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
Date: 2025-07-08
Institutions: European Commission, Secretariat-General
Subjects: Germany, administrative transparency, corruption, democracy, freedom of the press, human rights, independence of the judiciary, pluralism in the media, rule of law, whistleblowing

EN 

  EN 

   EUROPEAN 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 {COM(2025) 900 final} - {SWD(2025) 901 final} - {SWD(2025) 902 final} - {SWD(2025) 903 final} - {SWD(2025) 904 final} - {SWD(2025) 906 final} - {SWD(2025) 907 final} - {SWD(2025) 908 final} - {SWD(2025) 909 final} - {SWD(2025) 910 final} - {SWD(2025) 911 final} - {SWD(2025) 912 final} - {SWD(2025) 913 final} - {SWD(2025) 914 final} - {SWD(2025) 915 final} - {SWD(2025) 916 final} - {SWD(2025) 917 final} - {SWD(2025) 918 final} - {SWD(2025) 919 final} - {SWD(2025) 920 final} - {SWD(2025) 921 final} - {SWD(2025) 922 final} - {SWD(2025) 923 final} - {SWD(2025) 924 final} - {SWD(2025) 925 final} - {SWD(2025) 926 final} - {SWD(2025) 927 final} - {SWD(2025) 928 final} - {SWD(2025) 929 final} - {SWD(2025) 930 final} - {SWD(2025) 931 final}  
 
 
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.  

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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 
length  of  cooling-off  periods  for  federal  ministers  and  federal 

the 

increasing 
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. 

2 

 
 
 
 
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%). 

4  

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.  
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.   

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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.  

4 

 
 
 
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 

5 

 
 
 
 
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. 

6 

 
 
 
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). 

7 

 
 
 
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 
the  EPPO  on  corruption-related 
cooperation  between 
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 

the  German  authorities  and 

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. 

8 

 
 
 
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). 

9 

 
 
 
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. 

the  new 

to  disclose 

lobbying  register  requirements 

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 
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.  
 Country visit Germany, Ministry of Justice. 

73  
74   German Government (2025), written input, p. 4. Abgeordnetenwatch (7 March 2025). 

10 

 
 
 
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. 

11 

 
 
 
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). 

12 

 
 
 
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 
is  reviewing  public  procurement  cases98.  The  Single  Market  and 
good  when 
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.   

it 

III.  MEDIA PLURALISM AND MEDIA FREEDOM  

independently 

The 
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. 

13 

 
 
 
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. 

14 

 
 
 
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). 

15 

 
 
 
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.  

16 

 
 
 
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.  

17 

 
 
 
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.  

18 

 
 
 
“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.  

19 

 
 
 
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 
https://commission.europa.eu/publications/2025-rule-law-report-targeted-
stakeholder-consultation_en. 

found 

be 

at 

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 
Bundestag), 
Nebeneinkünfte 
https://www.abgeordnetenwatch.de/recherchen/nebentaetigkeiten/diese-nebeneinkuenfte-haben-die-
abgeordneten-im-bundestag. 

Abgeordneten 

haben 

die 

im 

Abgeordnetenwatch  (2023),  Lobby  register  2.0?  Full  lobby  transparency  still  does  not  exist 
nicht), 
Lobbytransparenz 
(Lobbyregister 
https://www.abgeordnetenwatch.de/kampagnen/lobbyregister-20-volle-lobbytransparenz-gibt-es-
immer-noch-nicht. 

immer 

Volle 

noch 

2.0? 

gibt 

es 

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 
ernennen?), 
https://rsw.beck.de/aktuell/daily/meldung/detail/afd-blockade-thueringen-richter-ernennung-
wahlausschuss. 

Lebenszeit 

Richter 

noch 

auf 

Bundesnetzwerk  Bürgerschaftliches  Engagement  (BBE)  (2025),  Political  neutrality  of  non-profit 
the  legal  framework  for  non-profit  organizations  (Politische  Neutralität 
organizations  and 
gemeinnütziger 
Rahmenbedingungen), 
gemeinnützigkeitsrechtliche 
https://www.b-b-e.de/projekte/bundestagswahl-2025-und-zivilgesellschaft/rechtspolitische-
rahmenbedingungen-und-zivilgesellschaft-1/. 

Organisationen 

und 

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 
https://www.liberties.eu/en/stories/rolreport2025-main/45330. 

for  Europe 

(2025a), 

Liberties  Rule 

of 

Law  Report, 

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 
Rechtsstaat”), 
https://www.mj.niedersachsen.de/download/208073. 

Bund-Länder-Gruppe 

“Wehrhafter 

der 

20 

 
 
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 
https://rm.coe.int/letter-to-federal-minister-of-the-interior-germany-by-michael-o-
the 
flaher/1680b64870.  

Interior, 

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21 

 
 
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Federal  Criminal  Police  Office 
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leichter 

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(Bundesamt 

Justice 

für 

Justiz, 

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for  civil  society 

für  Zivilgesellschaft), 

(Keine  Zeit 

(2024),  No 

time 

Frankfurter  Rundschau  (2023),  Despite  Wirecard  and  Cum-Ex:  no  protection  for  whistleblowers 
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Wirecard 

Cum-Ex: 

Schutz 

Kein 

und 

für 

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wachsen-1.  

zwischen 

Ländern 

den 

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22 

 
 
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(2025a), 

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CDU/CSU parliamentary group (Antwort der Bundesregierung auf die Kleine Anfrage der Fraktion 
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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 
https://freiheitsrechte.org/ueber-die-
gff/presse/pressemitteilungen-der-gesellschaft-fur-freiheitsrechte/pm-schmerzgriffe-erfolg. 

Demonstranten 

rechtswidrig), 

für 

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2023, 
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Session-2023-EN-new.pdf. 

October 

& 

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members/1680b0d2fd. 

GRECO  (2022),  4th  Evaluation  Round  –  Second  Interim  Compliance  Report  on  Germany, 
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of/1680a9173f. 

(2021),  4th  Evaluation  Round  – 

GRECO 
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of/1680a26425. 

Interim  Compliance  Report  on  Germany, 

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. 

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https://www.lobbycontrol.de/wp-content/uploads/lobbyreport-2024-web.pdf  

23 

 
 
LobbyControl  (2024b),  Corruption  of  Members  of  Parliament:  the  Traffic  Light  coalition  draws 
consequences  from  mask  affair  (Abgeordnetenkorruption:  Ampel  zieht  Konsequenzen  aus 
Maskenaffäre), 
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konsequenzen-aus-maskenaffaere-114033/. 

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cap is missing (Parteienfinanzierung: Ampel und Union einig, aber ein Parteispenden-Deckel fehlt), 
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parteispenden-deckel-fehlt-112484/. 

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– 
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vilprozess_Zukunft.html?nn=110490.   

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Zivilprozess 

der 

– 

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Deutschland 

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schludert 

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beim 

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(2018),  Council  of  Europe  body 

in  Azerbaijan  bribe 

expels  13 

case, 

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Deutschen 
Abgeordnetengesetzes), 
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Bundestages 

Absatz 

nach 

des 

51 

6 

§ 

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Verteidigungsbereich), 
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und 

im 

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anlässlich 

Anhörung 

zum 

der 

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law  (Transparency 

transparency 

24 

 
 
Transparency  International-Deutschland  (2025a),  Key  demands  for  more  transparency  and  a  strong 
anti-corruption 
starke 
policy 
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(Kernforderungen 

Transparenz 

für  mehr 

eine 

und 

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Bedeutung), 
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internationaler 

(Einzigartiges 

von 

United  Nations  Convention  against  Corruption,  (2020),  Country  Review  Report  of  Germany  for the 
Review 
2016-2021, 
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_Final_Country_Report.pdf. 

Cycle 

United  Nations  Office  of  the  High  Commissioner  for  Human  Rights  (2025),  Contribution  from  the 
UN OHCHR for the 2025 Rule of Law Report. 

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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 
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2025 Rule of Law Report. 

25 

 
 
 
 
 
 
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,  
• 
• 
•  JEF Europe  

International Commission of Jurists   
International Federation for Human Rights (FIDH)  

26 

 
 
 
•  Philea – Philanthropy Europe Association.  
•  Transparency International   

27