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The Board agreed that Germany has made satisfactory progress in implementing Requirement 2.5 on beneficial ownership of the 2019 EITI Standard.

Decision reference
2021-33 / BM-50
Decision basis
EITI Articles of Association 2019-2021, Article 12.1. ix)

The Board's decision

Following the Validation of Requirement 2.5 on beneficial ownership that commenced on 1 January 2021, the Board came to the following decision on 10 June 2021:

Germany has made “satisfactory progress” in implementing the initial criteria for Requirement 2.5 on beneficial ownership of the EITI Standard. The Board commends the government, extractive companies and civil society for working together to establish an appropriate legal framework and reporting practices for beneficial ownership disclosures. A public online register has been established, with further improvements in the reliability and accessibility of beneficial ownership data expected in future. In the second phase of implementing Requirement 2.5, Germany should ensure that all companies holding or applying for a mining license disclose their beneficial owners. Information on the legal owners of all company form should be comprehensively disclosed. Progress will be assessed in Germany’s next Validation, commencing on 1 April 2023. In accordance with the EITI Standard, Germany’s MSG may request an extension of this timeframe or request that Validation commences earlier than scheduled.


Following Germany's Validation, the EITI Board concluded on 8 May 2019 that Germany had made “satisfactory progress” in implementing the 2016 EITI Standard (see Board decision 2019-39/BC-273).

In June 2019, the EITI Board agreed a framework for assessing Requirement 2.5 on beneficial ownership. To ensure that progress on Requirement 2.5 would be assessed in all countries within a reasonable timeframe, the Board agreed that any country that had achieved overall “satisfactory progress” in a Validation that commenced or was concluded in 2019 would undergo a beneficial ownership Validation on 1 January 2021. The Board upheld this decision when agreeing on the transition to a new Validation model. The decision applies to four countries: Armenia, Germany, Nigeria and Norway.

The assessment follows the Board-agreed framework for phase 1 of assessing beneficial ownership disclosures. The Board agreed that between January 2020 and December 2021, the Validation would focus on whether the implementing country had met a set of initial criteria and provide recommendations for strengthening beneficial ownership disclosures. The progress in meeting other EITI Requirements has not been assessed as part of these Validations. Due to the transition to the new Validation model, the Board agreed an assessment on Requirement 2.5 only and did not agree an overall assessment of progress in implementing the 2019 EITI Standard.

The Secretariat’s draft assessment was sent to the German MSG on 10 March 2021. In accordance with the 2019 Validation procedure, the MSG provided feedback on the draft assessment on 12 April 2021. The Secretariat’s assessment was then finalised for review by the Validation Committee.

Corrective action

The EITI Board agreed the following recommendation to strengthen implementation in Germany. Progress in addressing the full set of criteria of Requirement 2.5 will be assessed in the next Validation commencing on 1 April 2023:

  1. To strengthen implementation ahead of the second phase of Validation of Requirement 2.5 from January 2022 onwards, Germany is encouraged to improve the accessibility of public information on the legal and beneficial owners of all companies holding or applying for extractive licenses.