Do crypto transactions need to be reported?

Yes, crypto transactions are subject to a reporting obligation under certain conditions. The reporting obligation for crypto transactions, known as the AWG reporting obligation, applies among other things from a value of €50,000.

Legal basis: the Foreign Trade and Payments Act (AWG)

The AWG regulates cross-border payment transactions and pursues foreign trade policy objectives.

<div class="u-blog-para">§ 11 (2) AWG obliges domestic persons — meaning natural or legal persons resident or domiciled in Germany — to report certain payments to or from abroad when they exceed a specified threshold.</div>

The details are set out in the Foreign Trade and Payments Regulation (AWV). The key provision here is in particular § 67 AWV, which specifies the reporting obligation for crypto transactions.

When does a reporting obligation exist for crypto transactions?

With the growing importance of cryptocurrencies, the Deutsche Bundesbank has also clarified: cryptocurrencies qualify as financial instruments within the meaning of § 67 AWV — provided they are used in the context of a cross-border payment transaction.

Since 1 January 2025, a uniform threshold of €50,000 per transaction applies. This replaces the previously applicable limit of €12,500.

Examples of reportable crypto transactions:

• You transfer Bitcoin worth more than €50,000 to a foreign exchange or third-party wallet.
• You receive Ethereum of the same value from a private individual or company not based in Germany.
• You make a payment in stablecoins to settle an invoice outside Germany.

What is decisive for the reporting obligation is not the currency but the euro equivalent at the time of the transaction.

Who must report — and how?

The following are subject to the reporting obligation for crypto transactions:

• Private individuals resident in Germany
• Companies that are domestic legal persons
• Financial service providers domiciled domestically

For regular payments, the report is submitted via the "General Reporting Portal Statistics" (AMS) of the Deutsche Bundesbank and must generally be submitted by the 7th calendar day of the month following the payment.

What are the consequences of violating the reporting obligation for crypto transactions?

A violation of the reporting obligation constitutes an administrative offence under § 19 AWG. Penalties range from formal warnings to fines of up to €30,000.

Voluntary disclosure as an opportunity to avoid a fine

Anyone who has missed their reporting obligations for crypto transactions should not hesitate: the AWG provides for the possibility of a so-called voluntary disclosure. Anyone who voluntarily submits an omitted report retrospectively before the authorities have discovered the violation can, under certain circumstances, avoid a fine entirely.

The requirement is that the disclosure is complete and submitted in time. This offers crypto investors in particular an effective way to return to legal compliance without penalties — similar to the penalty-exempt voluntary disclosure in tax law.

<div class="u-blog-haken">Our team at Kryptoanwalt.de is happy to support you in preparing and submitting a legally secure voluntary disclosure, as well as in assessing whether a reporting obligation even exists for your crypto transaction.</div>

Conclusion: compliance pays — even with crypto

Cryptocurrencies (still) carry a hint of anonymity — but that does not exempt you from regulatory obligations. The reporting obligation for crypto transactions, specifically the AWG reporting obligation, does not serve taxation but the collection of foreign trade data by the Deutsche Bundesbank. Nevertheless: those who fail to comply risk significant penalties.

Our advice: if you regularly make or plan to make larger crypto transactions, we recommend a legal review of your circumstances — particularly for cross-border transactions. An early voluntary disclosure can avoid fines and offers a straightforward path to legally compliant reporting of crypto transactions.

<div class="u-blog-achtung">We at Kryptoanwalt.de are happy to help you keep track of your obligations — competently, discreetly and efficiently.</div>

Do you have questions?

Kryptoanwalt.de advises you comprehensively on reporting obligations, tax implications and compliance questions surrounding cryptocurrencies. Get in touch — discreetly, competently and practically.