AWV Z4 Reporting: ZABILC1, EUR 50,000 and the Seventh Working Day

Since the January 2025 reporting month, AWV Z4 reporting has run on a EUR 50,000 threshold and a single seventh-working-day deadline. A resident institutional unit in Germany generally reports qualifying incoming or outgoing payments exceeding EUR 50,000 involving non-residents, including certain payments between residents made for the account of non-residents. The duty is subject to the exemptions in section 67(2) of the Aussenwirtschaftsverordnung (AWV), including qualifying goods payments and specified short-term credit transactions. Reports under section 67(1) and (4) AWV are due by the seventh working day of the following month under section 71(6) AWV. The duty reaches individuals as well as companies, banks and public bodies, and the return the Bundesbank used to issue as form Z4 is now the ZABILC1 schema in Annex 5 of the AWV.

Much of the guidance still in circulation describes the old regime. The Bundesbank’s 2007 notice, Mitteilung Nr. 8001/2007, works with a EUR 12,500 exemption limit, and the English translation of the AWV on gesetze-im-internet.de, which includes amendments only up to 25 April 2022, still shows EUR 12,500 in section 67 and a seventh-calendar-day deadline in section 71. A report that is missing, wrong, incomplete or late is an administrative offence under section 81(2) no. 19 AWV, with fines of up to EUR 30,000 under the Aussenwirtschaftsgesetz (AWG).

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

Legal basis of AWV Z4 reporting: section 11 AWG, sections 67 to 73 AWV and Annex 5

The statutory chain has three links. Section 11(2) AWG allows a federal ordinance to require reports on cross-border transactions, payments included, so that the balance of payments of the Federal Republic of Germany can be compiled at any time, and section 11(5) AWG applies sections 9, 15 and 16 of the Federal Statistics Act (BStatG) to those reports. The AWV supplies the detail in Chapter 7. Section 63 defines resident and non-resident, section 67 imposes the payment report, section 70 adds reports specific to banks, section 71 sets the deadlines, section 72 prescribes electronic filing with the Bundesbank and section 73 lets the Bundesbank simplify or waive.

Section 67(4) AWV is where Z4 lives today. It requires reports of incoming and outgoing payments to contain the information set out in Annex 5 (Anlage 5), and reports on payments linked to securities and financial derivatives the information in Annex 6. Annex 5 is headed ZABILC1 and gives BGBl. 2024 I No. 411 as its source, the bureaucracy-relief ordinance (Verordnung zur Entlastung der Buergerinnen und Buerger, der Wirtschaft sowie der Verwaltung von Buerokratie) of 11 December 2024. The Bundesbank’s FAQ on cross-border payment reports labels the schema “ZABILC1/ ehemals Z4”, formerly Z4. Section 67(5) AWV then requires a meaningful description of the underlying service or transaction and the matching code from Annex LV, the Bundesbank’s Leistungsverzeichnis, which is the schedule of transaction codes for the balance of payments.

The data feed Germany’s balance of payments and its share of euro area and EU external statistics. Regulation (EC) No 184/2005 requires member states to deliver balance of payments data to Eurostat, and its Article 3(2) obliges those who supply information to respect the national collector’s time limits and definitions. Individual reports are confidential: the Bundesbank’s explanatory notes cite section 16 BStatG and state that individual data may not be published or passed to other bodies, tax offices included.

Enforcement runs through section 81(2) AWV. Number 19 makes it an administrative offence, whether intentional or negligent, to fail to make a section 67(1) report or to make it incorrectly, incompletely or late; number 20 does the same for the transit-trade cancellation under section 67(6). Section 81(2) attaches these offences to section 19(3) no. 1(b) AWG, and section 19(6) AWG puts that category in the bracket of fines up to EUR 30,000.

One citation trap: the 2007 notice explains the rules under sections 56a ff. and 59 ff. of the old AWV. Those numbers belong to the ordinance that the 2013 recast replaced, and in the current AWV the block from section 55 to section 62a holds the rules on screening acquisitions of German companies. An internal procedure that still cites section 59 AWV for payment reports is citing the wrong regime.

Who must report under section 67 AWV: residents, pass-through parties and banks

The duty attaches to the resident party to the payment. Section 63 AWV defines a resident (Inlaender) as any institutional unit in Germany within the meaning of the European System of Accounts, Regulation (EU) No 549/2013, and a non-resident (Auslaender) as any institutional unit abroad. Nationality plays no part. Under the residence principle the Bundesbank applies, a German citizen living abroad for more than a year is normally a non-resident and a foreign citizen living in Germany for more than a year normally a resident. The Bundesbank’s FAQ names the four groups that file ZABILC1: private individuals, businesses, banks and public bodies.

A counterparty elsewhere in the euro area is still a non-resident. The 2013 Z4 notes said so expressly for euro transfers sent through a German bank to a payee in another EU member state, Liechtenstein, Norway, Iceland or Switzerland, and the current notes treat transfers between a resident and a non-resident as payments whatever the location of the accounts.

Payments for the account of a non-resident

Section 67(1) also captures payments that a resident receives from another resident for the account of a non-resident, and payments a resident makes to another resident for the account of a non-resident. The Bundesbank’s first worked example: resident I1 owes non-resident A, resident I2 holds a claim of the same amount on A, and I1 pays I2 directly. Only a domestic transfer moves, yet I1 reports an outgoing payment and I2 an incoming payment, both against A’s country and each under the code of its own underlying transaction.

Pass-through items and trust accounts

A resident that only passes on money in another’s name and for another’s account, with no claim of its own, has nothing to report. The notes use an insurance broker forwarding premiums and claims between a German insurer and a foreign policyholder: the insurer reports, the broker does not. Payments through a trust account held by a resident trustee, such as a notary’s escrow account (Anderkonto), are reported by the underlying resident creditor or debtor. A trustee who files instead does so as a third-party submitter under the principal’s reporting number, by agreement with the principal to avoid double reporting, and has to apply for that right.

Banks: their own payments plus section 70

Section 70 AWV gives domestic Geldinstitute, the MFIs, credit institutions, financial services institutions and investment firms listed in section 70(2), three dedicated reports: purchases and sales of securities and derivatives with non-residents (Annex 6), interest and dividends on domestic securities paid to or received from non-residents (Annex 5, so ZABILC1), and card turnover in travel (Annex 7, ZABILC3). Where section 70 applies, section 67 does not. The EUR 50,000 limit applies to the securities report but, according to the Bundesbank’s notes, not to the interest and dividend report or to the card report. MFIs are also exempt from reporting payments in long-term lending under Bundesbank circular 2/2005. Section 67 itself places the duty on the resident that pays or receives; nothing in the ordinance moves a customer’s report to the bank that executes the transfer (an interpretive reading of the text).

Private individuals

Individuals report too. A person without a reporting number may report one-off payments above EUR 50,000 by email or phone (the FAQ allows up to three payments this way), giving purpose, direction, amount in euro, month and the counterparty’s country. Regular reporting needs a Meldenummer. The notes are explicit that without those details the Bundesbank cannot create the report and the duty counts as unfulfilled.

Thresholds, consolidation and branches

The exemption in section 67(2) no. 1 covers payments that do not exceed EUR 50,000 or the equivalent in another currency, so the test runs payment by payment. Where a payment combines different underlying transactions, the Bundesbank’s explanatory notes require the reportable components to be separated by transaction code if the reportable portion of the payment exceeds EUR 50,000. Individual reportable components must then be shown separately, even if each is below EUR 50,000. Components exempt under section 67(2) AWV do not themselves trigger reporting.

Reporting runs entity by entity: subsidiaries are separate institutional units under the notes and each reports under its own number, although a group can deliver several reporters’ data in one collective XML file. A German branch of a foreign company counts as a resident quasi-corporation where a significant activity can be separated from the rest of the legal entity; on that definition, which is my reading of the notes, its payments to the foreign head office are cross-border payments for this report.

What the report contains: ZABILC1 fields, Leistungsverzeichnis codes and units

ZABILC1 is a list of transaction lines under a header. The header (Kopfdaten) carries details of the reporter, the submitter, a contact for queries and the reporting date. Each line then carries the characteristics listed in Annex 5 and in the Bundesbank’s collection schema:

Codes

The version of the Leistungsverzeichnis on the Bundesbank site is dated 01/2026 and flagged as editorial changes, and the 2026 explanatory notes define each code in more detail than the annex itself. A handful show the range: 523 commissions, 533 financial services, 594 rent and operating leasing, 003 transit trade, 997 other goods trade and 989 gold. Where nothing fits, the fallback is 950 for goods and services or 951 for capital transactions, with a purpose description detailed enough for the Bundesbank to classify the payment. Cancellations, misdirected payments, double payments and refunds of prepayments go, where possible, under the code originally reported, marked as such.

Country rules

The default is the debtor’s country for incoming payments and the creditor’s country for outgoing payments. The notes list exceptions for loans and receivables (debtor’s country for loans disbursed to non-residents, their repayment and the purchase of foreign claims; creditor’s country for borrowing abroad, its repayment and the sale of domestic claims), real estate (the property’s country abroad, or the foreign investor’s country for property in Germany), construction sites abroad (the site’s country), direct investment (the investment’s country abroad, or the investor’s country for inward investment) and transit trade (seller’s country on purchase, buyer’s country on sale). Gifts take the recipient’s country on the outgoing side and the country the gift comes from on the incoming side.

Gross reporting, units and signs

The notes apply a gross principle. Set-offs and netting are payments under section 67(3) and are reported as the individual underlying transactions, with the counterparty’s country rather than the country of a group clearing centre; the balancing payment that settles a netting position is not reported. For a running account (Kontokorrent under section 355 HGB), debit entries on the resident’s books are reported as incoming payments and credit entries as outgoing payments, in one collective report for the month of booking. For ZABILC1, foreign-currency payment amounts must be converted using the corresponding ECB reference exchange rate, as specified in section 4.6 of the Bundesbank’s ZABIL format description dated 23 July 2026. The resulting euro amount is reported in whole thousands of euro, commercially rounded.

The Bundesbank’s own example shows the result. Interest of EUR 87,000 on a loan of more than twelve months from a Swiss bank is debited to the loan account, raising the German borrower’s liability. Two lines follow: outgoing, code 284, purpose “Zinsen”, amount 87, country CH, flag V; and incoming, code 261, purpose “langfristiges Darlehen”, amount 87, country CH, flag V. No money moved, and both legs are reportable.

Anyone mapping an old Z4 extract to the new XML schema should note that the paper form’s “BA” (Belegart) column, which split lines into services and transfers, other goods trade and capital transactions, is no longer a field. The Bundesbank’s NExt FAQ states that, in the XML, the payment direction field (Zahlungsrichtung) replaces it.

Reference dates and deadlines: monthly, by the seventh working day

ZABILC1 is a monthly report keyed to the month in which a payment was made or received. Section 71(6) AWV requires reports under section 67(1) in conjunction with section 67(4), bank reports under section 70(1) and transit cancellations under section 67(6) by the seventh working day of the following month. The Bundesbank states that this single date has applied to every transaction type since the January 2025 reporting month, and its notes add that Saturdays count as working days.

The Bundesbank’s published calendar for 2026 shows how the count behaves. The January 2026 report was due on 9 February 2026, the March 2026 report on 10 April 2026, and the December 2026 report is due on 11 January 2027. Beyond the Saturday rule that the notes state, two inferences follow from those dates; they are my reading of the calendar, and the notes state neither of them. Nationwide public holidays such as Good Friday and Easter Monday do not count.

Where the seventh working day lands on a Saturday, as it does for the April, July and December 2026 reporting months, the calendar shows the following Monday. Where a count and the published calendar disagree, the calendar is the Bundesbank’s own statement of the date.

Each calendar month is a reference period. For a new reporter, the first month requiring a ZABILC1 payment report is the month containing its first reportable payment, after applying both the EUR 50,000 monetary exemption and the transaction-type exemptions in section 67(2) AWV. Section 67 AWV does not expressly require a ZABILC1 nil return for every month without reportable payments. However, section 5.4 of the Bundesbank’s ZABIL format description dated 23 July 2026 provides category-specific ZABILC1 nil reports (Fehlanzeigen) and recommends their use, so nil-report functionality is not confined to the stock reports. A recommendation is not a statutory obligation.

Two timing variations exist. By exemption, the Bundesbank can let a reporter build ZABILC1 on the transfer of ownership or the booking of the claim or liability instead of the payment date; the request goes informally to Leistungsbilanz-Statistik@bundesbank.de. A running account, as above, is reported for the month of booking. On extensions the FAQ is blunt: deviations from the deadline are in principle not granted.

A month that was missed is filed as soon as the gap comes to light, under the month in which the transaction took place and not the month in which the report is prepared or sent.

Submission channel and format: AMS, NExt, XML and CSV

Section 72(1) AWV requires electronic filing with the Bundesbank under the form rules the Bundesbank issues, and section 72(3) allows any other form only with the Bundesbank’s approval.

Reporting number first

Before registering for electronic filing, a reporter needs a Meldenummer, the eight-digit reporting number formerly called Firmennummer. The same number serves transaction and stock reports, and it is requested with a Bundesbank application form sent to aw-stammdaten@bundesbank.de. Credit institutions use their bank sort code (Bankleitzahl) in its place, which is also their identifier in NExt, and they select the RIAD code when third-party submitter rights are requested in the AMS. Private individuals previously registered under the collective number 00999995 need a number of their own for NExt.

Two front doors

Registration in NExt, the Bundesbank platform that replaces the ExtraNet for file exchange, is the prerequisite for the new Allgemeines Meldeportal Statistik (AMS). The split between the two is functional:

• AMS: manual entry of ZABILC1 lines, CSV upload, third-party submitter rights and master data.
• NExt: XML upload, up to 25 files at a time, and the dialogue channel with the Bundesbank.

Non-banks and private individuals register themselves at next.bundesbank.de in work area AWN, and the first two people registered for a company become its user managers automatically. Banks with their own sort code use work area AWB, where the Bundesbank carries out the registration from a form naming the user managers.

XML file names

The NExt FAQ makes the file-name convention mandatory: work area (AWN or AWB), process mode (P for production, T for test), report type (ZABILC1), the reporter’s eight-digit Meldenummer or sort code, the reporting date as the last day of the month in YYYYMMDD form, an optional message ID and the .xml extension. The FAQ’s example is AWN.P.ZABILC1.12345678.20251231.xml.

A collective XML file may contain up to 1,000 AWV-MELDUNG-ZABILC1 report blocks covering different reporters and reporting months. This limit applies to report blocks, not individual payment lines. The file name may use the submitter’s reporting number where several reporters are included and must show the latest reporting date contained in the file. Test files marked T do not discharge the reporting duty.

CSV upload

The AMS CSV upload pre-fills the entry screen, which can be edited before sending. CSV files are semicolon-separated and UTF-8 encoded, with their content restricted to the normative characters of DIN 91379.

The Bundesbank’s NExt and AMS FAQ (answers 6.2 and 6.5) allows up to 1,000 data rows per subsection in each CSV file and up to eight files per report, with a combined size limit of 2 MB for all files of a report. Its answer on several files per report (6.11) adds that total size and transaction count may not exceed the limits. The ZABIL format description of 23 July 2026 words the row limit as 1,000 transactions per input table, with multiple files counted in total. A file set kept to 1,000 rows per subsection across the whole report satisfies each of these wordings. The ZABILC1 columns are payment direction, code, purpose, country, amount and V/E, plus chapter number, ISIN, security name and number of units where relevant.

Third-party submitters

Tax advisers, law firms and group companies can file for others. In the AMS they need third-party submitter rights (Dritteinreicherrechte); rights approved up to 18 May 2026 carried over to the new AMS, and later ones have to be requested there. Third-party submitter rights in AMS are not required merely to upload XML files through NExt. For a standard single-reporter XML submission, the reporting number in the file is checked against the file-name identifier. Collective XML submissions follow separate naming rules: one file may contain reports for several reporting entities, and the file name may use the submitter’s reporting number.

On retention, the notes recommend keeping reporting documents for at least three years, with each transaction traceable through suitable records, and cite section 11(4) AWG.

Validation, rejections and corrections for ZABILC1

Checks run at two stations. In the current AMS workflow described in the Bundesbank’s July 2026 ZABIL instructions, filers select “Pruefen und Versenden” to check a report and then “Jetzt versenden” to submit it; the September 2026 NExt and AMS FAQ names the check button “Pruefen und abschliessen” and keeps “Jetzt versenden” for submission. The submission button remains unavailable while validation errors exist; these must be corrected before the report can be sent. In NExt, an uploaded XML file gets a first technical check straight away, and the “Plausibilitaetspruefung” details under “Einreichungen und Status” show whether XML validation passed, with a feedback file listing each error. The field-level rules sit in the Bundesbank’s ZABIL format description for the XML schema.

The failure causes the Bundesbank documents are mechanical:

• a CSV file name containing characters outside A to Z or a to z, digits 0 to 9, minus, underscore and dot, or exceeding the 80-character filename limit;
• characters outside DIN 91379 inside the file;
• two files with the same name, more than eight files, or more than 1,000 rows per subsection (the ZABIL format description counts rows across all files of the report; the FAQ states the limit per file and also caps the total transaction count);
• data in columns that cannot be mapped;
• for standard single-reporter XML, a file name outside the convention, or a Meldenummer in the file that differs from the one in the name (collective files follow the separate naming rule above).

How a correction works

Corrections are additive. A correction report adds to what was filed for the month, and the original lines stay unless they are cancelled. To fix a wrong amount, code, country or ISIN, the Bundesbank’s procedure is to cancel (Storno) the wrong line first and then file the correct one, both dated to the original reporting month, and to mark the report as a correction, for example in the purpose field. In the AMS, entering a correction generates the cancellation automatically as a minus position, and users can cancel only their own submissions. The old XML schema carried a cancellation as a minus sign; the new schema reports it like the original transaction, without a minus, and flags it separately.

The Bundesbank limits how far back it wants corrections. The duty to correct has no time limit, but corrections are requested only for the current year and the three preceding calendar years, and changes below EUR 1,000 per line may be left out. For periods before the 2025 reporting year, corrections apply the EUR 12,500 limit that was in force at the time.

Re-sending a whole month as a “corrected” report duplicates every line. The FAQ says a correction lists only the transactions to be corrected or added, and the AMS submission list shows each step for a reporting date with statuses such as Eingereicht, Storno, Korrigiert and Storniert.

Caveats and interactions: goods, transit trade, crypto-assets and the stock reports

The goods exemption is narrower than it reads

Section 67(2) no. 2 exempts payments for the import, export or movement of goods. The notes confine this to cross-border goods movements recorded in foreign trade statistics (Intrastat or Extrastat, run by the Federal Statistical Office). Software or technology supplied electronically stays reportable, and price adjustments on goods arising after the event are reported under codes 600 and 602. Purchases and sales of seagoing ships and aircraft are exempt, because trade statistics record them whether or not they cross a border.

Transit trade has its own lifecycle

Buying goods abroad and selling them to a non-resident without bringing them into Germany is transit trade, code 003, reported on both the purchase and the sale with the goods chapter number. Goods placed by a foreign seller in a German customs warehouse or free zone without import clearance count as other goods trade (997), as does broken transit, where the goods are sold on to another resident before they reach a foreign buyer; gold trading is never transit trade and goes under 989. If transit goods are later imported, section 67(6) requires a “Stornierung im Transithandel” for the month of the original payment, giving the goods description, chapter number, purchase country and the originally reported amount with a minus sign. The notes still describe the minus sign; for files in the new XML schema, the NExt FAQ states that a cancellation repeats the original values without a minus and is flagged separately.

Loans, cash pools and interest

Credits and deposits with an originally agreed term or notice period of no more than twelve months are exempt under section 67(2) no. 3; interest on them is not. Cash-pool sweeps are normally short-term credits and stay out of the report, while interest paid to or by the pool above EUR 50,000 goes on ZABILC1. Interest on foreign bonds and money market paper is exempt under section 67(2) no. 4.

Crypto-assets go to ZABILC2

The amendments in force from 1 January 2025 made explicit, in section 67(3) no. 2, that the transfer of crypto-assets within section 1(11) sentence 4 of the Kreditwesengesetz counts as a payment. The notes route those transactions to ZABILC2 with codes 804 (no issuer liability, which includes stablecoins without one), 814 (foreign issuer), 824 (domestic issuer) and 834 (NFTs), with “EUR” entered as issue currency and country code “QU” where the counterparty’s country cannot be established. Our stablecoin reporting guide under MiCAR and PSD3 covers the issuer-side reporting for the same tokens.

Securities sit on ZABILC2, with one carve-out

Payments for securities and financial derivatives use Annex 6, ZABILC2. ZABILC1 carries an ISIN only for direct investment in the form of shares, and under the current annexes it also carries the banks’ interest and dividend payments on domestic securities, which the Bundesbank’s FAQ maps to the former form Z11.

Stock reports run in parallel

ZABILC1 records flows. Positions are separate: residents other than natural persons, MFIs and the investment-fund vehicles listed in section 66(2) report monthly claims and liabilities vis-a-vis non-residents once either total exceeds EUR 6 million (AUSWIB1, by the tenth working day), and direct investment stocks under sections 64 and 65 (DIREK A1 and A2). Where the section 66 duty applies, netting balances outstanding at month end belong in the AUSWIB1 stock report. Sector and residence coding also sits at the centre of the Bundesbank’s banking statistics, which our guide to Bundesbank customer classification under RS 57 covers from the bank side.

Bundesbank exemptions

Section 73 AWV lets the Bundesbank allow simplified reports or deviations from deadlines or procedures for individual reporters or groups, and grant temporary or revocable exemptions, where special reasons exist or the purpose of the rules is not impaired.

A different report from CESOP

CESOP data, which in-scope payment service providers report quarterly to tax authorities under the framework introduced by Directive (EU) 2020/284, concern qualifying cross-border payments where the provider’s count exceeds 25 payments to the same payee in a calendar quarter. Under Article 243b(2) of Directive 2006/112/EC, the threshold is calculated per Member State and payee identifier, subject to the other statutory conditions and exclusions. The data support VAT controls and are drawn from PSP records. ZABILC1 describes the resident’s own transactions for statistics. In my reading of the two frameworks, a filing under one does nothing for the other; our CESOP reporting explainer sets out the PSP side.

Recent and upcoming changes: from Z4 to ZABILC1 and the NExt cut-over

The 2007 notice of 5 March 2007 consolidated forms Z1 to Z15, K3 and K4 under the pre-2013 AWV. Up to the 2024 reporting year, the September 2013 Z4 notes then applied: a EUR 12,500 limit, filing by the seventh calendar day through the ExtraNet application AMS or by file transfer, and fallback codes 950 and 951. The bank forms Z11 to Z15 ran to the fifth calendar day.

The AWV amendments in force from 1 January 2025, which Annex 5 traces to the ordinance of 11 December 2024 (BGBl. 2024 I No. 411), reset the regime from the January 2025 reporting month:

• the exemption limit rose from EUR 12,500 to EUR 50,000;
• a single deadline, the seventh working day, replaced the different calendar-day deadlines;
• the form numbering gave way to the ZABILC1, ZABILC2 and ZABILC3 schemas in Annexes 5 to 7;
• crypto-asset transfers were expressly classed as payments, with new codes 804, 814, 824 and 834 replacing the former use of codes 139 and 239.

New XML schemas were published in December 2025, under a 2025 ZABILC1 namespace. The Bundesbank’s consolidated explanatory notes appeared as version 1.0 on 30 June 2026 and version 1.1 on 31 July 2026, folding the general notes and topic leaflets into one document based on the AWV as amended on 1 January 2025. The consolidated AWV text on gesetze-im-internet.de still carries the EUR 50,000 limit and the seventh-working-day deadline.

The Bundesbank’s current AMS page schedules the old AMS and ExtraNet to be switched off for external-sector reporting on 31 December 2026, with read-only access to the old AMS until mid-2027. Earlier Bundesbank guidance gave a different provisional cut-over date, so the current AMS page is the appropriate reference for operational planning. The old XML schemas remain accepted through NExt until 31 December 2027, and old CSV formats at least until the end of 2027.

The IMF published BPM7 on 20 March 2025. EU implementation of the revised external-sector statistical standards is being prepared; the IMF and UN implementation strategy targets a 2029 to 2030 window, and no binding EU start date in 2029 is established. The notes do not say whether BPM7 will change the ZABILC1 fields or codes, and nothing here assumes that it will.

Frequently Asked Questions

Is a payment of exactly EUR 50,000 reportable, and do several smaller payments to one supplier add up?

A payment of exactly EUR 50,000 is exempt, because section 67(2) no. 1 exempts payments that do not exceed that amount; EUR 50,000.01 exceeds the monetary exemption, but the payment is reportable only if no other exemption under section 67(2) AWV applies. The ordinance tests each payment, and the Bundesbank material I checked contains no rule that adds up separate payments within a month. Splitting one payment into instalments to stay under the limit is a different question that the guidance does not address.

A foreign customer settles our invoice through its German subsidiary. Do we report?

A receipt exceeding EUR 50,000 from a German subsidiary acting for the account of a non-resident customer may fall within section 67(1) AWV even though the payment occurs between residents. Whether it is reportable depends on the underlying transaction and the exemptions in section 67(2) AWV. For example, qualifying payments for exports of goods are exempt, whereas payments for reportable services are generally subject to reporting.

I inherited EUR 200,000 from a relative living abroad. Is that my report to make?

Yes, if you are resident in Germany: the incoming payment from abroad is yours to report, and the Bundesbank’s notes give inheritance and gifts as examples of the purpose a private reporter states. Without a Meldenummer, the one-off route is email to SZAWStat-Private@bundesbank.de or the free hotline 0800 1234 111.

We contributed patents worth EUR 1 million to a new Italian subsidiary. No cash moved. What do we report?

Section 67(3) no. 1 treats a contribution of goods or rights to a company as a payment. The Bundesbank’s example reports two lines against Italy: an outgoing capital increase in the foreign company (code 211) and an incoming payment for the patents (code 635), each EUR 1,000 thousand. The field definition requires flag E for a contribution in kind. The example’s table prints V where its text says E; the field definition is the safer guide.

Our German treasury company files for all German group entities. Who is the reporter?

Each entity remains the reporter under its own Meldenummer, and the treasury company acts as third-party submitter. In the AMS it needs third-party rights for each entity; through NExt it can send a collective XML file covering several reporters, whose name may use its own number as identifier.

We moved EUR 2 million from our German account to our own account in Switzerland and paid a Swiss supplier from there. What is reportable?

Under the Bundesbank’s FAQ, a transfer between a resident’s own domestic and foreign accounts is not itself reportable. The subsequent payment from the Swiss account to the supplier must be assessed by reference to the underlying transaction and the exemptions in section 67(2) AWV. A qualifying services payment exceeding EUR 50,000 is generally reportable, while a payment for an exempt import of goods is not. A separately agreed deposit at the foreign bank with an original term exceeding twelve months does not qualify for the short-term-credit exemption under section 67(2) no. 3.

Related Articles

• AnaCredit Reporting in Germany: Bundesbank Credit Data and Deadlines: how the Bundesbank collects loan-by-loan credit data from German banks.
• Bundesbank Customer Classification in 2026: RS-57 sFEU Update and NACE Rev. 2.1: the sector and residence coding behind German banking statistics.
• CESOP Reporting Explained: the quarterly payee data PSPs send to tax authorities for VAT control.
• Stablecoin Reporting Obligations under MiCAR, EMT and PSD3: issuer-side reporting for e-money tokens and stablecoins.

Key Takeaways

• Update procedures to cite section 67 AWV and Annex 5 (ZABILC1), and drop any reliance on section 59 AWV, the EUR 12,500 limit or the English translation that predates 2025.
• For mixed payments, test whether the reportable portion exceeds EUR 50,000; if it does, split the reportable components by transaction code.
• Diary the seventh-working-day deadline from the Bundesbank’s published calendar, counting Saturdays.
• Book set-offs gross under flag V and contributions in kind under flag E; leave the balancing payment out.
• Have each entity’s Meldenummer, NExt user managers and third-party rights in place before 31 December 2026.
• Fix errors by cancel-and-replace under the original month, applying the limit that was in force for that month.

Sources and References

• Aussenwirtschaftsgesetz (AWG), sections 11 and 19: gesetze-im-internet.de, AWG (PDF) and section 11 AWG
• Aussenwirtschaftsverordnung (AWV), sections 63 to 73, 81 and Annexes 5 to 7, consolidated text, most recently amended by Article 1 of the ordinance of 14 October 2026 (BGBl. 2026 I No. 300): gesetze-im-internet.de, AWV (HTML), AWV (PDF) and section 67 AWV
• English translation of the AWV, including amendments up to 25 April 2022: gesetze-im-internet.de, Foreign Trade and Payments Ordinance
• Verordnung zur Entlastung der Buergerinnen und Buerger, der Wirtschaft sowie der Verwaltung von Buerokratie of 11 December 2024, BGBl. 2024 I No. 411: recht.bund.de
• Deutsche Bundesbank, Mitteilung Nr. 8001/2007 of 5 March 2007 (Meldebestimmungen): Bundesbank (PDF)
• Deutsche Bundesbank, Anlage Z 4 zur AWV form and explanatory notes, September 2013: Bundesbank (PDF)
• Deutsche Bundesbank, Anlagen Z 10 bis Z 15 zur AWV (bank forms) and explanatory notes, September 2013: Bundesbank (PDF)
• Deutsche Bundesbank, Erlaeuterungen zum aussenwirtschaftlichen Meldewesen, version 1.1 of 31 July 2026: Bundesbank page and document (PDF)
• Deutsche Bundesbank, FAQ zu grenzueberschreitenden Zahlungsmeldungen: Bundesbank (PDF)
• Deutsche Bundesbank, Einreichungsfrist (submission deadlines for external-sector reports): Bundesbank page
• Deutsche Bundesbank, Allgemeines Meldeportal Statistik (AMS): Bundesbank page
• Deutsche Bundesbank, Einreichung von Meldungen fuer die Zahlungsbilanzstatistik (ZABIL), Formatbeschreibung, as of 23 July 2026: Bundesbank (PDF)
• Deutsche Bundesbank, FAQs zu NExt und AMS im Bereich der Aussenwirtschaft, as of 10 September 2026: Bundesbank (PDF)
• Deutsche Bundesbank, Leistungsverzeichnis fuer die Zahlungsbilanzstatistik (Anlage LV zur AWV), version 01/2026: Bundesbank page
• Deutsche Bundesbank, letter to external-sector reporters of 18 May 2026 on NExt and CSV upload in the AMS (then giving 31 October 2026 as the provisional ExtraNet and old AMS switch-off date): Bundesbank (PDF)
• IMF Committee on Balance of Payments Statistics and Inter-secretariat Working Group on National Accounts, Strategy for Implementing 2025 SNA and BPM7 (target implementation window 2029 to 2030): IMF (PDF)
• Eurostat, Towards ESA 2030 (EU introduction of the updated BPM planned together with the updated ESA; legislative proposal in preparation): Eurostat
• Regulation (EC) No 184/2005 on Community statistics concerning balance of payments, international trade in services and foreign direct investment: EUR-Lex
• Council Directive (EU) 2020/284 of 18 February 2020 amending Directive 2006/112/EC (Articles 243a to 243d, payment service provider records): EUR-Lex
• Irish Revenue, Tax and Duty Manual on the CESOP reporting requirement under Directive (EU) 2020/284: Revenue (PDF)

Filing ZABILC1 through the ExtraNet switch-off

Each ZABILC1 falls due on the seventh working day after its month closes, on the date the Bundesbank prints in its submission calendar, and once the old ExtraNet and AMS close for external-sector reporting, scheduled by the Bundesbank for 31 December 2026, reports travel through NExt or the new AMS. The artifact that keeps the report on time is a register of who files: each resident entity’s Meldenummer, its NExt user managers and any third-party submitter rights, plus an XML build that follows the NExt naming convention and the 2025 schema before NExt stops accepting the old schemas on 31 December 2027.

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