Millionenkredit Reporting: GroMiKV EA Form and the 2026 Shutdown

Millionenkredit reporting under section 14 of the German Banking Act (Kreditwesengesetz, KWG) has a fixed end date. Article 36 of the Standortfoerdergesetz (StoFoeG) of 4 February 2026 deletes section 14 KWG with effect from 30 December 2026, and the Deutsche Bundesbank’s notice of 5 October 2026 to the firms in the procedure describes the notification for the 09/2026 reporting date as the last one. Until then, every participant still owes the Bundesbank’s Evidenzzentrale a quarterly report on each borrower whose credit volume reached EUR 1 million or more.

The return runs on two tracks set by the Grosskredit- und Millionenkreditverordnung (GroMiKV). Borrower master data goes in on paper under the current rules, led by the EA single borrower notification in Annex 2 of the ordinance. Amount data goes in electronically, as BA records and their totals, through the Bundesbank ExtraNet. A team closing out the 30 September 2026 reference date needs both tracks right, and it needs to know which parts of the machinery outlive the repeal.

Related reading: AnaCredit Reporting in Germany: Bundesbank Credit Data and Deadlines

Legal basis of Millionenkredit reporting: section 14 KWG and the GroMiKV

The obligation sits in section 14(1) KWG. Participating firms report to the Evidenzzentrale kept at the Deutsche Bundesbank, every quarter (the observation period), the borrowers whose credit volume is EUR 1 million or more. The statute calls that the million-credit reporting limit (Millionenkreditmeldegrenze). It leaves the content of the reports, the deadlines and the detail of the observation period to an ordinance issued under section 22 KWG.

That ordinance is the GroMiKV of 6 December 2013 (BGBl. I p. 4183). The Federal Ministry of Finance issued it under section 13(1) and section 22 KWG, in consultation with the Bundesbank and after hearing the institutions’ umbrella associations. It entered into force on 1 January 2014 and replaced the 2006 version. The current text was last amended by Article 10 of the Act of 25 March 2026 (BGBl. 2026 I No. 81).

The ordinance has three working parts for this return:

• Part 2 (sections 11 to 18) sets the million-credit rules: close of business, measurement basis, currency conversion, who counts as the borrower, the reporting dates, the master-data and amount-data filings and record keeping.
• Part 3 (section 19) governs the notification the Evidenzzentrale sends back to lenders about each borrower’s total indebtedness.
• Annexes 2 to 7 contain the forms. Annex 2 is the EA, the “Einzelmeldung Kreditnehmer fuer Millionenkreditanzeigen nach Paragraph 14 KWG”, addressed to the competent regional office (Hauptverwaltung) of the Bundesbank.

Part 1 of the same ordinance supplements the EU large exposure rules: exemptions from the Article 395 CRR limit, board resolution duties under section 13 KWG and large exposure master data under section 8. That split matters for the repeal, as the changes section below shows.

Alongside the ordinance, the Bundesbank publishes a technical implementation provision for large exposure master data and million-credit reports, the Meldetechnische Durchfuehrungsbestimmung (DFBS), version 2.3 of 23 April 2021, in force from 28 June 2021. The Bundesbank states that it alone is responsible for that text, that it is guidance and that it does not settle every question.

Two consequences follow. The forms reproduced in the DFBS are marked “nicht amtliches Dokument”; the official EA is the one in Annex 2. And DFBS 2.3 predates later ordinance amendments: it still tells reporters to observe the transitional rules in section 20 GroMiKV, which the current ordinance lists as repealed, and it describes the reporting financial services institutions by a Bundesbank grouping where section 14(1) KWG now names them by licence type. Where the two differ, the ordinance and the statute govern.

Who must report million credits, and who reports through a parent

Section 14(1) KWG names the “participating firms” (am Millionenkreditmeldeverfahren beteiligte Unternehmen). The operative split is between licensed institutions, which report under the statute directly, and the public bodies and non-bank firms that other provisions pull into the procedure. The table maps each group to its legal hook and to the StoFoeG provision that removes it from 30 December 2026.

The DFBS also lists branches of foreign undertakings under section 53 KWG and third-country branches under section 53c KWG among the reporters. Section 12(3) GroMiKV addresses third-country branches as well: with BaFin’s consent they may use the original exposure method for derivatives.

Group reporting without a consolidated return

A superordinated undertaking within the meaning of section 10a KWG also reports the borrowers of its group companies (section 14(1) sentence 2 KWG). Three carve-outs apply: the group company reports itself, it is exempt or excluded under section 2(4), (7), (8), (9a) or (9e) KWG, or the parent deducts the book value of its participation from own funds under Article 36 in conjunction with Article 19(2)(a) CRR. Group companies that do not report themselves must supply the parent with the data. The DFBS adds two details that change the build: each group company’s borrowers are reported separately and at the full credit amount, without pro-rating by shareholding, and the Bundesbank does not provide for a consolidated group-level million-credit report.

When a borrower crosses the line

The threshold test looks back over the whole quarter. A borrower or borrower unit (Kreditnehmereinheit) is reportable if its credit volume at the lender reached or exceeded EUR 1 million at any point during the three calendar months before the reporting date (section 15(1) GroMiKV). The position at the daily close of business counts, which section 11(1) GroMiKV fixes at 24:00 CET/CEST; intraday peaks brought back under the limit by close of business are ignored, and trading book securities are left out of the test (section 15(3)). BaFin can set a different close of business for an institution on application.

Borrower units can change the answer. Section 19(2) KWG treats connected debtors as one borrower, so a company whose own loans at a bank sit well below EUR 1 million is still reportable if its unit’s total at that bank reaches the limit, and the DFBS requires a separate report for each member of the unit. Joint loans follow their own rule: where a joint loan (Gemeinschaftskredit) totals EUR 1 million or more, every participant reports, even one whose share is below EUR 1 million (section 14(1) sentence 5 KWG).

What the report contains: the EA master-data form and the BA amount records

Section 15(1) GroMiKV defines the content as two data sets: master data (Stammdaten) of the million-credit borrowers and amount data (Betragsdaten) for their credits, built around the credit definition in section 19(1) KWG. The forms split along the same line.

The EA form, field by field

The EA is the master-data notification, and section 16(1) GroMiKV requires it on two triggers only: a borrower’s credit volume reaches the limit for the first time, or one of three master-data items changes (name or firm, residence or seat, assignment to a borrower unit). Every other reportable borrower is carried quarter after quarter on an amount record alone. The DFBS narrows the first trigger further: a new borrower that the lender has identified and checked in the Bundesbank’s master-data search engine (Stammdatensuchmaschine) needs no EA unless the record there is flagged as deleted, and section 16(2) waives the filing where the Bundesbank’s database already shows the change.

The fields fall into five groups:

• Lender identification: the reporting lender or superordinated undertaking, and, for group reports under section 14(1) sentence 2 KWG, the subordinated undertaking, each with name and Bundesbank ID, plus the reporting date.
• Borrower identity: name or firm as registered, ID if known, postcode (domestic borrowers only), legal seat or residence, state and two-letter ISO 3166-1 code (foreign borrowers only), industry code from the Bundesbank’s “Bankenstatistik Kundensystematik”, register type, number and court, tax number (foreign borrowers without a register number), the US state for borrowers seated in the United States, date of birth and occupation (natural persons only), ISIN for investment funds and other constructs identified only by an ISIN, and the LEI where one exists, including pre-LEIs.
• Borrower unit: unit name and ID, a borrower supplementary key, an assignment reason code under section 19(2) KWG, the reference debtor (the next level up in the unit) and a written justification of the unit, which the form requires on first notification or on any change to the unit.
• Link to the amount data: a running number that must be unique for the reporting date, and a repeat of the amount in position BA 100 of the borrower’s amount record.
• Service and contact fields: branch, additional information, and the contact person’s name, phone and email.

Two fields look mandatory and are not. The DFBS states that the reporting-relevance code no longer needs to be completed, and it limits the borrower supplementary key to borrowers that are investment funds, closed-end funds, securitisation vehicles or monoline insurers, with three-digit codes such as 195 for special funds (Spezialfonds) and 421 for ABS vehicles. The industry code follows the Bundesbank customer classification, which is covered in our note on the Bundesbank customer classification and its 2026 update; the DFBS asks for the borrower’s main line of business.

BA amount records and their totals

Each reportable borrower gets one BA record per lender, branch and borrower. The positions group as follows (Annex 7 GroMiKV):

The BAS record carries the lender’s totals across all BA records, plus the contact person, phone and email. BA6 and BA7 handle credits in which one reporting firm lends and another secures the loan by guarantee, acceptance or similar: under section 17(3) GroMiKV the lender reports positions 080 and 121 to 123 on BA7, the securing firm reports the same positions on BA6, and position 080 carries the other lender’s ID. BAS6 and BAS7 carry the totals. The purpose, in the DFBS’s words, is to stop double counting inflating a borrower’s reported indebtedness.

Position 090 shows how the CRR fields are coded: it accepts code 0 for pure securitisation transactions, code 1 for the standardised approach, codes 2 to 7 for the specified IRB approaches, code 8 for a loan sold on a true-sale basis that remains reportable, code 9 where the lender is outside the CRR, and code 10 for an IRB approach without a calculated PD, risk weight or LGD. Code 8 requires a separate amount-data record. Only one code applies per borrower, apart from the separate code 8 record. The codes track the CRR credit risk approaches set out in our COREP reporting guide.

Position 092 reports the probability of default (PD) calculated under Article 160 or 163 CRR. Where no PD has been calculated, the DFBS says to supply no value at all, not even 0. It permits omission for codes 6 and 7 in position 090 and bars a PD for securitisation transactions. A standardised-approach lender that calculates a PD for internal purposes should report it.

Units, currency and rounding

• Amounts are reported in thousands of euro, using commercial rounding (DFBS).
• Foreign currency converts at the ECB euro reference rate for the reporting date as published by the Bundesbank, or under Article 24 CRR. Participations may stay at the rate of first booking, and currencies without a euro reference rate use mid rates from the reporting date (section 13 GroMiKV).
• The measurement basis follows section 12 GroMiKV: book value plus specific value adjustments for balance sheet assets, the present value of minimum lease payments for leasing, and the CRR exposure methods in Articles 271 to 293 and 299 CRR for derivatives and securities financing.
• The view is gross. Collateral and the borrower’s deposits do not reduce the reported amount. The DFBS allows offsetting in narrow cases only: the CRR netting of opposing positions for derivatives; a loan debited to a special account and credited at the same time to the same customer’s current account (the English booking method), which counts only at the balance if the lender has reserved the right to call the loan at any time without notice and interest and commission are charged as if on one account; and overnight claims and liabilities in the same currency that are contractually treated as one account relationship. Letters of credit backed by cover balances do not count as credit.

Reference dates and deadlines: two clocks per quarter

The observation periods are the calendar quarters, and the reporting dates are the last calendar day of March, June, September and December (section 15(2) GroMiKV). Amounts reflect the position at close of business on the reporting date. If the reporting date is not a business day, the DFBS takes the same time on the previous business day; the booking cut-off of the ledger and value-dated postings do not count.

Master data and amount data run on different clocks, and the calendar-day clock can close first:

The STA can replace an EA for million-credit purposes only if it reaches the Bundesbank early enough to be processed before the regular million-credit submission; otherwise the DFBS still requires the EA in the regular cycle. For large exposures, the DFBS states that the Bundesbank returns master data with its IDs by the 25th business day after the reporting date.

The first and last reporting dates frame the regime. The current GroMiKV has applied since 1 January 2014, and the EA form in Annex 2 takes its current source reference from BGBl. I 2019, pp. 153 to 154. At the other end, the Bundesbank’s notice of 5 October 2026 refers to the notification for reporting date 09/2026 as the last one. The statutory timing implies that no 31 December 2026 report falls due, because section 14 KWG lapses on 30 December 2026, the day before that reporting date; the notice itself does not spell this out.

Submission: paper master data to the Hauptverwaltung, XML amount files through ExtraNet

Master data goes in as a single paper copy to the Bundesbank regional office (Hauptverwaltung) responsible for the lender (section 16(1) GroMiKV). The DFBS points to the bank publishers and the Bundesbank’s online form centre for the forms, and requires self-produced versions to match the official ones. With the Evidenzzentrale’s consent, a firm may use different formats where this suits the technical process and the information content is unaffected (section 16(4)). Section 16(5) lets BaFin make electronic master-data filing mandatory by general administrative act, after hearing the firms and announcing it at least twelve months ahead; the Bundesbank’s reporting page still describes master data as paper-based, and its NExt information sheet of October 2025 states that submitting master-data notifications through NExt or ExtraNet is currently not permitted, with an electronic route via NExt planned and no schedule given.

Amount data is electronic only (section 17(1) GroMiKV), through the Bundesbank ExtraNet, by one of two routes:

• File upload: an XML file built to the file description on the Bundesbank’s formats page, submitted zipped and named to the published file-naming convention (DFBS Part IV).
• The capture platform (Erfassungsplattform der Millionenkreditanzeigen), a web interface that also lets the lender add borrowers and export what it transmitted.

Both routes need ExtraNet registration with the Evidenzzentrale, a submission declaration (Einreichungserklaerung) lodged with the regional office and, in certain cases, an indemnity declaration. Capture-platform users register for two functions: the capture platform, and the collection of notifications under section 14(2) and (3) KWG. File uploaders register for the file-submission function (Dateieinreichung bankaufsichtlicher Anzeigen und Meldungen) plus the functions for collecting notifications, file error reports and correction notifications. Where an IT service provider handles the procedure, it submits one combined file for all connected reporting firms.

For each reporting date the Bundesbank prepares a pre-filled report (vorbereitete Sammelanzeige) listing the borrowers reported last time, with a separate one per group company under its own lender number. If no reportable credit existed during the period, the prepared report needs no processing. Paper BA forms serve only to correct amount data already filed, with one amount per line, and the form of a later correction is agreed with the Bundesbank.

The return flow is what lenders get out of the procedure. The Evidenzzentrale makes its notification available electronically (section 19(1) GroMiKV), broken down into positions 100 to 102 and 110 to 150. It shows the median of the reported PDs for a borrower where the notified firm reported a PD and at least three firms did in total, and, where at least four firms reported PDs, the numerical spread calculated as the highest reported PD minus the lowest reported PD (section 19(3)). Corrections to amount data for the last two reporting dates are passed on (section 19(4)).

Validation: the checks a million-credit file has to pass

The GroMiKV sets no list of rejection reasons. The rules a file can break come from the DFBS and from the separate plausibility checks the Bundesbank publishes for million-credit reports, which the DFBS says submitters must run before sending a file. The rule numbers in that list are not reproduced here; the checks below are the ones the DFBS states directly.

Identifiers and check digits

The Bundesbank assigns every borrower, borrower unit, group of connected clients and lender a seven-digit ID with a check digit. Borrower unit IDs start with 0; borrower and lender IDs start with a non-zero digit. The check digit uses MOD 10 with weights 2 and 1 alternating from the units digit, cross sums of the products, and the difference to the next multiple of ten. The DFBS’s worked example turns base number 2508519 into check digit 2. In the BA record, lender, unit and borrower IDs are eight digits including the check digit.

Record logic

• Position 015 takes SA (collective report) or EA. A borrower ID in position 050 is allowed only with SA; an EA running number in position 060 only with EA, at most five digits and unique per lender and reporting date.
• One BA record per lender, branch and borrower. BA6 and BA7 records carry the same running number as their BA.
• Position 090 takes one code per borrower and submission date. A true-sale loan under code 8 goes in a separate record, split off through the branch field.
• BAS, BAS6 and BAS7 carry the sums of the underlying BA, BA6 and BA7 records.

Value rules

A position without a value is left out entirely, not even reported as zero. A credit that crossed the limit during the period but was repaid by the reporting date is reported with 0 in position 100 and 0 in the position of the credit type it was booked under. Borrowers that stayed below the limit for the whole period, including through their unit, must not appear in the file. And where a lender’s figure falls outside the Bundesbank’s predefined value range for a position, the DFBS asks for it to be moved to the nearest permitted value after agreement with the Bundesbank. Error reports for file submissions are collected through the ExtraNet.

Caveats and interactions: exemptions, borrower rules, AnaCredit and large exposures

Section 20 KWG takes certain credits out of the million-credit count. The DFBS lists them, including foreign exchange and securities transactions with customary advance performance settled within two and five business days respectively, and payment and settlement credits that run no longer than the next business day. Its write-off rule draws a precise line: a loan drops out only once it is written off and derecognised, while impaired loans and loans with provisions stay reportable even when fully provisioned.

Section 14 GroMiKV decides who the borrower is, and the answer often differs from the contractual counterparty a system holds:

• For guarantees and other warranties for third-party claims, the borrower is the debtor of the guaranteed claim.
• For options, the writer; for credit derivatives, both the contract partner and the reference debtors.
• For securitisation positions, units in collective investment undertakings and similar structures, the transaction itself is reported as the borrower, plus the underlying assets where the lender looks through under Article 390(7) and (8) CRR for large exposure purposes.

Non-CRR participants such as insurers may compute derivative exposures under the original exposure method in Article 282 CRR, by uniform choice that can differ across clearly defined sub-areas (section 12(3) GroMiKV). When the measurement basis changed in 2021, the DFBS recorded that BaFin and the Bundesbank would tolerate delayed implementation by participants outside the CRR, such as insurers, until 31 December 2021 at the latest.

AnaCredit runs beside this return, under its own legal basis and threshold. In December 2023, BaFin and the Bundesbank wrote to Die Deutsche Kreditwirtschaft, the banking associations’ joint body, that AnaCredit, securities statistics and large exposure reports did not yet offer an adequate equivalent to million-credit reporting, and on that basis ruled out a short-term waiver. Large exposure reporting is the closer neighbour. The STA form carries a tick-box for the reporting basis (Article 394 CRR individual, Article 394 CRR consolidated, or section 14 KWG), the STAK is for groups of connected clients only, and the DFBS reuses a borrower unit’s ID for a group of connected clients where the same entity heads both, even though the two groups can differ in membership. The CRR side of that work is set out in our guide to large exposures reporting in COREP.

Two duties attach to the data itself. Staff at a reporting firm may neither disclose to third parties nor otherwise use what the Bundesbank tells the firm under section 14(2) KWG. And section 18 GroMiKV requires the master-data and amount-data reports to be kept for the current calendar year and the two preceding ones. Whether that retention duty survives for reports already filed once section 14 KWG has gone is a question for the follow-up ordinance; the sources reviewed here do not answer it.

Recent and upcoming changes: the 2019 credit definition to the 30 December 2026 repeal

The report changed shape several times before its repeal was legislated:

• 1 January 2019: the extended credit definition, the last outstanding part of the modernisation concept for million-credit reporting, took effect. From the 31 March 2019 reporting date, data for cross-border exchange between credit registers stopped, and so did the borrower supplementary key as amount position BA 095 (DFBS).
• 28 June 2021: DFBS 2.3 took effect on the same day as CRR II and the GroMiKV as revised by the third amending ordinance. The DFBS explains that section 12 GroMiKV had to be adjusted to keep the measurement basis in line with the large exposure definitions.
• 20 December 2023: BaFin and the Bundesbank told the associations that the supervisors’ proposal of the previous year to stop million-credit reporting could not be implemented at short notice. They said a change could come with the ESCB’s Integrated Reporting Framework (IReF) and that they would return to the topic once its start and design were clearer.
• 4 February 2026: the Gesetz zur Foerderung privater Investitionen und des Finanzstandorts (StoFoeG) was signed, then published on 9 February 2026 (BGBl. 2026 I No. 33). Article 36 deletes sections 14 and 22 KWG, rewrites section 2(2) and removes section 14 from the branch rules in section 53b(3). Article 44 no. 7 deletes section 66(1) WpIG, and Article 50 no. 2 deletes section 34(6) KAGB. Article 64(2) puts all of these into force on 30 December 2026.
• 15 September 2026: the Federal Ministry of Finance put out a draft ordinance to adapt the banking-supervisory ordinances that refer to the lapsing provisions, with comments due by 30 September 2026, and BaFin is consulting separately on its own amending ordinance. None of the StoFoeG articles amends the GroMiKV itself, so these ordinances are the vehicle for its clean-up; how they treat Part 2 and its forms is not covered here.
• 5 October 2026: the Bundesbank told participating firms how the shutdown will run (details below).

The 5 October 2026 notice sets out four operational consequences. The last correction notifications under section 19(4) GroMiKV, for reporting dates 12/2025 and 03/2026, go out in October and November 2026, and none follow after 30 December 2026. From about early February 2027 the external master-data search engine is expected to show only active master data, with a notice in the search screen from late January; the search engine otherwise stays available to reporting institutions, for example for large exposure and participation reporting. In the medium term the Bundesbank plans to run it through NExt instead of ExtraNet, with no date set. And for users at firms that were subject only to million-credit reporting, in particular insurers and Kapitalverwaltungsgesellschaften, all supervisory ExtraNet and NExt permissions are expected to be deleted automatically from about February 2027, with no further notice; the 09/2026 notification stays downloadable for them until the end of January 2027.

Large exposure master data has no end date in any of these sources. The STA and STAK filings under section 8 GroMiKV serve Article 394 CRR, which a German statute cannot switch off. What the follow-up ordinances do with the section 14 KWG tick-box on the STA form is the open drafting point for reporting teams.

Frequently Asked Questions

How are investment fund share classes reported?

The DFBS treats each share class with its own ISIN as a separate borrower, and groups the share classes of one fund into a borrower unit under the name of the main fund. For an umbrella fund, the sub-fund is reported with its ISIN; for a fund of funds, the ISIN of the fund of funds unless the lender looks through. A non-public fund without an ISIN leaves the field empty, and share classes that only use the main fund’s LEI leave the LEI out of the BA record for technical reasons.

Can a branch of a foreign bank file the master-data forms in English?

Yes for master data. The DFBS states that the Bundesbank provides English versions of the master-data forms and that these can be used for filing. The English amount-data forms are only an aid: amount data goes in electronically and in German.

A borrower is a sole trader registered in the commercial register. Is that one master record or two?

Two. The DFBS says the Bundesbank builds a separate master record for the registered merchant (eingetragener Kaufmann) next to the one for the natural person. Legally dependent branches or administrative units of a borrower are not reported as separate borrowers.

What happens to a loan sold on a true-sale basis that we still report?

The DFBS gives two routes. The seller files it in a separate BA record with code 8 in position 090, split from the borrower’s other record through the branch field. Or the originator files the million-credit reports on behalf of the purchasing vehicle, which usually has factoring status.

We find an error in the 09/2026 amount data after the deadline. How is it corrected?

Corrections to amount data already filed go to the Bundesbank on paper BA forms, or in a form agreed with it. The Bundesbank’s notice names 12/2025 and 03/2026 as the reporting dates covered by the last correction notifications to other lenders, and says none follow after 30 December 2026. It does not say how a correction to 09/2026 data is handled, so that question goes to the Evidenzzentrale (mio-evidenz@bundesbank.de).

Can we still ask the Bundesbank about a prospective borrower’s debt before lending?

Until the repeal, yes: section 14(2) KWG allows a pre-lending enquiry (Vorab-Anfrage) on an existing or prospective borrower, with no minimum amount. The DFBS requires the prospective borrower’s written consent and a signed form sent by letter or fax to the regional office (email is not accepted), and the answer reflects the last completed reporting date. The right sits in section 14(2), which Article 36 StoFoeG deletes with the rest of section 14 on 30 December 2026.

Does a reporting date that falls on a weekend change the snapshot?

Yes. Where the reporting date is not a business day, the DFBS takes the amounts at the same time on the preceding business day. The deadlines stay anchored to the fixed months of January, April, July and October.

Related Articles

• AnaCredit Reporting in Germany: Bundesbank Credit Data and Deadlines: the loan-level statistical return that runs beside the million-credit procedure, with its EUR 25,000 threshold.
• Large Exposures Reporting: COREP LE: the CRR large exposure templates behind the STA and STAK master-data forms.
• Bundesbank Customer Classification in 2026: RS-57 sFEU Update and NACE Rev. 2.1: the Kundensystematik that supplies the industry code on the EA form.
• COREP Reporting Explained: the CRR credit risk approaches that feed BA positions 090 to 094 and 105 to 108.

Key Takeaways

• Last filing: reporting date 09/2026. No 12/2026 million-credit run should be built without a contrary instruction from the Bundesbank.
• EA triage: one is due only for a first-time borrower that the lender cannot identify and verify in the search engine or whose record there is flagged as deleted, or for a change of name, seat or unit membership.
• Corrections to 09/2026 data: raise them with the Evidenzzentrale before 30 December 2026; the shutdown notice is silent on later handling.
• Insurers and Kapitalverwaltungsgesellschaften that reported only million credits: download the 09/2026 notification by the end of January 2027.
• Decommissioning scope: EA, GbR, MKNE and the BA family. STA and STAK filings for large exposures continue under section 8 GroMiKV.
• Pre-lending debt enquiries and the total-debt notification both end with section 14(2) KWG on 30 December 2026.
• Watch the BMF and BaFin amending ordinances for what happens to GroMiKV Part 2 and its forms.

Sources and References

• Grosskredit- und Millionenkreditverordnung (GroMiKV), full text as last amended by Article 10 of the Act of 25 March 2026: gesetze-im-internet.de
• GroMiKV Annex 2, Meldeformular EA: gesetze-im-internet.de
• Kreditwesengesetz, section 14 (Millionenkredite): gesetze-im-internet.de
• Kreditwesengesetz, section 1 (definitions): gesetze-im-internet.de
• Kreditwesengesetz, section 2 (exceptions and scope): gesetze-im-internet.de
• Kreditwesengesetz, section 53b (EEA branches): gesetze-im-internet.de
• Kapitalanlagegesetzbuch, section 34: gesetze-im-internet.de
• Wertpapierinstitutsgesetz, section 66: gesetze-im-internet.de
• Gesetz zur Foerderung privater Investitionen und des Finanzstandorts (Standortfoerdergesetz, StoFoeG) of 4 February 2026, BGBl. 2026 I No. 33: recht.bund.de
• StoFoeG Article 36 (KWG amendments), consolidated text: buzer.de
• StoFoeG Article 44 (WpIG amendments), consolidated text: buzer.de
• StoFoeG Article 50 (KAGB amendments), consolidated text: buzer.de
• StoFoeG Article 64 (entry into force), consolidated text: buzer.de
• Deutsche Bundesbank, Millionenkreditmeldewesen service page: bundesbank.de
• Deutsche Bundesbank, Meldetechnische Durchfuehrungsbestimmung (DFBS) version 2.3, 23 April 2021: bundesbank.de (PDF)
• Deutsche Bundesbank, Information ueber Aenderungen im Zusammenhang mit der Einstellung des Millionenkreditmeldewesens zum 30.12.2026, 5 October 2026: bundesbank.de (PDF)
• BaFin and Deutsche Bundesbank, letter on million-credit reporting to Die Deutsche Kreditwirtschaft, 20 December 2023: bundesbank.de (PDF)
• Deutsche Bundesbank, NExt-Fachthema Aufsichtliches Stammdatenmeldewesen, October 2025: bundesbank.de (PDF)
• Regulation (EU) No 575/2013 (Capital Requirements Regulation): eur-lex.europa.eu
• Federal Ministry of Finance, consultation dated 15 September 2026 on the draft ordinance adapting banking-supervisory provisions following cessation of section 14 KWG reporting: bundesfinanzministerium.de

Closing the 09/2026 million-credit cycle

Article 64(2) StoFoeG fixes the legal end point. What remains is one filing and a record of it: the 30 September 2026 report, with paper master data on the calendar-day clock and the BA file on the business-day clock, and the filed EA, BA and BAS set kept afterwards. Section 18 GroMiKV, as it stands, requires those reports to be kept for the current calendar year and the two preceding ones.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.