COMMISSION STAFF WORKING DOCUMENT 2025 Rule of Law Report Country Chapter on the rule of law situation in Germany Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Rule of Law Report The rule of law situation in the European Union

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COMMISSION
Strasbourg, 8.7.2025
SWD(2025) 905 final
COMMISSION STAFF WORKING DOCUMENT
2025 Rule of Law Report
Country Chapter on the rule of law situation in Germany
Accompanying the document
Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions
2025 Rule of Law Report
The rule of law situation in the European Union
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ABSTRACT
The level of perceived judicial independence in Germany continues to be high among both
the general public and companies. A reform to strengthen the resilience of the Constitutional
Court was adopted, enshrining certain safeguards for its functioning and independence in the
Constitution. While some steps have been taken regarding the level of remuneration for
judges and prosecutors, challenges related to recruitment to the judiciary persist.
Digitalisation efforts in the judiciary continue, supported by a multi-annual investment
programme, though their implementation in practice varies. New rules on the creation of
specialised commercial courts have entered into force, aiming to provide more specialised
and efficient proceedings for companies in high-value disputes. The justice system overall
continues to perform efficiently and a new procedure to deal more efficiently with so-called
‘mass’ civil cases has been introduced.
The planned revision of Germany’s strategic anti-corruption framework and gift policy for
the federal administration remains pending. The enforcement of recent legislative reforms
increasing transparency and enhancing the prevention of corruption show effective results,
including with regard to the lobbying register, post-employment rules (revolving doors), and
whistleblower protection. Work to establish a fully-fledged legislative footprint is still to be
advanced, particularly for the Federal Parliament, to further enhance transparency in an
environment of strong industry interest representation. Some shortcomings remain in the
enforcement of conflicts of interest rules for parliamentarians and Government officials as
well as political party and campaign finance. Germany has modernised its public
procurement rules, carrying the potential to increase transparency and ensure equal level
playing field for businesses. Amendments to strengthen liability and sanctions of legal
persons to fight foreign bribery more effectively had advanced but were not concluded before
the end of the previous legislature. High-level corruption is addressed, and no systemic
weaknesses have been identified.
The independently functioning media regulators assumed new enforcement responsibilities,
while the reprimands of the self-regulatory body for print and online media reached a record
level. Reforms to further strengthen the independent functioning of some public service
broadcasters are progressing, while a decision not to increase the license fee triggered
constitutional challenges. The business environment for media service providers remained
overall stable, while plans to revise the media market concentration framework are
progressing. The process to establish a right to information of the press as regards federal
authorities has not advanced further, as work on a draft law came to a halt due to the early
dissolution of Parliament. The overall protection framework for journalists is good but
reports of physical and only attacks raise concern.
Consultation procedures vary in practice, with stakeholders, including from the business
sector, noting instances of particularly short consultation periods. There have been no steps
yet taken regarding the tax-exempt status of non-profit organisations, which continues to
create obstacles in practice. Civil society organisations continue to face certain challenges in
their operation, while a new strategy to better support voluntary engagement has been
adopted and welcomed by civil society.
2
RECOMMENDATIONS
Overall, concerning the recommendations in the 2024 Rule of Law Report, Germany has
made:
• Some further progress on taking measures to ensure an adequate level of remuneration for
judges and prosecutors, taking into account European standards on remuneration for the
justice system.
• No further progress on further strengthening the ‘legislative footprint’ by disclosing all
interest representatives’ inputs to legislation and by extending the scope to the
parliamentary phase of the legislative procedure.
• Some further progress on strengthening the existing rules on revolving doors by
increasing the length of cooling-off periods for federal ministers and federal
parliamentary state secretaries.
• Limited progress on advancing with the plan to create a legal basis for a right to
information of the press as regards federal authorities, taking into account European
standards on access to official documents.
• No progress on taking forward the plan to adapt the tax-exempt status for non-profit
organisations with a view to address the challenges which the currently applicable rules
present for their operation in practice, taking into account European standards on funding
for civil society organisations.
On this basis, and considering other developments that took place in the period of reference,
it is recommended to Germany to:
• Take measures to increase the resources of the judiciary and address recruitment
challenges, taking into account European standards on resources for the justice system.
• Step up efforts to strengthen the ‘legislative footprint’ to provide a comprehensive public
record to register lobbying input and to extend the scope to the parliamentary phase of the
legislative procedure.
• Advance with creating a legal basis for a right to information of the press as regards
federal authorities, taking into account European standards on access to official
documents.
• Take steps to adapt the tax-exempt status for non-profit organisations with a view to
address the challenges which the currently applicable rules present for the organisations’
operation in practice, taking into account European standards on funding for civil society
organisations.
3
I. JUSTICE SYSTEM1
Independence
The level of perceived judicial independence in Germany continues to be high among
both the general public and companies. Overall, 72% of the general population and 70% of
companies perceive the level of independence of courts and judges to be ‘fairly or very good’
in 20252
. The perceived judicial independence among the general public remains at the same
level as in 2024 (72%) although it has significantly decreased in comparison with 2021
(80%). The perceived judicial independence among companies has slightly increased in
comparison with 2024 (69%), as well as with 2021 (68%).
A reform to strengthen the resilience of the Constitutional Court was adopted,
enshrining certain safeguards for its functioning and independence in the Constitution.
The Constitutional amendment adopted in December 2024 following extensive debates
enshrines in the Constitution key features of the Constitutional Court, such as the number of
judges and the length and non-renewable nature of their mandate. One consequence is that
these rules can only be changed by a two-thirds majority, safeguarding the Court’s
independence3
. In addition, an anti-deadlock mechanism has been introduced in the law on
the Constitutional Court, which foresees that in a situation where the Bundesrat or Bundestag
would not manage to elect a new judge within three months after a proposal made by the
Constitutional Court, the other chamber steps in4
. Stakeholders welcome the reform as an
important step to safeguard the independence of the Constitutional Court5
. At the same time,
they stress the importance of further steps for the overall resilience of the justice system
beyond the Constitutional Court and welcomed on-going reflections6
. Other projects related
to strengthening judicial independence at federal level under the previous legislature7
, notably
the introduction of rules to ensure legal certainty and to increase transparency for instructions
by Ministers of Justice to prosecutors in individual cases and enshrining the respect of
constitutional values by lay judges, were ultimately not taken forward before the early
dissolution of Parliament. At the level of the Länder, reflections on how to further strengthen
the resilience and safeguard the independence of their justice systems are also on-going,
1
An overview of the institutional framework for all four pillars can be found here .
2
Figures 50 and 52, 2025 EU Justice Scoreboard and Figures 49 and 51, 2023 EU Justice Scoreboard. The
level of perceived judicial independence is categorised as follows: very low (below 30% of respondents
perceive judicial independence as fairly good and very good); low (between 30-39%), average (between 40-
59%), high (between 60-75%), very high (above 75%).
3
Law amending the Fundamental Law (Article 93 and 94). German Government (2025), written input, pp. 4-
5. 2024 Rule of Law Report, Germany, pp. 4-5. The Venice Commission has underlined the need to ensure
both the independence of the judges of the Constitutional Court and to involve different state organs and
political forces in the appointment process. Venice Commission (2004), para 18.
4
If two months after the end of mandate/retirement of a judge, no successor has been elected, the
Constitutional Court is asked to forward proposals for appointment. §7a, Law on the Constitutional Court.
5
While the Bundesrat and stakeholders had proposed a requirement for specific approval by the Bundesrat
for any future changes to the law on the Constitutional Court as an additional safeguard, this was not
ultimately taken forward. Country visit Germany, EU Affairs Committee of the Conference of Justice
Ministers, Federal Bar, Bar Association, Association of Judges.
6
Country visit Germany, Association of Judges, Bar Association, Federal Supreme Court, Federal Bar,
Federal Administrative Court. Civil society organisations (Gesellschaft für Freiheitsrechte (GFF),
Bundesnetzwerk Bürgerschaftliches Engagement (BBE)) and the German Institute for Human Rights also
shared this view.
7
2024 Rule of Law Report, Germany, pp. 5-6.
4
based on the joint Report of the Länder and Federal Ministry of Justice on ‘resilient rule of
law’ of June 20248
.
Quality
While some further progress has been made regarding the recommendation on the
remuneration for judges and prosecutors, challenges related to recruitments in the
judiciary persist9. As in past years, in the Länder the most recent collective bargaining
agreement for the civil service has been applied to the judiciary, while some Länder have
foreseen additional one-time payments10
. However, salaries of judges at the beginning of
their career continue to be slightly below the average national gross salary11
. Salary
disparities between the Länder also continue to increase12
. Stakeholders reiterate that
additional measures to ensure adequate salaries are needed, as, in a context of upcoming
retirement waves and decreasing numbers of law graduates, the judiciary faces a serious
challenge to recruit qualified personnel and be competitive against private sector salaries13
.
The expenditure for the judiciary remains overall high in relation to GDP and the Länder
have made additional efforts to create new posts14
. However, in the prosecution the workload
remains very high, with stakeholders estimating a need for around 2 000 additional posts for
prosecutors nationwide. This impacts efficiency, as figures indicate that over 900 000 cases
in the prosecution services remained open at the end of 202315
. Recruitment challenges have
influenced a lowering of the required grade to become a judge or prosecutor in several
Länder. The Constitutional Court is expected to rule in an upcoming case on salaries in
8
Conference of the Justice Ministers (2024). This includes reflections on the constitutional courts of the
Länder (in Bayern, where a reform was enacted, and Berlin, Saarland and Schleswig-Holstein), on security
checks before judges’ initial appointment (Sachsen-Anhalt, Hamburg and Schleswig-Holstein) or the
functioning of judges’ election committees (in Hamburg, where a reform was enacted, and in Thüringen,
where the re-appointment of the committee remains blocked). German Government (2025), written input, p.
5. Country visit Germany, EU Affairs Committee of the Conference of Justice Ministers and additional
written input.
9
The 2024 Rule of Law Report recommended Germany to “[t]ake measures to ensure an adequate level of
remuneration for judges and prosecutors, taking into account European standards on remuneration for the
justice system.”
10
This notably includes a raise of 5.5% as of 1 February 2025, which is reported to be applied in all Länder
except Hessen, where, after a first raise of 4.8 % as of 1 February 2025, the second raise of 5.5 % was
postponed from August 2025 to December (in Berlin, a slightly higher raise of 5.9% is applied). Family
bonuses have also been increased, in line with Constitutional Court case law. German Government (2025),
written input, pp. 7-12 and EU Affairs Committee of the Justice Ministers (2025), pp. 21-23.
11
Figure 25, 2025 EU Justice Scoreboard. The European Court of Justice has pointed out that it is appropriate
to compare the average remuneration of judges to the average salary in that State. Judgment of the CJEU,
joined Cases C-146/23 Sąd Rejonowy w Białymstoku and C-374/23 Adoreikė, para. 62. The German
authorities consider a comparison of net salaries to be more appropriate. German Government (2025),
written input, p. 3.
12
The difference between the highest and lowest salary in the Länder (entry level grade for judges) amounts
to 16% at the end of 2024, up from 12% the previous year. Association of Judges (2025b).
13
Association of Judges, Bar Association, Civil Liberties Union for Europe (Liberties), Federal Bar (2025),
written contributions, pp. 8-9, p. 12, p. 357, and p. 11, respectively. Country visit Germany, Association of
Judges, Federal Bar, Bar Association. Association of Judges (2025a). The project ZUKUNFTSGERICHTet
in Baden-Württemberg is an example of a participatory process identifying a variety of factors affecting the
recruitment of talent and employee satisfaction in the judiciary. German Government (2025b), p. 2.
14
Figure 34, 2025 EU Justice Scoreboard. German Government (2025), written input, pp. 8-12.
15
Association of Judges (2025), written input, p. 8. This figure is around 25% higher than in 2021. Data from
the Länder confirms a rise of open investigations of 19% in Baden-Württemberg, 23% in Niedersachsen
and 20% in Sachsen (all compared to 2021). EU Affairs Committee of the Justice Ministers (2025), p. 13.
5
202516
According to European standards, judges’ remuneration should be commensurate with
their profession and responsibilities17
. The coalition agreement of the new Government
commits to a re-launch of the ‘Pact for the Rule of Law’, which would also include a
strengthening of resources 18
. Taking into account certain efforts made at Länder level, there
has been some further progress on this recommendation.
Digitalisation efforts in the judiciary continue, supported by a multi-annual investment
programme, though their implementation in practice varies. The level of digitalisation of
justice is overall good, with procedural rules allowing digital technology in courts in civil,
commercial, and administrative cases in place, yet limited in criminal cases. Some gaps
remain regarding digital solutions to conduct and follow court proceedings in civil,
commercial and administrative cases, and in the availability of secure remote work for
judges, prosecutors and court staff19
. Under the digitalisation initiative for the justice system,
since 2023 the funding of 32 projects by the Federal Government and the Länder amounting
to EUR 180.4 million has been approved and implemented. The Federal Government and the
Länder also plan to build a federal justice cloud to unify different judicial software
applications, to be financed under the digitalisation initiative20
. In July 2024, rules to further
expand the possibility of video hearings in civil and specialised courts entered into force,
though stakeholders report that their implementation varies regionally21
. The much-debated
proposal to introduce digital documentation of main proceedings in criminal cases has lapsed
due to the early dissolution of Parliament22
. The systematic introduction of electronic files by
1 January 2026 is progressing, though with regional divergences23
. In January 2025, the final
report of an expert commission on the future of civil procedures was published, proposing
notably a joint e-Justice portal as the single access point for judicial information for the
federal and Länder level, advisory services and the filing of claims and applications24
.
Overall, stakeholders point to a need for further significant investments to advance the
digitalisation of justice, also in view of the notable regional disparities25
. This commitment is
included in the new coalition agreement26
.
16
The German authorities note that when the Constitutional Court previously ruled salaries in individual cases
to be insufficient, they have always been adjusted promptly. German Government (2025), written input, p.
3.
17
Committee of Ministers (2010), para. 54 and 33. See also Judgment of the Court of Justice of the European
Union, C-64/16, Associação Sindical dos Juízes Portugueses, para. 45.
18
German Government (2025a), p. 63.
19
Figures 42-50, 2025 EU Justice Scoreboard.
20
German Government (2025), written input, pp. 15-16; Ministry of Justice (2025a), p. 5. Examples of
projects include citizen-centred online services, the development of an online civil court procedure, the
promotion of the use of artificial intelligence and the creation of further IT standards at federal and Länder
level. The first operational version of the justice cloud is planned to be realised by the end of 2026. 2024
Rule of Law Report, Germany, pp. 9-10.
21
Country visit Germany, Bar Association, Federal Bar. In July 2024, a new act on the further digitalisation
of the judiciary also entered into force. German Government (2025), written input, p. 15.
22
The Federal Bar and Bar Association strongly supported this proposal, while the Länder and Association of
Judges expressed notable reservations; see 2024 Rule of Law Report, Germany, p. 10 for details.
23
German Government (2025), written input, pp. 16-21; Association of Judges (2025), written input, p. 9; Bar
Association (2025), written input, p. 10.
24
Ministry of Justice (2025b). Other proposals include the introduction of a digital proceedings document for
all statements of the parties, a uniform evidence register, and a central digital enforcement register.
25
Association of Judges (2025), written input, pp. 9-10, Bar Association (2025), written input, p. 4, Federal
Bar (2025), written input pp. 12-13. Country visit Germany, DIHK. The final report of the
6
New rules on the creation of specialised commercial courts have entered into force,
aiming to provide more specialised and efficient proceedings for companies in high-
value disputes. The federal law providing for the possibility to introduce specialised
commercial courts and chambers entered into force on 1 April 202527
. So far, nine Länder
have either already immediately introduced commercial courts and/or chambers or plan to do
so in the near future. Stakeholders generally welcome this as improving specialisation and
efficiency, though they note that the high threshold for the dispute value at the commercial
courts limits their relevance for small and medium enterprises in practice28
.. The report on the
future of the civil procedure includes suggestions to reform the chambers for commercial
matters, which is supported by business stakeholders, while also proposing to generally
support the further specialisation of judges and court chambers29
. As regards alternative
dispute resolution, the Federal Chamber of Industry and Commerce has established in
December 2024 a court of arbitration, which, subject to a contractual agreement of the
parties, offers an option for dispute resolution in national and international commercial
matters30
. Furthermore, there are 28 recognised consumer dispute resolution bodies in
Germany31
.
Efficiency
The justice system overall continues to perform efficiently and a new procedure to deal
more efficiently with so called ‘mass’ civil cases32 has been introduced. The disposition
time in administrative cases at first instance continued to decrease (from 408 days in 2022 to
391 days in 2023), though it continued to increase for litigious civil and commercial cases at
first instance (from 241 days in 2022 to 249 days in 2023). High clearance rates observed a
decrease in both litigious civil and commercial cases (104% in 2022 to 97% in 2023) as well
as administrative cases (114% to 109%)33
. To deal with the phenomenon of ‘mass’ civil court
cases, the possibility for the Federal Supreme Court to designate a case as a ‘leading
decision’ in final appeal at stake was introduced in September 2024. The lower instance can
suspend pending parallel proceedings if no substantial concerns are raised by one of the
ZUKUNFTSGERICHTet project has also highlighted the potential of digitalisation to further increase
efficiency and simplify communication. German Government (2025b), p. 3.
26
German Government (2025a), p. 65.
27
German Government (2025), written input, p. 25. 2024 Rule of Law Report, Germany, p. 11. Commercial
Courts are specialised bodies at a higher or highest regional court. Only one such court can be created per
Land. Commercial chambers can be created as specialised civil chambers at the regional courts. These
bodies can conduct proceedings fully in English and provide for more flexible and efficient procedural
arrangements.
28
Country visit Germany, DIHK. Commercial courts are competent for disputes with a minimum value of
EUR 500 000. There is no minimum threshold for disputes at the commercial chambers. These new
commercial courts and chambers should be distinguished from long-standing chambers for commercial
matters (Kammern für Handelssachen), which are distinct in both in their competence as well as
composition, as they consist of one regular judge and two lay commercial judges. These are expert judges
appointed by the chambers of industry and commerce. These chambers for commercial matters are notably
responsible for disputes involving a claim arising from a mutual commercial transaction against a registered
merchant/tradesperson, as regulated in the courts’ organisation law.
29
Ministry of Justice (2025b), p. 4.
30
See www.schiedsgerichtshof.de. Country visit Germany, DIHK.
31
German Government (2025), written input, pp. 29-30.
32
These are usually a large number of individual lawsuits, giving rise to the same key legal issues and
asserting similar claims, such as following the so-called Dieselgate scandal or relating to consumer disputes
in insurance or bank contracts.
33
Figures 6-7 and 10-11, 2025 EU Justice Scoreboard.
7
parties. The Federal Supreme Court has already applied this procedure in practice34
. The
introduction of the ‘leading decision’ constitutes one step towards a more efficient handling
of mass civil cases35
. The report on the future of the civil procedure included proposals on
further efficiency measures, such as creating specialised chambers and adapted procedural
rules to accelerate proceedings especially for complex litigation, but also for mass civil cases
36
.
II. ANTI-CORRUPTION FRAMEWORK
The perception among experts, citizens and business executives is that the level of
corruption in the public sector remains relatively low. In the 2024 Corruption Perceptions
Index by Transparency International, Germany scores 75/100 and ranks 8th
in the European
Union and 15th
globally37
. This perception has deteriorated over the past five years38
. The
2025 Special Eurobarometer on Corruption shows that 52% of respondents consider
corruption widespread in their country (EU average 69%) and 13% of respondents feel
personally affected by corruption in their daily lives (EU average 30%). As regards
businesses, 47% of companies consider that corruption is widespread (EU average 63) and
14% consider that corruption is a problem when doing business (EU average 35%).
Furthermore, 38% of respondents find that there are enough successful prosecutions to deter
people from corrupt practices (EU average 36%), while 33% of companies believe that
people and businesses caught for bribing a senior official are appropriately punished (EU
average 33%)39
.
Revisions of Germany’s Federal strategic anti-corruption framework and of its gifts
policy are still pending. The revision of the 2003 ‘Federal Government Directive
Concerning the Prevention of Corruption in the Federal Administration’ led by the Ministry
of Interior, was originally expected to be finalised by the end of 2022 but has since seen
several delays40
. It is now planned to be finalised after the adoption of the proposed EU
directive on combating corruption through criminal law to ensure alignment41
. The revision
of the 2004 rules on the prohibition to accept favours and gifts is also still ongoing with the
original date of finalisation being postponed to the end of 202542
. The comprehensive 2023
report on integrity in the federal public administration was published in September 2024,
including specific data on corruption suspicion and cases at federal level43
.
34
Federal Supreme Court (2024), VI ZR 10/24.
35
Stakeholders have highlighted the importance of addressing the challenge of mass cases more
comprehensively. Association of Judges (2025), written input, p. 11.
36
Ministry of Justice (2025b).
37
The level of perceived corruption is categorised as follows: low (above 79); relatively low (between 79-60),
relatively high (between 59-50), high (below 50).
38
In 2020, the score was 80, while, in 2024, the score is 75. The score significantly increases/decreases when
it changes more than five points; improves/deteriorates (changes between 4-5 points) and is relatively stable
(changes from 1-3 points) in the last five years.
39
Data from Special Eurobarometer 561 (2025) and Flash Eurobarometer 557 (2025).
40
2024 Rule of Law Report, Germany, pp. 13-14. The strategy is limited to corruption prevention. GRECO
(2019b), p. 4, considers it a solid framework.
41
Country visit Germany, Ministry of Justice/Ministry of Interior. UNCAC Review Report Germany, Cycle
2016-2021 (2020), p. 30, and UNCAC, Executive Summary, p. 3, encouraging a public consultation.
42
Country visit Germany, Ministry of Interior. The revision, planned since 2021, aims to assess if legal
certainty could be increased by more updated, harmonised rules, providing officials with practical
examples.
43
Ministry of Interior (2024).
8
A broad legislative framework against corruption and a renewed commitment to
address financial crime, including corruption, exist, while plans on corporate sanctions
for foreign bribery had advanced before the early dissolution of Parliament.
Stakeholders welcomed the introduction in 2024 of a new criminal offence on unlawful
influence peddling involving members of Parliament at Federal and State level, as well as
German members of the European Parliament and parliamentary assemblies of international
organisations44
. To ensure coherence, stakeholders still suggest extending the scope of the
new offence also to elected officials at the local level45
. There is no general provision to
criminalise unlawful influence peddling by other categories of public officials46
. Corporate
liability for criminal offences is rarely enforced in criminal prosecutions of foreign bribery47
,
and the Ministry of Justice had advanced work on a draft proposal to strengthen sanctions for
criminally liable companies before the early dissolution of Parliament48
. The new coalition
agreement contains commitments to tackle financial crimes, while addressing gaps in the
beneficial ownership transparency register49
. In this context, stakeholders have identified a
need for the systematic strengthening of Germany’s financial investigation and law
enforcement capacities on transnational financial flows to address, inter alia, increasing risks
of strategic corruption50
.
The German criminal justice system provides an effective response in the fight against
corruption. The treatment of corruption at the level of investigation, prosecution or final
adjudication is effective, including as regards high-level corruption cases and no systemic
weaknesses have been identified by stakeholders51
. No corruption cases or challenges in the
cooperation between the German authorities and the EPPO on corruption-related
investigations have been reported52
. After four years of investigations, proceedings started in
Germany on bribery charges in the ‘Azerbaijan affair’, involving former members of
Parliament. The level of human and financial resources as well as high specialisation for
corruption cases within the police, the financial intelligence unit, the prosecution service, and
courts are found to be overall sufficient to carry out their tasks effectively53
. The 2024
Situation Report by the Federal Criminal Police illustrates in a robust annual analysis recent
44
LobbyControl (2024b). 2024 Rule of Law Report, Germany, p. 14. Art. 108(f) Criminal Code,
complementing 108(e), which criminalises bribery involving members of Parliaments. It closes criminal
liability gaps as Art. 108(e) only applies to bribes paid in return for an act in the exercise of the mandate.
Commercial conduct of members of Parliament is not prohibited, as it is for public officials (Art. 108(e)).
45
Country visit Germany, Transparency International.
46
The Federal Court of Justice called to regulate this gap in its decision StB 7-9/22. GRECO requested
Germany to consider a stand-alone trading in influence offence. GRECO, (2019a), recommendation ix.
Similarly, UNODC, Country Review Report (2017), p. 55.
47
Federal Criminal Police Office (2024), p. 5, there were two cases in 2023 relating to Art. 335a Criminal
Code and more cases of foreign corporate corruption relating to Art. 299 Criminal Code. OECD (2021):
Enforcement targets primarily natural persons committing economic crimes, while corporate liability is
rarely enforced. Companies are liable for corruption committed by their representatives under the more
generic Act on Regulatory Offences with a fine of up to EUR 10 million and profit confiscation
possibilities.
48
Country visit Germany, Ministry of Justice. There is no reference in the Government’s coalition agreement.
49
German Government (2025a), pp. 48-49.
50
Transparency International (2025a), pp. 4-5. On 18 December 2024, Germany also adopted a new law on
the digitalisation of the financial markets amending money laundering laws.
51
Country visit Germany, Prosecution Service/ Federal Police/ Transparency International.
52
EPPO Annual Report 2024 (2025), pp. 32-33, noting the highest number of reports by private parties (719)
to the EPPO of all participating countries. EPPO (2025), written input.
53
Country visit Germany, Ministry of Interior, Federal Criminal Police, Prosecution Service.
9
trends, developments and statistics on corruption and Germany’s efforts to repress it54
. The
health sector is identified as the most affected sector by corruption crimes, while the business
and particularly the construction sector are the preferred targets for corruption. The detected
financial damage caused by corruption has notably increased compared to the previous
year55
. Of those who have been found to have accepted a bribe, 57.4% have been public
officials.
The new mandatory Lobbying Register Act is effectively enforced in practice, providing
for more transparency in the decision-making process. On 31 March 2025, the German
Federal Parliament published its first report on the maintenance of the electronic, machine-
readable Lobbying Register, which was created in 2022 and is mandatory for all interest
representatives, with certain actors exempted from the obligations, mostly for constitutional
reasons56
. The Registry will prepare such a report every two years from now on57
. With more
than 6 000 interest representative entries by mid-2025, the lobbying register is further
expanding58
. The Parliament Administration is monitoring and verifying all published data
content to ensure correctness and consistency, while also taking third parties’ compliance
monitoring into account. For the first time, sanctioning proceedings were launched59
.
Stakeholders view this initiative largely positively providing for more transparency in
Germany’s environment of strong industry interest representation60
. Work is underway to link
the Lobbying Register to the future joint digital legislative portal for the Government and
Parliament, as previously reported61
, and should be finalised by 2027.
There has been no further progress regarding the introduction of a comprehensive
public record to register lobbying input on law-making (‘legislative footprint’)62. The
Federal Government had introduced an executive footprint requiring Federal Ministries since
June 2024 to disclose the influence of lobbyists on legislative drafts63
. Lobbying input that
54
For 2023, 3 841 police-registered corruption cases (i.e. 6.7% increase compared to 2022). Federal Criminal
Police Office (2024), Situation Report - Corruption 2023. The data is not broken down by the 16 Länder,
which could help identify regional discrepancies and areas for particular attention.
55
Ibid, by approximately 111.1% amounting to EUR 57 million in 202.
56
German Federal Parliament (2025), Lobbyregister Report, covers the period 1 January 2022 to 31
December 2024. For details of the March 2024 reform, see 2024 Rule of Law Report, p. 16. Stakeholders
flag persisting shortcomings of broad exemptions for churches, employer and trade unions and the lack of
real-time reporting of lobby meetings. Country visit Germany, LobbyControl, Transparency International.
57
The next report will be published in March 2027.
58
Country visit Germany, Parliament Administration.
59
By June 2025, 25 proceedings for administrative offences had been initiated for non-registration. 6
proceedings have already been completed and the fines as administrative sanctions have been paid. German
Government (2025), written input, p. 20. Administrative fines can be imposed of up to EUR 50 000. In
addition, an audit procedure regarding a significant infringement of the Code of Conduct was carried out
and the appropriate sanction for the violation was imposed.
60
Country visit, LobbyControl, Transparency International. Note however also GRECO (2024),
recommendation (i), paras. 9-16, pp. 3-4, for ‘the transparency of the parliamentary process be further
improved, e.g. by introducing rules for members of Parliament on how to interact with lobbyists and other
third parties seeking to influence the parliamentary process.’
61
2024 EU Rule of Law report, pp. 16-17. See also below, p. 12.
62
The 2024 Rule of Law Report recommended to Germany to ‘further strengthen the ‘legislative footprint’ by
disclosing all interest representatives’ inputs to legislation and by extending the scope to the parliamentary
phase of the legislative procedure’.
63
With approx. 80-90% of the legislative drafts prepared by the Government, the majority of proposals are
thus covered by the new rules as laid down in the Joint Rules of Procedure of the Federal Ministries.
GRECO concluded in 2025 that with the Government executive footprint recommendation iv is met,
Country visit Germany, Ministry of Justice.. Abgeordnetenwatch (22 June 2023); LobbyControl (2024c).
10
contributes to a significant extent or led to changes of the core aspects of the legislative must
be disclosed. Although largely welcomed by stakeholders, the changes do not yet encompass
reporting obligations on in-person meetings between lobbyists and officials nor the disclosure
of all written contributions64
. No rules or guidelines exist for members of Parliament to attach
a ‘legislative footprint’ to reports or legislation, including a list that would demonstrate the
range of outside expertise and opinions received65
. Stakeholders called for a comprehensive
federal transparency law66
. The Federal Government, the Länder, and the Federal Parliament
continue to work on the digitalisation of the law-making process, envisaging a publicly
available joint, digitalised portal for the legislative process, for which several steps are still
planned but now planned to be finalised by 202767
. The creation of such a joint digital
legislative portal for Government and Parliament could present an opportunity to include a
fully-fledged legislative footprint68
. Against this background, there has been no further
progress on the recommendation.
Some further progress has been made regarding stricter post-employment rules for
high-level officials, with new obligations to declare post-employments showing results in
practice69. Following the new lobbying register requirements to disclose interest
representatives’ current or previous roles as public and elected officials (revolving doors) –
which stakeholders largely welcomed70
– a total of 668 (of the 27 144 registered lobbyists)
declared to have held such roles in the past five years71
. As previously reported, the
disclosure obligation for former political officials and high-ranking civil servants who had
been granted security clearance extends since 1 April 2024 to all gainful post-employment
activities and to a period of seven years following their service72
. At the same time the
cooling-off periods for state secretaries and director generals had been extended to five to
seven years (from previously three to five years)73
. For federal ministers and federal
parliamentary state secretaries, the cooling-off periods remains unchanged at 12-18 months,
which the Government justifies with the shorter period of their office, while at the same time
allowing for case-by-case decisions in practice taking into consideration the public interest
and the constitutionally guaranteed freedom of occupation74
. While the systematic
64
Civil Liberties Union for Europe (2025a), p. 353. LobbyControl (6 March 2024), indicating that it is in the
public interest to disclose also those lobbyists’ arguments that have been found not to have influenced the
respective draft law.
65
Statements made in the context of public hearings of experts are published, cf. Section 70 of the Rules of
Procedure of the German Federal Parliament. For lobbyists, there is an obligation to provide their lobbying
inputs in the lobby register, which is however not connected to the legislative outputs or ongoing work.
GRECO (2024), para. 9-16, concluding that recommendation (i)has been satisfactorily addressed by the
reform. The German approach of disclosing the content and objective of lobbying is recognised as a ‘more
effective” alternative to the transparency of all individual contacts’.
66
Transparency International (2024).
67
Country visit Germany, Parliament Administration.
68
Its introduction was planned for end-2024, then end-2025, see 2024 Rule of Law Report, Germany, p. 17.
69
The 2024 Rule of Law Report recommended to ‘strengthen the existing rules on revolving doors by
increasing the length of cooling-off periods for federal ministers and federal parliamentary state
secretaries’.
70
Country visit Germany, LobbyControl, Transparency International, GFF.
71
Since 1 March 2024, including the publication of any membership or function in the Federal Parliament or
Government. German Government (2025), written input, p. 4. Abgeordnetenwatch (7 March 2025).
72
Section 105 of the Law on Federal Public Officials. New employment is to be declared one month ahead of
the new activity’s start. The activity can be prohibited for a period of one month and, in case of non-
compliance, considered a disciplinary offence.
73
Country visit Germany, Ministry of Justice.
74
German Government (2025), written input, p. 4. Abgeordnetenwatch (7 March 2025).
11
enforcement of these cooling-off rules faces some challenges which will need to be
monitored in the future75
, there has been some progress on the recommendation regarding the
reporting of post-employments in practice.
New conflict of interest disclosure obligations for members of the Parliament entered
into force, while oversight and enforcement in practice continues to constitute
challenges. The amendments that entered into force on 30 December 2024 also concern rules
covering potential conflicts of interest76
. They extend to disclosures of conflicts of interest in
parliamentary committees but still not to ad hoc disclosures in plenary debates when a
conflict between specific private interests emerges in relation to a matter under discussion77
.
Only remunerated secondary jobs of members of the Parliament and certain shareholding in
companies that could provide for a financial conflict of interest fall under the reporting
obligations, while substantial investments in companies may fall outside the scope, if the
shareholding does not exceed the current threshold of five per cent78
. There is also still no
requirement to disclose the actual time spent on the remunerated secondary job79
. Systematic
oversight and enforcement remain an obstacle in practice with several cases of non-
compliance having raised public attention, as previously reported80
. Asset disclosure rules for
top executives remain limited in terms of oversight and transparency81
and do not extend to
liabilities and significant assets, such as shareholdings in private enterprises below the current
threshold82
. For members of the Federal Parliament assets and financial interests are only
subject to notification in the context of their parliamentary committee work. The
deliberations of an evaluation report of the Parliament’s Council of Elders is still pending83
.
Given the Parliament Administration’s limited mandate to investigate and subordination to
the Presidium of the Parliament, stakeholders continue to remark the lack of a fully
independent oversight body to investigate breaches84
.
Germany plans to evaluate its legislation on whistleblower protection. The Act for the
Better Protection of Whistleblower protection law encompasses, among others, breaches
75
For a list of revolving door cases, see Lobbypedia (2025). LobbyControl (2024a), pp. 36-37, calling for an
effective control mechanism, as there are currently no consequences in practice for the failure to report a
new employment or to comply with a decision on a cooling-off period. Similarly, GRECO (2025), 5th
Evaluation Round, recommendation vii.
76
Law amending the law on members of Parliament (30 December 2024).
77
GRECO (2021), p. 4. Similarly, ministers and parliamentary state secretaries are not yet under any
unequivocal obligation to disclose potential conflict of interests on an ad hoc basis, see GRECO (2023),
recommendation vi, pp. 8-9. Art. 49 of the Member of the Bundestag Act.
78
Abgeordnetenwatch (2024).
79
2024 Rule of Law Report, Germany, pp. 18-19.
80
2024 Rule of Law Report, Germany, p. 19. For data on the number of initiated investigations, breaches,
sanctions applied and amounts paid to the Federal budget in the last electoral term, see the Report of the
President of the German Bundestag (2025). LobbyControl (2024a); GRECO (2024), recommendation (iv),
paras. 21-27, pp. 5-6, recognising the staff increase in the Parliament Administration assigned to the lobby
register monitoring.
81
Country visit Germany, Ministry of Justice/ Ministry of Interior. The related GRECO recommendation
(viii) has not been implemented, GRECO (2024), pp. 12-13.
82
Members of the Parliament are obliged to disclose shareholdings above five percent in private corporations
or partnerships, with certain exceptions. See Art. 45(2)(6), 45(3) Member of the Bundestag Act.
83
2024 Rule of Law Report, Germany, p. 19, reported since 2021. Parts may become public upon
deliberations by the parliamentary committee. Country visit Germany, Parliament Administration. GRECO
(2022) accepted the extensive internal review carried out in 2021-2022 to meet its recommendation (iii).
84
Country visit, Germany, LobbyControl, Transparency International. GRECO (2022), p. 9.
12
related to all types of corruption crimes without the need of a link to the EU budget85
. Several
reporting offices exist at the Federal Government level, including in anti-corruption units86
.
The Federal Office for Justice, which administers the central external reporting channel, has
published its first annual report in 202487
. The second annual report is expected in the near
future. In practice, stakeholders consider the legal framework essential to supporting
whistleblower reports to uncover large-scale corruption, economic crimes, and other
wrongdoings88
. The Act for the Better Protection of Whistleblowers was planned to be
evaluated by external evaluators two years after its entry into force in July 2023. Since the
corresponding budgets have not been available, the evaluation is planned to take place shortly
after the adoption of the 2025 Federal budget89
.
New political party obligations enhance transparency, although other weaknesses
persist in party and campaign finance. The new rules regulating party sponsoring and
hidden party campaign finance at federal and Länder level contribute to increasing
transparency in party financing in practice90
. Since 1 January 2025, political parties are
required to add to their accountability reports a specific report on sponsoring91
. Any
advertising measure in support of a political party that exceeds usual forms of free speech
without the knowledge or consent of the respective political party is prohibited. Party
approved advertising is now considered a donation income to the party to which the regular
donation regulations apply92
. The new rules have been welcomed by stakeholders, although
they note that party and campaign donations are not capped93
. The collection and channelling
of party donations through foundations that are not organised as non-for-profits presented
another challenge in the recent federal elections, risking circumventing transparency rules94
.
Other challenges in practice relate to the inaccessible format of the publicly available data
and the significant time lapse until the reporting of party income, which make outside
monitoring more difficult95
. The Parliament Administration has requested additional human
resources, including for oversight on party and campaign finance96
. However, it still lacks
investigative powers, with stakeholders proposing the establishment of an independent
control body97
.
85
Apart from all crimes also misdemeanours are covered in as much as they concern important legal interests.
86
The Federal Office for Justice, the ‘Bundesanstalt für Finanzdienstleistung’ and the ‘Bundeskartellamt’
provide reporting channels at federal level.
87
Federal Office for Justice (2024). Of 410 reports, more than 90 cases were transferred to prosecution
service and ca. 160 to other authorities. Whistleblowers can report to internal or external channels. Going
public is last resort, except for imminent danger or risk of losing evidence.
88
Whistleblowers helped to unveil major scandals, such as the Cum-Ex, Wirecard and tax leaks. 2024 Rule of
Law Report, Germany, p. 21.
89
Netzpolitik (2025).
90
Among others, donation reporting requirements were lowered from EUR 50 000 to 35 000.
91
Section 24 (8a) PartG.
92
Tweets and a live interview of a foreign public figure publicly streamed at a party convention are currently
examined as to whether they constitute commercialised advertising and thus illegal foreign donations.
Country visit, Parliament Administration.
93
Transparency International (2025a).
94
Country visit Germany, GFF.
95
Country visit Germany, LobbyControl, Transparency International. LobbyControl (2023). Transparency
International (2023). The 2021 party accountability reports were published in 2023.
96
In addition to the four administrative lawyers. Country visit Germany, Parliament Administration.
97
It does not have access to donors’ tax information for data verification. UNCAC Country Review Report
Germany, Review cycle 2016-2021, p. 67. Transparency International (2023).
13
A new public procurement law was adopted to modernise public procurement, carrying
the potential to increase transparency and ensure an equal level playing field for
businesses. Businesses’ attitudes towards corruption in the EU show that 18% of companies
in Germany (EU average 25%) think that corruption has prevented them from winning a
public tender or a public procurement contract in practice in the last three years. 53% of
businesses perceive the level of independence of the Federal Cartel Office as very or fairly
good when it is reviewing public procurement cases98
. The Single Market and
Competitiveness Scoreboard on access to public procurement in Germany reports 24% of
single bids for 2023 (EU average 29%). The legislative transformation package to simplify,
digitalise and speed up public procurement procedures was adopted on 27 November 2024.
The initiative was overall welcomed by stakeholders and businesses as having the potential to
increase transparency and thus to prevent corruption in public contracting in support of an
equal level playing field for businesses99
.
III. MEDIA PLURALISM AND MEDIA FREEDOM
The independently functioning media regulators assumed new enforcement
responsibilities. The independent operation of the 14 media regulators remained ensured,
with stakeholders reporting that they continue to function well100
. The funding framework for
State Media Authorities in Germany is transparent and predictable, ensuring compliance with
regulations101
. The 5th
Interstate Media Amendment Treaty entered into force in October
2024 and aims, in particular, to adjust the media regulatory framework to the obligations of
the Digital Services Act and the corresponding national law. With the amendment, the media
regulatory authorities assumed some new enforcement responsibilities deriving from the
Digital Services Act102
. The media regulators reported that the new responsibilities resulted in
an increase of the workload103
.
Self-regulation of the media is well established, with reprimands reaching a record level
as the number of complaints treated had also increased. The German Press Council, the
self-regulatory body for press and online media, is widely accepted in the print and online
media sectors. In 2024, the number of complaints on press publications it received further
increased to 2 215 (compared to 1 850 in 2023). Many complaints continue to be related to
either violations of the journalistic due diligence or violations of the protection of privacy as
defined in the Press Code. The number of non-binding public reprimands issued by the Press
Council also increased to 86 in 2024, reaching a record level104
. The Press Code was
amended to further strengthen editorial independence by reinforcing existing rules concerning
conflicts of interest. According to the rules, editorial teams should as much as possible avoid
conflicts of interest in reporting or, at a minimum, disclose them to the audience. The
98
Figure 59, 2025 EU Justice Scoreboard.
99
DIHK (2024), p. 12, as business representation, stressing that simple and accessible digital proceedings in
the interaction with authorities are seen as highly important for businesses, reducing burden and costs and
as such also facilitating cross-border commercial activities. Coalition agreement (2025), pp. 64-65. Further
amendments are envisaged to harmonise procurement thresholds and to provide for higher direct award
ceilings, Coalition agreement (2025), pp. 64-65.
100
Country visit Germany, Association of Private Media, Joint Office of the Media Authorities.
101
2025 Media Pluralism Report (MPM), country report for Germany, p. 16-17.
102
German Government (2025), written input, p. 57.
103
Country visit Germany, Joint Office of the Media Authorities.
104
Country visit Germany, Press Council.
14
reinforced rules also apply to personal relationships or interdependencies, insofar as these
may give rise to doubts as to the necessary independence of reporting105
.
Reforms to further strengthen the independent functioning of some public service
broadcasters are progressing, while a decision not to increase the license fee triggered
constitutional challenges. The independence of the public service broadcasters remains
ensured. The Media Pluralism Monitor (MPM) 2025 confirms that the independence of
public service media is at low risk106
. The Länder signed the Interstate Reform Treaty in
March 2025, which will enter into force in December 2025, subject to the ratification by all
Länder parliaments. It aims to reduce costs for public service broadcasters and to increase
their acceptance among citizens. The Treaty also further strengthens the independent
functioning of some public service broadcasters by establishing collegial management bodies,
and by reinforcing the dismissal and appointment procedures of members of the management
bodies in line with the requirements of the European Media Freedom Act (EMFA) to ensure
editorial independence and transparent governance. A further supervisory body (Media
Council) will be established to monitor the public service remit of all public service
broadcasters, operating alongside the existing supervisory bodies and consisting of six
independent experts. A license fee remains the main source of funding for the public service
broadcasters. The Länder presented a draft proposal (Interstate Broadcasting Financing
Amendment Treaty) to adjust the funding procedure from 2027. Below certain thresholds, the
funding would be automatically adjusted in line with the recommendation of the independent
expert commission (KEF), unless respective quorums of opposing Länder are reached107
. For
the period until 2027, the Länder decided to not follow the recommendation of the KEF to
increase the license fee by 3.2%108
from the beginning of 2025109
. In response, two public
service broadcasters filed constitutional complaints, arguing that the non-adjustment of the
contribution puts the fulfilment of the public service remit at risk. Also other stakeholders
criticised the non-adjustment of funding110
.The Länder considered that an adjustment of the
fee is not necessary due to financial reserves of the public service broadcasters the amount of
which covers the additional financial requirements for two years111
. The Constitutional Court
is assessing the admissibility and merits of the complaint.
The business environment for media service providers remained overall stable, while
plans to revise the media market concentration framework are progressing.
Stakeholders reported no significant changes to the legal framework governing business
environment of media service providers112
. Access to ownership information of television,
105
Country visit Germany, Newspaper Publishers and Digitalpublishers Association, Press Council and Union
of Journalists.
106
2025 Media Pluralism Report, country report for Germany, pp. 29.
107
German Government and ZDF (2025), written inputs, pp. 58-61 and pp. 14f., respectively; Country visit
Germany, Joint Office of the Media Authorities,Ministry of State for Culture and Media and Länder media
units.
108
From EUR 18.36 to 18.94, Country visit Germany, Ministry of State for Culture and Media and Länder
media units.
109
The recommendation is part of a three-step process to determine the funding for the public service
broadcasters, with the Länder having a limited margin to deviate from the recommendation. 2024 Rule of
Law Report, Germany, p. 23.
110
Country visit Germany, Association of Journalists and Union of Journalists.
111
Country visit Germany, ARD, Ministry of State for Culture and Media, Länder media units and ZDF.
112
Country visit Germany, Association of Private Media and Newspaper Publishers and Digitalpublishers
Association.
15
radio, press, and online media remained ensured via a public database113
. The allocation of
state advertising is still considered not to be problematic. However, stakeholders criticised a
lack of level playing field between the media sector and online platforms and expressed
concerns about the continued shift in advertising spending from the media sector to online
platforms114
. The discussions on revising the media concentration framework are progressing,
although any revision will not take place before 2026115
.
There has been limited progress on the recommendation to establish a right to
information of the press as regards federal authorities since work on the draft law came
to a halt with the early dissolution of Parliament116. Some stakeholders continue to
highlight gaps in the legal framework regarding the access to information from federal
authorities117
. A legislative proposal establishing a right to information of the press from
federal authorities had been under internal preparation, with a draft law expected to be
submitted to Parliament in January 2025. However, the work on the draft law was interrupted
by the early parliamentary elections118
. Whether the new Government will continue the work
on the draft law is unknown. The right of the press to access information remains guaranteed
at regional level in the press laws of all Länder, and at federal level based on the
Constitution119
. In November 2024, the Federal Administrative Court ruled that the
constitutional right to access to information at federal level also applies to online media120
.
Stakeholders welcomed the ruling as it clarifies the rights of online media, while the federal
authorities highlighted that it only confirms the existing practise of handling requests from
online media121
. Overall, limited progress has been made on the recommendation.
The overall protection framework for journalists is good but reports of physical and
online attacks raise concern. The 2025 MPM continues to confirm an overall low risk for its
indicator on the journalistic profession, standards, and protection, but underlines increasing
concerns related, in particular, as regards attacks on journalists, both physical and online122
.
The Council of Europe Platform to promote the protection of journalism and safety of
journalists issued seven new alerts concerning Germany123
. The Mapping Media Freedom
platform recorded 151 alerts related to media freedom124
. The alerts relate mainly to cases of
attacks or threats against journalists and online harassment. Police statistics for 2024 indicate
a total of 423 registered criminal offences in the broad category ‘media’, which is an increase
113
2024 Rule of Law Report, Germany, p. 22.
114
Country visit Germany, Association of Journalists, Association of Private Media and Newspaper Publishers
and Digitalpublishers Association.
115
Country visit Germany, Ministry of State for Culture and Media and Länder media units.
116
The 2024 Rule of Law Report recommended to Germany to “[a]dvance with the plan to create a legal basis
for a right to information of the press as regards federal authorities, taking into account European standards
on access to official documents.”.
117
Reports Without Borders, written input, pp. 11f.; Country visit Germany, Association of Journalists and
Association of Private Media. However, other stakeholders reported that the current legal framework poses
no significant challenge to the work of the media. Country visit Germany, Newspaper Publishers and
Digitalpublishers Association and ZDF.
118
German Government (2025), written input, pp. 56f.
119
2024 Rule of Law Report, Germany, p. 23.
120
Decision of Federal Administrative Court, BVerwG 10 A 5.23.
121
Country visit Germany, Association of Journalists, Ministry of State for Culture and Media, Press Council,
and Union of Journalists.
122
2025 Media Pluralism Report, country report for Germany, p. 16.
123
Council of Europe Safety of Journalist Platform (2025). Germany replied to all seven of them.
124
Mapping Media Freedom (2025).
16
of approximately 42.4% (compared to 297 offences in 2023)125
. According to a report, most
physical attacks against journalists took place during the coverage of demonstrations126
.
Similarly, stakeholders raised concerns that the situation regarding the safety of journalists
appears to deteriorate127
. The public authorities at federal and Länder level continue to take
measures to ensure journalists’ safety, including by promoting exchanges between the police
and the media, or by providing trainings on press law to the Federal Police and Federal
Criminal Police Office officers. Since March 2024, the Government has co-financed a civil
society helpline that offers psycho-social support to journalists, an initiative which was
welcomed by stakeholders128
. Discussions between stakeholders and public authorities to
update the principles on conduct for the media and the police stalled129
. Strategic lawsuits
against public participation (SLAPPs) targeting journalists remain generally not a concern for
the media sector130
. However, the findings of a study show that three out of four intimidation
attempts to prevent public participation, notably through SLAPPs, are directed against media
professionals131
. Preparations are underway to allow for data on SLAPP cases to be
collected132
. Stakeholders welcomed that the Government started providing financial support
to a civil society contact point for the protection of journalistic work against SLAPPs. It
offers information and counselling for individuals affected by SLAPPs and raises public
awareness of the issue through outreach measures133
. Stakeholders continued to call for
changes to the prohibition of verbatim publication of official documents in criminal
proceedings, arguing that this prohibition could restrict reporting and constitutes an
unjustified limitation on the freedom of the press, however the authorities consider this
necessary to safeguard the confidentiality of the proceedings134
.
IV. OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES
Consultation procedures continue to vary in practice, with stakeholders, including from
the business sector, noting instances of particularly short consultation periods. The
recommended consultation period for draft laws at the federal level is four weeks135
.
However, stakeholders note that the duration of consultations in practice varies between
Ministries and can sometimes amount to only a few days also on complex and technical
125
These 423 cases include 44 cases of violent offences, Reply of the Federal German Interior Ministry (Letter
No ÖSII3.53006/6#32).
126
For example, Reporters Without Borders reported a significant increase of physical attacks against
journalists in 2024, with 75 verified physical attacks. Out of these, 38 took place during demonstrations on
the Israeli-Palestinian conflict. Reporters Without Borders (2025).
127
Country visit Germany, BBE, Newspaper Publishers, and Digitalpublishers Association and Union of
Journalists.
128
Country visit Germany, Newspaper Publishers and Digitalpublishers Association and Ministry of State for
Culture and Media.
129
Reporters Without Borders, written input, p. 15.
130
Country visit Germany, Association of Private Media, Newspaper Publishers and Digitalpublishers
Association and ZDF; Reporters Without Borders (2025), written input, pp. 16f.
131
The findings are based on a non-representative survey. Otto Brenner Stiftung (2025); Country visit
Germany, Association of Journalists, Union of Journalists and GFF.
132
Country visit Germany, Federal Ministry of Justice and Consumer Protection.
133
Country visit Germany, Union of Journalists and Ministry of State for Culture and Media.
134
The prohibition of verbatim publication concerns documents before they have been discussed in a public
hearing or the proceedings have been concluded. Country visit Germany, Association of Journalists,
Newspaper Publishers and Digitalpublishers Association, Ministry of State for Culture and Media, and
GFF; ZDF (2025), written input, p. 15.
135
2024 Rule of Law Report, Germany, p. 26.
17
proposals, as also pointed out by business stakeholders136
. A 2024 study based on data
provided by the respective Ministries showed that between 2017 and 2023, in two thirds of
proposals, the consultation period was below four weeks137
. As regards parliamentary
hearings, the German Institute for Human Rights points out that there has been no follow-up
yet to the recommendation by the GANHRI Sub-Committee for Accreditation to formalise
the institute’s participation therein138
.
Over half of the companies surveyed in Germany express confidence in the effectiveness
of investment protection. 58% of companies are very or fairly confident that investments are
protected by law and courts139
. As regards authorities relevant for economic operators 56%
perceive the level of independence of the Federal Cartel Office as very or fairly good when it
is deciding in competition matters140
. A number of judicial mechanisms are in place at the
level of the Federal Administrative Court to ensure the implementation of administrative
court judgments, which include the possibility to quash administrative decisions for
continued non-compliance with court’s instructions. However, these mechanisms do not
include the use of direct enforcement measures or the possibility to award direct or
consequential damages or compensation141
. A joint proposal from the Federal Government
and the Länder to improve enforcement of administrative court decisions against non-
compliant public authorities has not been pursued further yet142
.
On 1 January 2025, Germany had 9 leading judgments of the European Court of
Human Rights pending implementation, an increase of 1 compared to the previous
year143. At that time, Germany’s rate of leading judgments from the past 10 years 10 years
that had been implemented was at 71% (compared to 67% in 2024; 29% remained pending),
and the average time that the judgments had been pending implementation was 3 years and 8
months (compared to 4 years in 2024)144
. The oldest leading judgment, pending
implementation for 7 years, concerns a violation of the right to respect for private life on
account of the inspection of the applicant lawyer’s professional bank account by the public
prosecution office for a period of over two years in the context of criminal investigations
against his client145
. As regards the respect of payment deadlines, on 31 December 2024 there
136
Liberties (2025), written input, p. 368-369; Federal Bar (2025), written input, p. 23, Bar Association (2025),
written input, p. 21. As also confirmed by the DIHK, Allianz für Rechtssicherheit and BBE in the Country
visit Germany.
137
Frag den Staat (2024).
138
Global Alliance of National Human Rights Institutions (2023), p. 12. German Institute for Human Rights
(DIMR) (2025), written input, p. 3.
139
Figure 54, 2025 EU Justice Scoreboard. Only 18% and 15% of the surveyed investors respectively perceive
the frequent changes in legislation or concerns about the quality of the law-making process, and the quality,
efficiency or independence of justice, respectively, as a reason for the lack of confidence in investment
protection.
140
Figure 50, 2025 EU Justice Scoreboard.
141
Figure 49, 2025 EU Justice Scoreboard. The data presented reflects exclusively the mechanisms in place at
the level of the highest administrative jurisdictions; the same or other mechanisms may be in place at lower
instance administrative courts.
142
Report of the Bund-Länder Working Group “Resilient Rule of Law” (2024), pp. 50-52.
143
For an explanation of the supervision process, see the website of the Council of Europe.
144
All figures calculated by the European Implementation Network (EIN) and based on the number of cases
that are considered pending at the annual cut-off date of 1 January 2025. EIN (2025), written input, p. 4.
145
Judgment of the ECtHR, 73607/13, Sommer v. Germany, pending implementation since 2017.
18
was no case awaiting confirmation of payments (compared to 1 in 2023)146
. On 16 June 2025,
the number of leading judgments pending implementation had decreased to 7147
.
There has been no progress yet on the recommendation to adapt the tax-exempt status
of non-profit organisations, which continues to create obstacles in practice148. An attempt
to clarify the actual legal situation regarding the understanding of ‘occasional political
activity’ permissible for non-profit organisations was not taken forward under the previous
legislature149
. Civil society organisations (CSOs) therefore face the same obstacles as
previously reported, notably the uncertainty as to what type of political activity unrelated to
the non-profit purpose of their organisation is permissible, the limited catalogue of grounds
for non-profit status and limitations on the use of ‘political means’ to achieve the
organisation’s stated purpose. This situation continues to impact the operating space for
CSOs in practice, and can create a chilling effect, as CSOs can be targeted by being reported
upon to the tax authorities for alleged non-compliance with their non-profit status150
. The
coalition agreement commits to simplifying the law for non-profit organisations, though it is
not clear yet whether this would address the specific challenges identified in the
recommendation151
. Therefore, there has been no progress yet on the recommendation.
Civil society organisations continue to face some challenges to their operations, while a
new strategy to better support voluntary engagement was adopted and welcomed by
civil society. Civic space continues to be considered as ‘narrowed’152
. Concerns related to the
application of bans or other restrictions of protests and policing practices persist, as recently
highlighted by the Council of Europe Commissioner of Human Rights 153
, with a number of
these measures subject to judicial review154
. Assembly laws of certain Länder continue to be
subject to judicial review, while a new assembly law in Sachsen was criticised for potentially
curbing freedom of assembly155
. As regards access to funding for CSOs, the programme
146
Council of Europe (2025), p. 156.
147
Data according to the online database of the Council of Europe (HUDOC).
148
The 2024 Rule of Law Report recommended Germany to “[t]ake forward the plan to adapt the tax-exempt
status for non-profit organisations with a view to address the challenges which the currently applicable rules
present for their operation in practice, taking into account European standards on funding for civil society
organisations.”
149
This provision, which already exists at the level of an administrative decree, was set to be included in the
Taxation Development Law but was not retained in the finally adopted version. Liberties (2025), written
input, pp. 373-374. 2024 Rule of Law Report, Germany, pp. 28-29.
150
See Allianz Rechtssicherheit für politische Willensbildung (2025), an alliance of over 200 German CSOs,
for a summary of suggested improvements to the current system. Liberties (2025), written input, pp. 373-
374, DIMR (2025), written input, pp. 7-8. Civil Society Europe (CSE) (2025), written input, p. 7.
151
German Government (2025a), p. 47.
152
Rating given by Civicus, Germany. Ratings are on a five-category scale defined as: open, narrowed,
obstructed, repressed, and closed.
153
The letter expresses concerns in relation to restrictions of freedom of expression and of peaceful assembly
of persons protesting in the context of the conflict in Gaza. Council of Europe Commissioner of Human
Rights (2025). See also further on this European Legal Support Centre (2025), documenting 766 incidents
of repression in this context in Germany since 2019.
154
Liberties (2025), written input, pp. 374-376; DIMR (2025), written input, pp- 5-6; CSE (2025), written
input, pp. 5-7. CIVICUS (2024). See also German Institute for Human Rights (2024), pp. 15-17, on protest
bans and their impact. 2024 Rule of Law Report, Germany, pp. 29-30. For example, in one case, the use of
so-called ‘pain grips’ by police to remove peaceful protestors has been found to be unlawful by a first
instance court. Gesellschaft für Freiheitsrechte (2025a).
155
DIMR (2025), written input, p. 6. The constitutional challenge against the assembly law of Nordrhein-
Westfalen remains pending. In March 2025 the Hessen assembly law was largely upheld as constitutional.
Judgment of the Hessen Constitutional Court, P.St. 2920, P.St. 2931.
19
“Demokratie Leben!” has been extended. The proposal for a federal ‘democracy support law’
was not adopted under the previous legislature156
. Some stakeholders report that CSOs
working on issues perceived as contentious face increasing challenges157
and CSOs
welcomed the clear stance by the Government as regards their right to the freedom of
assembly and to be politically active158
. CSOs also positively assess the federal strategy for
voluntary engagement adopted in December 2024 following an extensive stakeholder
consultation process, while noting the need for adequate resources and monitoring159
. The
strategy provides a framework to facilitate and support voluntary engagement, focussing
among others on addressing structural challenges for engagement and supporting the digital
transformation of civil society.
156
CSE (2025), written input, pp. 8-9.
157
Liberties (2025), written input, p. 372.
158
German Government (2025b). Country visit Germany, Allianz für Rechtssicherheit, BBE, GFF.
159
Ministry for Family Affairs, Senior Citizens, Women and Youth (2024); Country visit Germany, BBE.
20
Annex I: List of sources in alphabetical order*
* The list of contributions received in the context of the consultation for the 2025 Rule of Law report
can be found at https://commission.europa.eu/publications/2025-rule-law-report-targeted-
stakeholder-consultation_en.
Abgeordnetenwatch (2025), New Bundestag: These three members of parliament are listed in the
lobby register (Neuer Bundestag: Diese drei neuen Abgeordneten stehen im Lobbyregister),
https://www.abgeordnetenwatch.de/recherchen/lobbyismus/diese-drei-neuen-abgeordneten-stehen-im-
lobbyregister.
Abgeordnetenwatch (2024), These are the additional earnings of members of the Bundestag (Diese
Nebeneinkünfte haben die Abgeordneten im Bundestag),
https://www.abgeordnetenwatch.de/recherchen/nebentaetigkeiten/diese-nebeneinkuenfte-haben-die-
abgeordneten-im-bundestag.
Abgeordnetenwatch (2023), Lobby register 2.0? Full lobby transparency still does not exist
(Lobbyregister 2.0? Volle Lobbytransparenz gibt es immer noch nicht),
https://www.abgeordnetenwatch.de/kampagnen/lobbyregister-20-volle-lobbytransparenz-gibt-es-
immer-noch-nicht.
Allianz Rechtssicherheit (2025), Demands to change the legal situation (Forderungen zur Änderungen
der Rechtslage), https://www.zivilgesellschaft-ist-gemeinnuetzig.de/forderungen/.
Beck-aktuell (2025), AfD blockade: Can Thuringia still appoint judges for life? (AfD-Blockade: Kann
Thüringen noch Richter auf Lebenszeit ernennen?),
https://rsw.beck.de/aktuell/daily/meldung/detail/afd-blockade-thueringen-richter-ernennung-
wahlausschuss.
Bundesnetzwerk Bürgerschaftliches Engagement (BBE) (2025), Political neutrality of non-profit
organizations and the legal framework for non-profit organizations (Politische Neutralität
gemeinnütziger Organisationen und gemeinnützigkeitsrechtliche Rahmenbedingungen),
https://www.b-b-e.de/projekte/bundestagswahl-2025-und-zivilgesellschaft/rechtspolitische-
rahmenbedingungen-und-zivilgesellschaft-1/.
CDU, CSU and SPD (2025), Responsibility for Germany: Coalition Agreement between CDU, CSU
and SPD (Verantwortung für Deutschland: Koalitionsvertrag zwischen CDU, CSU und SPD),
https://www.cdu.de/app/uploads/2025/04/Koalitionsvertrag-2025-1.pdf.
Centre for Media Pluralism and Media Freedom (2024), Media Pluralism Monitor 2024.
Centre for Media Pluralism and Media Freedom (2025), Media Pluralism Monitor 2025.
Civil Liberties Union for Europe (2025), Contribution from Civil Liberties Union for Europe for the
2025 Rule of Law Report.
Civil Liberties Union for Europe (2025a), Liberties Rule of Law Report,
https://www.liberties.eu/en/stories/rolreport2025-main/45330.
Civil Society Europe (2025), Contribution from Civil Society Europe for the 2025 Rule of Law
Report.
Civicus (2025), Repression of Palestine Solidary Continues: Raids, Detentions and Police Brutality,
https://monitor.civicus.org/explore/repression-of-palestine-solidarity-continues-raids-detentions-and-
police-brutality/.
Conference of the Justice Ministers (2024), Report of the working group ‘resilient rule of law’
(Bericht der Bund-Länder-Gruppe “Wehrhafter Rechtsstaat”),
https://www.mj.niedersachsen.de/download/208073.
21
Council of Europe (2025), Supervision of the execution of judgments decisions of the European Court
of Human Rights – 18th Annual Report of the Committee of Ministers – 2024, https://rm.coe.int/gbr-
2001-18e-rapport-annuel-2024/1680b4d77d.
Council of Europe Commissioner of Human Rights (2025), Letter to the German Federal Minister of
the Interior, https://rm.coe.int/letter-to-federal-minister-of-the-interior-germany-by-michael-o-
flaher/1680b64870.
Council of Europe: Committee of Ministers (2007), Recommendation CM/REC(2007)14 of the
Committee of Ministers to member states on the legal status of non-governmental organisations in
Europe.
Council of Europe: Committee of Ministers (2010), Recommendation CM/Rec(20010)12 of the
Committee of Ministers on judges: independence, efficiency and responsibilities.
Council of Europe: Platform to promote the protection of journalism and safety of journalists –
Germany, https://fom.coe.int/en/pays/detail/11709520.
Council of Europe: Venice Commission (2004), Moldova - Opinion on the Proposal to Amend the
Constitution of the Republic of Moldova (introduction of the individual complaint to the
Constitutional Court), (CDL-AD(2004)043).
Council of Europe: Venice Commission (2010), Report on the role of the opposition in a democratic
Parliament (CDL-AD(2010)025).
Council of Europe: Venice Commission (2019), Parameters on the relationship between the
parliamentary majority and the opposition in a democracy: a checklist (CDL-AD(2019)015).
Court of Justice of the European Union, judgment of 27 February 2018, Associação Sindical
dos Juízes Portugueses, C-64/16, ECLI:EU:C:2018:117, para. 45.
Court of Justice of the European Union, judgment of 25 February 2025, joined cases Sąd Rejonowy w
Białymstoku and Adoreikė, C-146/23 and C374/23, ECLI:EU:C:2025:109, para. 62.
DIHK, Survey on internal market barriers (Umfrage zu Binnenmarkthindernissen) 2024,
https://www.dihk.de/resource/blob/115606/0fa0f8cfe1b492f0d16e7ddd2ab8feee/eu-dihk-
binnenmarktumfrage-2024-data.pdf.
Directorate-General for Communication (2025), Flash Eurobarometer 557 on businesses’ attitudes
towards corruption in the EU and selected candidate countries.
Directorate-General for Communication (2025), Special Eurobarometer 561 on citizens’ attitudes
towards corruption in the EU.
European Centre for Press and Media Freedom, Mapping Media Freedom, Germany country profile,
https://www.mappingmediafreedom.org.
European Commission (2021), 2021 Rule of Law Report, Country Chapter on the rule of law situation
in Germany.
European Commission (2022), 2022 EU Justice Scoreboard.
European Commission (2022), 2022 Rule of Law Report, Country Chapter on the rule of law situation
in Germany.
European Commission (2023), 2023 Rule of Law Report, Country Chapter on the rule of law situation
in Germany.
European Commission (2024), 2024 Rule of Law Report, Country Chapter on the rule of law situation
in Germany.
European Commission (2025), 2025 Rule of Law Report, Country Chapter on the rule of law situation
in Germany.
European Court of Human Rights, judgment of 27 April 2017, Sommer v. Germany, 73607/13.
22
European Implementation Network (2025), written input for the 2025 Rule of Law Report.
European Legal Support Centre (2025), Press release on the launch of the index of repression,
https://elsc.support/scope-and-patterns-of-anti-palestinian-repression-in-germany-revealed-repression-
is-systematic-institutional-and-undeniable/.
European Public Prosecutor (EPPO), Annual Report 2024 (2025),
https://www.eppo.europa.eu/assets/annual-report-2024/index.html
Federal Criminal Police Office (2024), Federal Situation Report - Corruption 2023,
https://www.bka.de/SharedDocs/Downloads/DE/Publikationen/JahresberichteUndLagebilder/Korrupti
on/korruptionBundeslagebild2023.html?nn=28078.
Federal Ministry of Interior (2024) – Press statement, executive footprint: Federal legislation becomes
more transparent and easier to understand (Exekutiver Fussabdruck: Gesetzgebung des Bundes wird
transparenter und leichter nachvollziehbar),
https://www.bmi.bund.de/SharedDocs/pressemitteilungen/DE/2024/03/exekutiver-fussabdruck.html.
Federal Office for Justice (2024), Whistleblower protection (Bundesamt für Justiz,
Hinweisgeberschutz),
https://www.bundesjustizamt.de/DE/DasBfJ/Aktuelles/Pressemitteilungen/20240603.html
Federal Supreme Court, judgment of 18 November 2024, VI ZR 10/24.
Frag den Staat (2024), No time for civil society (Keine Zeit für Zivilgesellschaft),
https://fragdenstaat.de/artikel/exklusiv/2024/05/stellungnahmefristen-interessensverbande-zu-wenig-
zeit/.
Frankfurter Rundschau (2023), Despite Wirecard and Cum-Ex: no protection for whistleblowers
(Trotz Wirecard und Cum-Ex: Kein Schutz für Whistleblower),
https://www.fr.de/wirtschaft/gastwirtschaft/trotz-wirecard-und-cum-ex-kein-schutz-fuer-
whistleblower-92130011.html.
German Association of Judges (2025), Contribution from the German Association of Judges for the
2025 Rule of Law Report.
German Association of Judges (2025a), Justice is left behind on income (Justiz wird beim Einkommen
abgehängt), https://www.drb.de/newsroom/presse-mediencenter/nachrichten-auf-einen-
blick/nachricht/news/justiz-wird-beim-einkommen-abgehaengt.
German Association of Judges (2025b), Differences in remuneration between the Länder are growing
(Besoldungsunterschiede zwischen den Ländern wachsen),
https://www.richterbesoldung.de/besoldung-
versorgung/besoldungsmeldungen/meldung/news/besoldungsunterschiede-zwischen-den-laendern-
wachsen-1.
German Bar Association (2025), Contribution from the German Bar Association for the 2025 Rule of
Law Report.
German Federal Bar (2025), Contribution from the German Federal Bar for the 2025 Rule of Law
Report.
German Federal Parliament (2022), Report of the President of the Bundestag on investigations and
sanctions (Bericht der Präsidentin des Deutschen Bundestages nach § 51 Absatz 6 des
Abgeordnetengesetzes), https://dserver.bundestag.de/btd/20/035/2003500.pdf.
German Federal Parliament (2025), Lobbyregister for interest representation towards the German
Federal Parliament and Federal Government, Report (1 January 2022 until 31 December 2024),
https://www.bundestag.de/resource/blob/1059060/71f164571b1143b026de154ba147a535/Bericht-
der-registerfuehrenden-Stelle-nach-9-Abs-1-LobbyRG.pdf.
23
Federal Ministry for Family Affairs, Senior Citizens, Women and Youth (2024), Federal Engagement
Strategy (Engagementstrategie des Bundes), https://www.bmfsfj.de/bmfsfj/themen/engagement-und-
gesellschaft/engagement-staerken/engagementstrategie-des-bundes-222072.
German Government (2025), Input from Germany for the Rule of Law Report 2025.
German Government (2025a), Coalition Agreement (Koalitionsvertrag),
https://www.koalitionsvertrag2025.de/sites/www.koalitionsvertrag2025.de/files/koav_2025.pdf.
German Government (2025b), Response of the German Government to the minor interpellation by the
CDU/CSU parliamentary group (Antwort der Bundesregierung auf die Kleine Anfrage der Fraktion
der CDU/CSU), https://dserver.bundestag.de/btd/20/151/2015101.pdf.
German Institute for Human Rights as part of ENNHRI (2025), Contribution from the European
Network of National Human Rights Institutions for the 2025 Rule of Law Report.
German Institute for Human Rights as part of ENNHRI (2024), Contribution from the European
Network of National Human Rights Institutions for the 2024 Rule of Law Report.
Gesellschaft für Freiheitsrechte (2025), Contribution from Gesellschaft für Freiheitsrechte as part of
Civil Liberties Europe for the 2025 Rule of Law Report.
Gesellschaft für Freiheitsrechte (2025a), Major success for freedom of assembly: Berlin court declares
use of pain grips against peaceful demonstrators unlawful for the first time (Großer Erfolg für die
Versammlungsfreiheit: Berliner Gericht erklärt erstmals Einsatz von Schmerzgriffen gegen
friedlichen Demonstranten für rechtswidrig), https://freiheitsrechte.org/ueber-die-
gff/presse/pressemitteilungen-der-gesellschaft-fur-freiheitsrechte/pm-schmerzgriffe-erfolg.
Global Alliance of Human Rights Institutions (2023), Sub-Committee on Accreditation Report –
September & October 2023,
https://www.ohchr.org/sites/default/files/documents/countries/nhri/ganhri/SCA-Report-Second-
Session-2023-EN-new.pdf.
GRECO (2019a), 3rd
Evaluation, Second Addendum to the Second Compliance Report on Germany,
https://rm.coe.int/third-evaluation-round-second-addendum-to-the-second-compliance-
report/168094c73a.
GRECO (2024), 4th
Evaluation Round - Addendum to the Second Compliance Report – Germany on
Germany, https://rm.coe.int/fourth-evaluation-round-prevention-of-corruption-in-respect-of-
members/1680b0d2fd.
GRECO (2022), 4th
Evaluation Round – Second Interim Compliance Report on Germany,
https://rm.coe.int/fourth-evaluation-round-corruption-prevention-in-respect-of-members-
of/1680a9173f.
GRECO (2021), 4th
Evaluation Round – Interim Compliance Report on Germany,
https://rm.coe.int/fourth-evaluation-round-corruption-prevention-in-respect-of-members-
of/1680a26425.
GRECO (2023), 5th
Evaluation Round – Compliance Report on Germany, https://rm.coe.int/fifth-
evaluation-round-preventing-corruption-and-promoting-integrity-i/1680aa89ee.
GRECO (2019b), 5th
Evaluation Round - Evaluation Report Germany, https://rm.coe.int/fifth-
evaluation-round-preventing-corruption-and-promoting-integrity-i/1680a0b8d7.
Hessen Constitutional Court (Staatsgerichtshof des Landes Hessen), judgment of 6 March 2025, P.St.
2920 and P.St. 2931.
Legal Tribune Online (2025), Seegmüller remains unelected (Seegmüller bleibt ungewählt),
https://www.lto.de/recht/justiz/j/bverfg-richter-cdu-vorschlag-robert-seegmueller-gruene-wahl-
bundestag.
LobbyControl (2024a), Lobby report 2024 (Lobbyreport 2024: Großer Fortschritt bei Lobbyregeln,)
https://www.lobbycontrol.de/wp-content/uploads/lobbyreport-2024-web.pdf
24
LobbyControl (2024b), Corruption of Members of Parliament: the Traffic Light coalition draws
consequences from mask affair (Abgeordnetenkorruption: Ampel zieht Konsequenzen aus
Maskenaffäre), https://www.lobbycontrol.de/pressemitteilung/abgeordnetenkorruption-ampel-zieht-
konsequenzen-aus-maskenaffaere-114033/.
Lobbycontrol (2023), Party financing: Traffic Light coalition and CDU agree, but a party donation
cap is missing (Parteienfinanzierung: Ampel und Union einig, aber ein Parteispenden-Deckel fehlt),
https://www.lobbycontrol.de/pressemitteilung/parteienfinanzierung-ampel-und-union-einig-aber-ein-
parteispenden-deckel-fehlt-112484/.
LobbyControl (2024c), Traffic Light coalition finally decide on lobbying footprint (Ampel-Regierung
beschließt endlich Lobby-Fußspur), https://www.lobbycontrol.de/lobby-fussspur/ampel-regierung-
beschliesst-endlich-lobby-fussspur-114234/.
Lobbypedia (2025), Changeover and post-employment periods - Overview (Seitenwechsel und
Karenzzeiten – Überblick),
https://lobbypedia.de/wiki/Seitenwechsel_und_Karenzzeiten_(%C3%9Cberblick).
Ministry of Interior (2024), Integrity in the Federal public administration - Annual Report 2023,
https://www.bmi.bund.de/SharedDocs/downloads/DE/publikationen/themen/oeffentlicher-
dienst/BMI24045.pdf?__blob=publicationFile&v=2
Ministry of Justice (2025a), Additional writtein input from the Ministry of Justice for the Rule of Law
Report 2025.
Ministry of Justice (2025b), Final Report – reform commission civil procedure of the future
(Abschlussbericht – Reformkommission Zivilprozess der Zukunft),
https://www.bmj.de/SharedDocs/Downloads/DE/Themen/Nav_Themen/250131_Abschlussbericht_Zi
vilprozess_Zukunft.html?nn=110490.
Netzpolitik (2025), Deutschland schludert beim Whistleblower-Schutz,
https://netzpolitik.org/2025/nicht-mal-die-evaluation-klappt-nach-plan-deutschland-schludert-beim-
whistleblower-schutz/.
OCCRP (2018), Council of Europe body expels 13 in Azerbaijan bribe case,
https://www.occrp.org/en/news/council-of-europe-body-expels-13-in-azerbaijan-bribe-case.
OCCRP (2025), Former German lawmakers on trial over alleged bribes from Azerbaijan,
https://www.occrp.org/en/news/former-german-lawmakers-on-trial-over-alleged-bribes-from-
azerbaijan.
OECD (2021), Working Group on Bribery, Implementing the OECD Anti-Bribery Convention, Phase
4 - Two Year Follow-Up Report: Germany, https://www.oecd.org/daf/anti-bribery/germany-phase-4-
follow-up-report.pdf.
President of the German Bundestag (2025), Report of the President of the German Bundestag
pursuant to Section 51(6) of the Act on Members of the Parliament (Bericht der Präsidentin des
Deutschen Bundestages nach § 51 Absatz 6 des Abgeordnetengesetzes),
https://dserver.bundestag.de/btd/21/001/2100185.pdf .
Transparency International (2022), Corruption prevention in the fields of security and defense
(Korruptionsprävention im Sicherheits- und Verteidigungsbereich),
https://www.transparency.de/fileadmin/Redaktion/Publikationen/2022/Scheinwerfer_96_Verteidigung
.pdf.
Transparency International-Deutschland (2023), Statement on the hearing for the Political Parties Act
(Stellungnahme anlässlich der Anhörung zum Parteiengesetz),
https://www.bundestag.de/resource/blob/979884/5a65362863a0fb68ccf61995d2f64927/20-4-344.pdf.
Transparency International-Deutschland (2024), Transparency demands the swift implementation of
the transparency law (Transparency fordert schnelle Umsetzung des Transparenzgesetzes),
https://www.transparency.de/aktuelles/detail/article/pm-internationaler-antikorruptionstag-2024.
25
Transparency International-Deutschland (2025a), Key demands for more transparency and a strong
anti-corruption policy (Kernforderungen für mehr Transparenz und eine starke
Antikorruptionspolitik),
https://www.transparency.de/fileadmin/Redaktion/Publikationen/2025/BTW_2025_Kernforderungen_
TI-DE_Erlaeuterungen.pdf.
Transparency International-Deutschland (2025b), Unique criminal proceedings of international
significance (Einzigartiges Strafverfahren von internationaler Bedeutung),
https://www.transparency.de/aktuelles/detail/article/prozessbeginn-aserbaidschan-affaere.
United Nations Convention against Corruption, (2020), Country Review Report of Germany for the
Review Cycle 2016-2021,
https://www.unodc.org/documents/treaties/UNCAC/CountryVisitFinalReports/2020_11_06_Germany
_Final_Country_Report.pdf.
United Nations Office of the High Commissioner for Human Rights (2025), Contribution from the
UN OHCHR for the 2025 Rule of Law Report.
UNODC (2017) , Country Review Report of the Federal Republic of Germany - Review by the Czech
Republic and Denmark of the implementation by Germany of articles 15 - 42 of Chapter III
“Criminalization and law enforcement” and articles 44 - 50 of Chapter IV “International
cooperation” of the United Nations Convention against Corruption for the review cycle 2010 – 2015
https://www.unodc.org/documents/treaties/UNCAC/CountryVisitFinalReports/2022_02_04_Germany
_Cycle_I_Country_Report_EN.pdf.
Zweites Deutsches Fernsehen (ZDF) (2025), Contribution from Zweites Deutsches Fernsehen for the
2025 Rule of Law Report.
26
Annex II: Country visit to Germany
The Commission services held virtual meetings in March and April 2025 with:
• Allianz Rechtssicherheit
• Association of Private Media
• ARD
• Bündnis Bürgerschaftliches Engagement
• Committee for EU Affairs of the Conference of the Justice Ministers
• Court of Audit
• Federal Administrative Court
• Federal Bar
• Federal Constitutional Court
• Federal Criminal Police
• Federal Supreme Court
• German Association of Journalists
• German Bar Association
• German Chamber of Industry and Commerce
• German Institute for Human Rights
• German Judges Association
• German Union of Journalists
• Gesellschaft für Freiheitsrechte
• Joint Office of the Media Authorities and Media Authorities of the Länder
• Lobbycontrol Germany
• Minister of the Interior
• Ministry of Justice
• Ministry of State for Culture and Media and Länder media units
• Parliament Administration
• Press Council
• Prosecution Service
• Transparency International Germany
• ZDF
* The Commission also met the following organisations in a number of horizontal meetings:
• Amnesty International
• Araminta
• Civil Liberties Union for Europe
• Civil Society Europe
• European Civic Forum
• European Partnership for Democracy
• European Youth Forum,
• International Commission of Jurists
• International Federation for Human Rights (FIDH)
• JEF Europe
27
• Philea – Philanthropy Europe Association.
• Transparency International