BaFin, the ECB and Germany’s layered deposit protection

BaFin supervises German banks, with Deutsche Bank, Commerzbank and the other significant institutions under the direct supervision of the European Central Bank. Statutory deposit protection depends on the kind of bank. Private banks belong to the Entschädigungseinrichtung deutscher Banken (EdB), which protects the deposits of private persons, partnerships and corporations such as a GmbH up to EUR 100,000 per customer and per bank, pays in euro even for foreign currency accounts and excludes banks, financial service providers, insurers and the public sector. The savings banks and the cooperative banks run institutional protection schemes officially recognised as deposit guarantee schemes, with the same statutory cover. On top, the private banks’ voluntary Einlagensicherungsfonds picks up where the EdB stops for non-financial companies, within a limit tied to each bank’s own funds and only for deposit terms of up to twelve months.

GmbH capital and the account before registration

A GmbH needs share capital of at least EUR 25,000. Before the application to the Handelsregister, a quarter of each cash contribution must be paid and the total paid must reach half of that minimum capital (section 7 GmbHG); an UG (haftungsbeschränkt) must pay its whole capital in cash first. The managing directors declare that the money is finally at their free disposal, and only where the court has substantial doubts may it demand proof, such as deposit receipts from a financial institution or payment service provider established in the EU (section 8). The statute therefore does not insist on a German bank; any bank that opens an account for a GmbH in formation does so under its own policy. The articles themselves can be notarised by video (section 2(3)).

What Deutsche Bank and Commerzbank publish

Bank Online route What its own pages say
Deutsche Bank Yes, for the common legal forms of companies Identification by VideoIdent through WebID Solutions; only a valid identity card or passport is accepted; the application and its documents are in German only; the account is usually opened within a few days once everything is complete
Commerzbank Yes, with online identification For a GmbH it lists the commercial register extract, the articles, the list of shareholders and a tax identification number; an identity card or passport in every case; a company receives its photoTAN activation letter by post

Both appear on the EdB’s list of assigned banks.

The Transparenzregister check

When a bank takes on a GmbH, it must obtain proof of the company’s registration in the Transparenzregister or an extract of the data held there (section 12(3) GwG). If the register names different beneficial owners from those the bank identifies, or has no entry at all, the bank must report the discrepancy to the register without delay (section 23a GwG). Put the entry right before you apply.

No statutory right to a company account

Germany’s right to a basic account belongs to consumers lawfully resident in the EU (section 31 of the Payment Accounts Act). The Act gives a GmbH no comparable claim, so a declined company has to find a bank willing to take it on.

Why German applications stall

  • A Transparenzregister entry that is missing or differs from what the bank establishes.
  • Identity documents other than an identity card or passport, which Deutsche Bank does not accept.
  • No one able to work through German-language paperwork in Deutsche Bank’s online process.
  • Capital that is not at the managing directors’ free disposal, or doubts about it.
  • Unexplained funds or ownership layers, a matter of general bank practice.

DE IBAN and SEPA

A German IBAN has 22 characters: DE, two check digits, the eight-digit Bankleitzahl and a ten-digit account number. Germany is in SEPA.

Ready-made GmbH: what our offer page says

Our page on shelf companies with bank accounts lists Germany among the jurisdictions where pre-banked shelf companies are not readily available, so with a ready-made German GmbH plan to be onboarded as a new client. A new GmbH can be formed first and banked afterwards, since the law does not tie its capital to a German bank. We can transfer a ready-made GmbH or form a new one, assemble the onboarding pack with you and, should a suitable bank be one where we have a working contact, introduce you; the bank decides on its own. More on the Germany page.

Frequently Asked Questions on Banking a German GmbH

Can a GmbH run from abroad open a German business account?

Company law allows a GmbH to be owned and managed entirely from abroad, provided it keeps a German business address. The banks set the practical limits: Deutsche Bank identifies by VideoIdent but accepts only an identity card or passport and runs its process in German, and Commerzbank identifies online with the same documents. Neither page states a residence condition.

Does the GmbH capital have to be paid into a German bank?

No. Section 7 GmbHG requires at least a quarter of each cash contribution and half of the EUR 25,000 minimum capital to be paid before registration, and the managing directors declare that the money is at their free disposal. If the court doubts it, it may ask for receipts from a financial institution or payment service provider established anywhere in the EU.

What does a German bank need from a GmbH?

Commerzbank lists the commercial register extract, the articles, the list of shareholders and a tax identification number, plus an identity card or passport for each person identified. By law the bank must also obtain a Transparenzregister extract or proof of registration, and it must report any mismatch between that entry and the owners it identifies itself.

Which scheme protects a GmbH’s deposits in Germany?

At private banks the EdB protects a GmbH’s deposits up to EUR 100,000 per customer and per bank, and the recognised savings bank and cooperative bank schemes give the same statutory cover. The private banks’ voluntary fund adds protection for non-financial companies above that amount, limited by each bank’s own funds and to deposit terms of up to twelve months.

Can I buy a German shelf GmbH with its bank account still open?

Our own offer page lists Germany among the places where pre-banked shelf companies are not readily available. The account belongs to the GmbH and does not end automatically on a share transfer, but the bank must identify the new owners and managing directors and can keep, review or close the relationship. Buy the GmbH for its existing registration, and plan a fresh account application.

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