Disclosure requirements in Germany, Austria and Switzerland

What companies in Germany, Austria and Switzerland have to publish

If you assess target companies or win new clients in an M&A process, you need reliable financial data. But which companies are actually required to publish figures, and to what extent? This article gives you a structured overview of the statutory reporting requirements in Germany, Austria and Switzerland.

Why reporting requirements matter to M&A professionals

Before you qualify a company as a potential acquisition target or buyer, there is a fundamental question to answer: how much is actually known about this company?

The answer depends directly on which statutory disclosure requirements a company is subject to. Depending on legal form, size and location, the requirements vary considerably across the DACH region. M&A advisors, corporate finance teams and investors should be familiar with these rules, as they determine how reliable the available primary data on a company is.

Germany: disclosure requirements under the HGB

The German Commercial Code (Handelsgesetzbuch, HGB) governs disclosure requirements for corporations in Germany. They apply to the GmbH (private limited company), UG (mini-GmbH), AG (stock corporation) and KGaA (partnership limited by shares), as well as to partnerships in which no natural person bears unlimited liability, such as the GmbH & Co. KG. Sole proprietorships and traditional partnerships such as the OHG (general partnership) and KG (limited partnership) are generally not subject to public disclosure.

The scope of the requirements depends on the size of the company. Since the 2024 financial year, higher thresholds have applied (Sections 267 and 267a HGB), implementing EU Directive 2023/2775:

Micro-entities: A company falls into this category if, on two consecutive balance sheet dates, it does not exceed at least two of the following three thresholds: total assets ≤ €450,000, annual revenue ≤ €900,000 and an average of ≤ 10 employees. These companies only have to deposit their balance sheet with the Company Register (Unternehmensregister) – full publication in the Federal Gazette (Bundesanzeiger) is not required.

Small corporations: Total assets ≤ €7.5m, revenue ≤ €15m. They may file an abridged balance sheet and do not have to publish a profit and loss account. Notes to the financial statements are only required in limited form.

Medium-sized corporations: Total assets ≤ €25m, revenue ≤ €50m. These companies must file a balance sheet, profit and loss account, notes and management report – albeit in abridged form compared with large companies.

Large corporations: All thresholds exceeded. Full disclosure requirements apply: balance sheet, profit and loss account, notes, management report and the auditor’s opinion. A report of the supervisory board must also be filed, where one exists.

In Germany, the filing deadline is twelve months after the balance sheet date (Section 325 HGB). Filings are submitted to the Federal Gazette or the Company Register. If a company fails to file, the Federal Office of Justice (Bundesamt für Justiz) initiates administrative fine proceedings; penalties can range from €2,500 to €25,000.

Austria: disclosure via the company register (Firmenbuch)

The Austrian Commercial Code (Unternehmensgesetzbuch, UGB) governs disclosure requirements in Austria. Corporations (GmbH, FlexCo, AG) and partnerships in which no natural person bears unlimited liability, such as the GmbH & Co. KG, are required to file.

Austria, too, has raised its monetary thresholds by around 25% for financial years from 2024 onwards as part of EU harmonisation (Section 221 UGB):

Micro companies: Total assets ≤ €450,000, revenue ≤ €900,000, ≤ 10 employees. These may file a heavily simplified balance sheet.

Small companies: Filing of an abridged balance sheet and simplified notes; no requirement to file a profit and loss account.

Medium-sized companies: Balance sheet, profit and loss account, notes and management report; an audit is mandatory.

Large companies: Full annual financial statements with audit, extended notes and management report; listed companies face additional capital markets law requirements.

In Austria, the filing deadline is nine months after the balance sheet date – considerably shorter than in Germany. Since 1 January 2026, electronic filings have been made exclusively via justizonline.gv.at. Failure to file can result in coercive penalties of at least €700 and up to €3,600 per company and per managing director.

Switzerland: financial reporting under the Code of Obligations

Switzerland takes a different approach from Germany and Austria. The Swiss Code of Obligations (Obligationenrecht, OR) sets out the financial reporting requirements. When it comes to the scope of bookkeeping, it barely differentiates by company size or legal form – but it does so far more clearly for audit requirements and public accessibility.

Bookkeeping obligation: In principle, all sole proprietorships, partnerships and corporations (AG, GmbH) must keep accounts and prepare annual financial statements. Sole proprietorships and partnerships with annual revenue below CHF 500,000 are exempt from the full financial reporting requirements – a simple record of income and expenditure is sufficient for them.

Statutory audit: This is where Swiss law differentiates more strongly. Public interest entities (listed on a stock exchange, with bonds outstanding or with more than 500 full-time positions) are subject to an ordinary audit by a licensed audit firm. Medium-sized companies can opt for a limited audit. Very small companies can dispense with the audit altogether if all shareholders agree (opting out).

Publication requirement: Unlike in Germany or Austria, there is no general obligation in Switzerland to publish annual financial statements. Under Art. 958e OR, companies with listed securities or outstanding bonds must publish their financial statements. All other companies only have to make their financial statements available to creditors with a legitimate interest – broad public availability is not required.

This makes Switzerland the most challenging of the three DACH jurisdictions for analysts and M&A professionals: financial data on unlisted SMEs is considerably harder to obtain than in Germany or Austria.

What companies publish voluntarily, beyond their legal obligations

In addition to mandatory disclosures, many companies in the DACH region voluntarily publish further information. These voluntary reports are becoming increasingly important, particularly in the Mittelstand – the privately held, often family-owned mid-market companies typical of German-speaking Europe.

Sustainability and ESG reports: Under the EU’s Corporate Sustainability Reporting Directive (CSRD), sustainability reporting is becoming mandatory for large companies. In Germany, it applies to companies with 1,000 or more employees and revenue of more than €450m. For SMEs, reporting remains voluntary for now under the VSME (Voluntary SME Standard), which has been explicitly promoted since the EU’s Omnibus sustainability package (February 2025). Many growth-oriented Mittelstand companies already use ESG reports as a strategic tool to position themselves with investors and financing partners.

Integrated reports: Larger family businesses and Mittelstand companies that need debt financing are increasingly publishing integrated reports that combine financial and non-financial metrics. These reports are aimed at lenders, potential buyers and strategic partners.

Industry reports and association publications: Particularly in sectors with strong trade associations (mechanical engineering, chemicals, construction), companies publish aggregated industry data or take part in benchmarking studies that allow conclusions to be drawn about their own performance.

Press releases and investor relations: Growth companies and PE-backed businesses actively communicate revenue and growth figures through press releases, even though no listing rules require them to – usually to raise their profile with investors or acquisition candidates.

ProxDeal: primary data straight from annual financial statements

For M&A advisors, corporate finance teams and investors, it is essential to be able to rely on financial data that comes directly from official primary sources – not from third-party estimates or outdated database exports.

ProxDeal sources its financial metrics directly from published annual financial statements: total assets, net income for the year, net retained profits, equity ratio, cash and other primary data are processed from filings with the Federal Gazette (Germany) and the Firmenbuch (Austria), as well as from available register data (Switzerland). In other words, what you see in ProxDeal is not a model of a model – it is the company’s own published financial statements.

ProxDeal also supplements this primary data with machine-learning-based estimates of revenue, EBIT and headcount – clearly labelled and based on validated statistical models. This gives our users reliable reference values even for companies that only have to file limited data.

For companies that – like many Swiss SMEs – are not required to make public disclosures, ProxDeal combines all available register data with web analysis and company profiles to provide as complete a picture as possible.

The result: your longlists, your outreach campaigns and your market analyses are always based on the latest officially published data – not on historical figures that haven’t been updated for years. In the DACH M&A market, that is not a nice-to-have. It is the foundation of every well-informed decision.

Want to query financial metrics for target companies in the DACH region directly? Explore the ProxDeal Datafinder or build your next AI-powered longlist.