment |
| Gewerberegister (municipal) | Trade licence status for the named entity | Beneficial owner; any conditions attached |
| State health authority records | Manufacturing or distribution authorisation for pharmaceuticals | Chain of control; post-grant ownership changes |
| Handelsregister | Legal existence, registered address, managing directors, shareholder list (GmbH) | Licence status in any regulated sector |
| Insolvency register (Insolvenzbekanntmachungen) | Filed insolvency proceedings | Whether a licence has been suspended as a consequence |
The limit of what the sources allow
The ceiling of what the sources allow is stated before any work begins.
German licence records confirm authorisation status for the named entity. They do not confirm who controls that entity at the time of the inquiry. The fitness assessment conducted at grant is not accessible to third parties. Post-grant changes of control are not reflected in the licence record unless the sector statute mandates re-assessment.
The commercial register fills part of the gap: for a GmbH, the Gesellschafterliste names shareholders with their percentage interests. For an AG, the share register is not public. For a GmbH & Co. KG, the structure requires reading both the GmbH register entry and the partnership register entry together.
Even with both layers — licence record and commercial register — the chain of control stops at the first non-German holding entity. A Dutch or Cypriot intermediate holding is named in the Gesellschafterliste, but its own ownership structure is governed by its home jurisdiction's disclosure rules. The German record does not reach through it.
Where the chain breaks, the analysis names the break point and the reason. It does not substitute inference for evidence.
Sector coverage and access conditions
Access to licence records in Germany is not uniform. The following describes the mechanism; exact fees are set by each authority and published in its own tariff schedule.
BaFin: The public database of supervised entities is accessible without registration. It covers banks, investment firms, payment institutions, insurance undertakings, and asset managers. The database returns authorisation status and the scope of the authorisation. It does not return the underlying application documents.
Gewerbeamt (municipal trade office): A Gewerbezentralregisterauszug (extract from the central trade register) can be requested by the entity itself or by a person with a demonstrated legitimate interest. The extract shows trade licence status and any administrative sanctions. Access by a third party requires a statement of legitimate interest. The authority determines whether the interest is sufficient.
State health authorities: Records of pharmaceutical manufacturing authorisations are held at state level. Access conditions vary by state. Some states publish a public list; others require a formal request with a statement of purpose.
Professional chambers (Kammern): For regulated professions — lawyers, auditors, architects, engineers — the relevant chamber maintains the register of admitted members. Chamber registers are generally accessible without registration for the purpose of verifying membership status.
Sector-specific federal agencies: The Bundesnetzagentur holds records for telecommunications and energy market participants. The Luftfahrt-Bundesamt holds aviation licences. Each publishes what its mandate requires, under its own access rules.
The practical consequence for a cross-border verification: establishing licence status across multiple sectors requires separate requests to separate authorities. There is no single point of access, no single response time, and no single fee schedule.
What a licence record establishes and what it does not
A confirmed licence record establishes:
- That the named entity held a valid authorisation as of the date the record was retrieved
- The scope of the authorised activity
- The conditions attached, where published
- Whether the authorisation has been suspended or revoked, where the authority's database is current
It does not establish:
- That the entity is currently operating within the scope of the authorisation
- That the persons controlling the entity at the time of inquiry were assessed by the authority
- That no change of control has occurred since grant
- That no parallel enforcement action is pending in a jurisdiction outside Germany
The absence of a revocation record is not equivalent to confirmed compliance. It is confirmed absence of a published revocation as of the date of retrieval.
Where the sources disagree
Discrepancies between the licence record and the commercial register are not rare. They arise from independent maintenance cycles, from sector-specific notification obligations that are not always met, and from the absence of any automated synchronisation between registers.
When a discrepancy is found, both records are presented with their respective retrieval dates. The analysis does not resolve the discrepancy by assertion. It identifies the discrepancy as a finding requiring further inquiry — typically a direct request to the competent authority for a current status confirmation.
FAQ
Does a valid German licence confirm that the company is under fit-and-proper control? A valid licence confirms that the entity was assessed as fit at the time of grant. The outcome of that assessment is not published. Post-grant changes of control are not automatically reflected in the licence record. The licence record alone does not confirm current control arrangements.
Can a third party access the Gewerbezentralregisterauszug for a German company? A third party can request an extract if they can demonstrate a legitimate interest. The competent authority — the Bundesamt für Justiz — determines whether the stated interest is sufficient. The mechanism exists; access is not guaranteed. No exact fee is stated here: the current tariff is published by the Bundesamt für Justiz.
What happens if the licence record and the commercial register show conflicting status? Both records are retrieved and presented with their retrieval dates. The discrepancy is flagged as a material finding. It is not resolved by choosing one source. A direct inquiry to the competent authority is the appropriate next step.
Does the German commercial register show whether a company holds a licence? No. The Handelsregister records legal existence, registered address, managing directors, and — for a GmbH — the shareholder list. It does not record licence status in any regulated sector. Licence status must be verified separately with the competent authority.
What is the coverage level for German licence records? Coverage is rated C — partial. For major regulated sectors with federal oversight (financial services, insurance, pharmaceuticals), status is confirmable from published databases. For municipal-level trade licences and sector-specific state permits, coverage depends on the authority and the access conditions it applies.
Sources
- Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) — supervised entities database — https://www.bafin.de — verified 2026-09-01
- Bundesamt für Justiz — Gewerbezentralregister — https://www.bundesjustizamt.de — verified 2026-09-01
- Bundesnetzagentur — regulated entities register — https://www.bundesnetzagentur.de — verified 2026-09-01
- Handelsregister — https://www.handelsregister.de — verified 2026-09-01
- Insolvenzbekanntmachungen — https://www.insolvenzbekanntmachungen.de — verified 2026-09-01
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Disclaimer: This report is a factual compilation from official registers and public sources. It is provided for informational purposes only, does not constitute legal advice, and contains no legal qualification of the facts established. VLO Law Firm assumes no liability for actions taken or not taken based on this material. For advice regarding your particular situation, please contact info@vlolawfirm.com.
Author: Katharina Berg — Partner, Central Europe, VLO Law Firm
