COMMISSION STAFF WORKING DOCUMENT 2026 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 2026 Rule of Law Report The rule of law situation in the European Union
Date: 2026-07-17
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  Brussels, 17.7.2026  SWD(2026) 905 final  COMMISSION STAFF WORKING DOCUMENT 2026 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 2026 Rule of Law Report              The rule of law situation in the European Union {COM(2026) 900 final} - {SWD(2026) 901 final} - {SWD(2026) 902 final} - {SWD(2026) 903 final} - {SWD(2026) 904 final} - {SWD(2026) 906 final} - {SWD(2026) 907 final} - {SWD(2026) 908 final} - {SWD(2026) 909 final} - {SWD(2026) 910 final} - {SWD(2026) 911 final} - {SWD(2026) 912 final} - {SWD(2026) 913 final} - {SWD(2026) 914 final} - {SWD(2026) 915 final} - {SWD(2026) 916 final} - {SWD(2026) 917 final} - {SWD(2026) 918 final} - {SWD(2026) 919 final} - {SWD(2026) 920 final} - {SWD(2026) 921 final} - {SWD(2026) 922 final} - {SWD(2026) 923 final} - {SWD(2026) 924 final} - {SWD(2026) 925 final} - {SWD(2026) 926 final} - {SWD(2026) 927 final} - {SWD(2026) 928 final} - {SWD(2026) 929 final} - {SWD(2026) 930 final} - {SWD(2026) 931 final}  
 
 
ABSTRACT 

The level of perceived judicial independence is now very high among both the general public 
and companies in Germany. Reflections regarding reforms to further strengthen the resilience 
of the justice system continue at the Federal and Länder level. With the new Pact for the Rule 
of Law and a joint campaign to attract qualified personnel, significant steps have been taken 
to  increase  resources  of  the  judiciary  and  address  recruitment  challenges.  Further  efforts  to 
improve  digitalisation  of  justice  are  on-going,  while  in  practice  regional  divergences  as 
regards  the  maturity  of  digitalisation  persist.  Specialised  commercial  courts  and  chambers 
have been created in over half of the Länder and have become operational. Certain challenges 
have  been  identified  regarding  restrictions  to  the  right  to  legal  assistance  in  specific 
circumstances.  The  justice  system  overall  continues  to  perform  efficiently  in  civil  and 
commercial  cases,  with  changes  to  criminal  and  administrative  procedural  rules  under 
consideration. 

The planned revision of the strategic anti-corruption framework and gift policy for the federal 
administration  remains  pending.  Germany  will  strengthen  sanctions  of  legal  persons, 
including  for  corruption  crimes.  High-level  corruption  is  addressed,  and  no  systemic 
weaknesses have been identified. Work to establish a fully-fledged legislative footprint is still 
to be advanced to further enhance transparency in an environment of strong industry interest 
representation.  The  federal  Lobbying  Register  is  effectively  enforced.  Some  shortcomings 
remain  in  the  enforcement  of  conflicts  of  interest  and  asset  declaration  rules  for 
parliamentarians  and  Government  officials  as  well  as  for  whistleblower  protection  and 
political party and campaign finance. Linking the fully electronic Competition Register to the 
Company  Data  Register  could  facilitate  investigations  of  data  of  companies  involved  in 
public procurements, as recommended by the evaluation of the Company Register law. 

The  independently  functioning  media  regulators  assumed  new  enforcement  responsibilities 
regarding  youth  protection.  Reprimands  issued  by  the  self-regulatory  body  reached  a  very 
high  level.  Reforms  to  further  strengthen  the  independent  functioning  of  the  public  service 
broadcasters  entered  into  force,  and  future  funding  remains  under  discussion.  The  business 
environment  for media service providers remained overall stable,  while plans to  adopt new 
measures  to  support  media  pluralism  are  progressing.  There  have  been  no  further  steps  to 
establish  a  codified  right  of  the  press  to  information  from  federal  authorities.  The  overall 
protection framework for journalists has remained stable, but reports of physical and online 
attacks  raise  concern.  Work  is  ongoing  with  the aim  to  establish  anti-SLAPP  safeguards  in 
legislation. 

The length of stakeholder consultations and use of impact  assessments continues to  vary in 
practice among Ministries. No steps were taken to adapt the tax-exempt status of non-profit 
organisations,  which  still  creates  obstacles  for  civil  society  in  practice.  Civil  society 
organisations continue to  face some challenges to their operations and funding  schemes for 
organisations in the area of democracy promotion are currently under review.  

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RECOMMENDATIONS 

Overall,  based  on  the  recommendations  in  the  2025  Rule  of  Law  Report  and  considering 
other developments that took place in the period of reference, the Commission concludes the 
following:  

•  Significant  further  progress  has  been  made  on  increasing  the  resources  of  the  judiciary 
and addressing recruitment challenges, through the new Pact  for the Rule of Law and a 
joint campaign to attract qualified personnel. In view of addressing remaining challenges, 
it  is  recommended  to  Germany  to  take  forward  the  implementation  of  the  Pact  for  the 
Rule of Law as regards both human resources and digitalisation and continue measures 
to address recruitment challenges, taking into account European standards on resources 
for the justice system.  

•  No progress  has  been made to 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.  As  gaps  remain,  it  is 
recommended to Germany to step-up efforts to provide a comprehensive public record of 
lobbying input in the legislative process. 

•  No further progress has been made on advancing with creating a legal basis for a right to 
information  of the press as  regards federal  authorities, as internal  preparations  have not 
been pursued further. Therefore, it is recommended to Germany to 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.   

•  No  progress  has  been  made  to  adapt  the  tax-exempt  status  for  non-profit  organisations, 
which still affects civil society in practice. Therefore, it is recommended to Germany to 
take  steps  to  adapt  the  tax-exempt  status  for  non-profit  organisations  with  a  view  to 
addressing  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. 

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I. 

JUSTICE SYSTEM1  

Independence  

The level of perceived judicial independence in Germany is now very high among both 
the  general  public  and  companies.  Overall,  82%  of  the  general  population  and  77%  of 
companies perceive the level of independence of courts and judges to be ‘fairly or very good’ 
in  20262.  The  perceived  judicial  independence  among  the  general  public  has  significantly 
increased in comparison with 2025 (72%), and has increased in comparison with 2022 (76%). 
The  perceived  judicial  independence  among  companies  has  significantly  increased  in 
comparison with 2025 (70%), and remains at the same level as in 2022 (77%).  

Reflections regarding reforms to further strengthen the resilience of the justice system 
continue at the Federal and Länder level. Following the reform to strengthen the resilience 
of  the  Federal  Constitutional  Court  in  December  20243,  three  new  appointments  to  the 
Constitutional  Court  took  effect  in  October  2025.  Regarding  other  efforts  to  strengthen  the 
resilience  of  the  justice  system,  at  Federal  level  two  initiatives  concerning  lay  judges  are 
pending.  First,  to  confirm  their  obligation  to  respect  constitutional  values  and  second,  to 
allow them to  continue  exercising their functions  after expiry of their five-year mandate, if 
the two-thirds majority typically required for the election of a successor cannot be achieved4. 
At the level of the Länder, ongoing initiatives concern the resilience of their Constitutional 
Courts  (broadly  mirroring  the  reform  at  the  Federal  level)5  and  of  their  judges’  election 
committees,  where  they  exist6.  As  regards  the  right  of  Ministers  of  Justice  to  instruct 
prosecutors  in  individual  cases,  there  are  no  plans  at  Federal  level  to  change  the  system, 
while in two Länder further initiatives in this respect have been taken7. Stakeholders8, as well 
as  a  recent  research  project  focussing  on  potential  vulnerabilities  in  the  current  system9, 
highlight  further  areas  for  action,  including  judicial  appointments,  notably  the  more 

1  An overview of the institutional framework for all four pillars can be found here.  
2   Figures 48 and 50, 2026 EU Justice Scoreboard and Figures 51 and 53, 2024 EU Justice Scoreboard. The 
level  of  perceived  judicial  independence  is  categorised  as  follows:  very  low  (below  30%  of  respondents 
perceive judicial independence as fairly good and very good); low (between 30-39%), average (between 40-
59%), high (between 60-75%), very high (above 75%). 

3   2025 Rule of Law Report, Germany, p. 3.  
4   A  draft  law  on  the  respect  of  constitutional  values  by  lay  judges  had  been  presented  under  the  previous 
legislature  but  was  subject  to  discontinuity  following  the  elections.  Country  visit  Germany,  Ministry  of 
Justice. 2025 Rule of Law Report, Germany, p. 2. See also Conference of the Justice Ministers (2025b).  
5   Such reflections, at different stages, exist in Berlin, Brandenburg, Saarland, Sachsen-Anhalt (implemented 
in May 2026), Hamburg, Niedersachsen. Country visit Germany, EU Affairs Committee of the Conference 
of  Justice  Ministers.  EU  Affairs  Committee  of  the  Conference  of  Justice  Ministers  (2026a),  additional 
written input, pp. 53-56.  

6   Reflections  are  currently  on-going  in  Schleswig-Holstein.  In  Thüringen,  the  Judges’  Election  Committee 
continues to operate in its old composition, as the two-thirds majority necessary to re-appoint the members 
chosen among members of parliament could not be reached. Country visit Germany, EU Affairs Committee 
of the Conference of Justice Ministers.   
In  Sachsen,  the  Ministry  of  Justice  is  examining  whether  to  formalise  requirements  for  instructions  to 
improve  transparency.  In  Mecklenburg-Vorpommern,  the  Minister  of  Justice  issued  a  declaration  in 
December  2025  that  she  would  make  use  of  instructions  only  if  the  handling  of  the  case  by  the  public 
prosecutor’s offices and the Office of the Attorney General is legally untenable (which however does not 
bind future Ministers of Justice).  

7  

8   Country  visit  Germany,  German  Judges’  Association,  Federal  Bar,  Bar  Association,  Federal  Supreme 
Court, National Human Rights Institution (NHRI), Gesellschaft für Freiheitsrechte (GFF). Bar Association, 
Liberties (2026), written inputs, pp. 4-7 and pp. 303-304 respectively.  
Judicial Resilience Project, available here: The Judicial Resilience Project. 

9  

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formalised  involvement  of  the  Councils  of  Judges  (Präsidialräte)  and  the  budgetary 
autonomy of the judiciary. The Federal Ministry of Justice has pointed to the on-going work 
on a Federal Justice Cloud (see below) as an additional safeguard for resilience as regards the 
IT infrastructure and is examining further areas for action also based on the recommendations 
of  the  Judicial  Resilience  Project,  including  as  regards  the  role  of  Councils  of  Judges10.  At 
their conference in June 2026, the Ministers of Justice of the Länder reiterated the importance 
of  a  continuous  review  of  the  resilience  of  the  legal  foundations  of  the  justice  system  and 
consider further measures if needed11. 

Quality  

Significant further progress was made on the recommendation to increase resources of 
the judiciary and address recruitment challenges, through the new Pact for the Rule of 
Law and a joint campaign to attract qualified personnel12. Following the announcement 
in the coalition agreement13, the Federal Government and the Länder agreed in June 2026 on 
a new ‘Pact for the Rule of Law’ which will provide EUR 240 million of Federal funding to 
the Länder, to create around 2 000 new posts in their judiciaries. The aim of the pact which 
consists  of  three  pillars  on  human  resources,  digitalisation  and  improvements  to  the 
efficiency  of  procedures,  is  to  overall  strengthen  the  effectiveness  of  the  justice  system14. 
Stakeholders have welcomed this announcement, in particular in view of the 2 000 posts for 
prosecutors  and  judges  in  criminal  matters  they  have  identified  as  currently  needed15.  This 
continues to have an impact on the efficiency in criminal cases, with over one million open 
cases  at  the  end of 2025 and increased instances of releases from  pre-trial  detention  due to 
lengthy proceedings16. The expenditure for the judiciary in relation to GDP remains stable at 
a relatively high level17 and almost all Länder have continued to create some additional posts 
in their judiciaries18. To make the judiciary more attractive and in view of upcoming waves of 
retirements, the Länder have launched a joint campaign aimed at attracting young people to 
the  judiciary  and,  will  now  examine  options  to  further  expand  this  campaign19.  Regarding 
judicial salaries, as in previous years, the Federal level and most Länder have applied or plan 
to  apply  the  most  recent  collective  bargaining  agreement  for  the  civil  service  to  the 
judiciary20. However, entry-level  salaries  for judges and prosecutors continue to  be slightly 

10   Country visit Germany, Ministry of Justice.  
11  Conference of the Justice Ministers (2026a).  
12   The 2025 Rule of Law Report recommended Germany to “[t]ake measures to increase the resources of the 
judiciary and address recruitment challenges, taking into account European standards on resources for the 
justice system.” Some progress was previously assessed on this recommendation in 2025 and 2024, and no 
progress in 2023.  

13   2025 Rule of Law Report, Germany, pp. 4-5.  
14   Ministry  of  Justice  (2026a).  German  Government  (2026),  written  input,  p.  1.  Country  visit  Germany, 
Ministry of Justice, EU Affairs Committee of the Conference of Justice Ministers. Conference of the Justice 
Ministers (2025a).  

15   Country  visit  Germany,  German  Judges’  Association,  Federal  Bar,  Bar  Association.  German  Judges’ 

Association (2026a).  

16   German Judges’ Association (2026), written input, p. 13 and information during the country visit Germany.   
17   Figure 34, 2026 EU Justice Scoreboard.   
18   This ranges, in 2026, from five in the Saarland to almost 76 in Nordrhein-Westfalen. EU Affairs Committee 

of the of the Conference of Justice Ministers (2026), additional written input, pp. 10-14.  

19   The campaign, called “Unser Recht braucht dich” (our law needs you), includes an advertising clip which 
aired  in  cinemas  across  Germany  and  a  website,  reached  around  two  million  persons.  Further  measures 
could  include  advertising  in  audio  or  print  media.  Country  visit  Germany,  EU  Affairs  Committee  of  the 
Conference of Justice Ministers. Conference of the Justice Ministers (2026b).  

20   German Government (2026), written input, pp. 6-8. This would correspond to a salary raise of 2.8% as of 
April  2026,  further  2%  in  March  2027  and  1%  in  2028.  In  Hessen,  which  is  not  part  of  the  bargaining 
4 

 
 
 
below the average national gross salary21 and regional disparities persist22. A judgment of the 
Federal Constitutional Court of September 2025 found that the level of salaries in the Land of 
Berlin for civil servants (including judges and prosecutors) between 2008-2020 was in most 
instances  unconstitutional23.  Further  similar  cases  are  still  pending  at  the  Federal 
Constitutional Court, and all Länder are examining the follow-up required, including due to 
the  further  development  of  the  criteria  for  adequate  salaries  by  the  Federal  Constitutional 
Court24.  Stakeholders  continue  to  highlight  that  additional  measures  to  ensure  adequate 
salaries  are  needed,  also  in  view  of  this  jurisprudence,  as  the  judiciary  faces  a  serious 
challenge to recruit qualified personnel25. Overall, significant further progress has been made 
on the recommendation.  

Further  efforts  to  improve  digitalisation  of  justice  are  ongoing,  while  in  practice 
regional  divergences  as  regards  the  maturity  of  digitalisation  persist.  The  level  of 
digitalisation of justice is overall good in civil, commercial, and administrative cases26, while 
procedural  rules  allowing  for  the  use  of  digital  tools  and  availability  of  digital  solutions  to 
conduct and follow proceedings remain more limited in criminal cases27. The implementation 
of the digitalisation initiative, on-going since 2023, has continued, with flagship projects such 
as  the  Federal  Justice  Cloud28,  and  the  remaining  budget  under  the  initiative  is  set  to  be 
allocated to further projects by the end of 202629. Under the second pillar of the new Pact for 
the Rule of Law, an additional EUR 210 million of Federal funding for digitalisation has been 
allocated  for  the  time  period  of  2027-202930.  The  implementation  of  the  e-file  for  all  new 
cases  has  been  achieved  by  the  January  2026  deadline  in  all  Länder,  except  in  Sachsen-
Anhalt  where  an  extension  of  the  deadline  by  one  year  was  requested31.  Stakeholders 
continue  to  report  important  regional  discrepancies  in  the  level  of  digitalisation,  linked  for 
example to  the differences in  quality  and availability of tools as well as the level  of digital 
skills  among  the  Länder32.  There  have  been  no  further  steps  in  view  of  introducing  digital 

community  of  the  German  Länder,  similar  raises  are  also  foreseen.  EU  Affairs  Committee  of  the 
Conference of Justice Ministers (2026a), additional written input, pp. 15-21.  

21   Figure  35,  2026  EU  Justice  Scoreboard.  This  figure  does  not  take  into  account  any  additional  benefits 
provided  to  judges  and  prosecutors,  such  as  special  pensions,  general  exemption  from  social  security 
contributions, housing benefits or other financial benefits. 

22   German Judges’ Association (2026c).  
23   The  reasoning  is  based  on  the  “alimentation  principle”  emanating  from  Art.  33(5)  of  the  Basic  Law. 
Judgment of the Federal Constitutional Court of 17 September 2025, 2 BvL 5/18 u.a. The judgment requires 
relevant legislation to be revised by end March 2027 and back payments in certain cases.  

24   Country  visit  Germany,  EU  Affairs  Committee  of  the  Conference  of  Justice  Ministers  and  additional 

written input (2026), pp. 22-28. 

25   The lack of competitiveness vis-à-vis private sector salaries is a further challenge in this respect.  German 
Judges’ Association and Association of German Administrative Judges (2026), written inputs, p. 13 and p. 
9. German Judges’ Association (2026b).  

26   Some  gaps  remain  in  the  availability  of  digital  solutions  to  initiate  and  follow  proceedings  for  civil, 

commercial and administrative cases. Figure 40-44, 2026 EU Justice Scoreboard.   

27   Figures 40 and 45, 2026 EU Justice Scoreboard.  
28   The  Justice Cloud allows a central provision and use of software applications for the Federal and  Länder 
level. A minimum viable product is expected for 2027. German Government (2026), written input, p. 10.  

29   2025 Rule of Law Report, Germany, p. 5.  
30   This money would be spent based on results-oriented budgeting, implementing a number of lessons learned 
from  the  current  digitalisation  initiative.  Country  visit  Germany,  Ministry  of  Justice  and  German 
Government (2026), written input, p. 10. 

31   However, in some fields, transitional measures still apply, as well as certain technical issues in the practical 
use of the e-file. German Government (2026), written input, pp. 12-15. Country visit Germany, EU Affairs 
Committee of the Conference of Justice Ministers. 

32   Country visit Germany, Judges’ Association, Federal Bar, Bar Association, Federal Supreme Court. 

5 

 
 
 
documentation  of  main  proceedings  in  criminal  cases,  which  remains  a  key  demand  by 
certain  stakeholders33.  Another  area  pointed  out  as  a  challenge  is  the  limited  online 
publication  of  judgments  and  lack  of  an  optimised  country-wide  portal  to  access  laws  and 
court  decisions34.  In  this  respect,  the  Government  has  announced  the  creation  of  an  online 
database for judgments, which would cover judgments of the Federal Courts and is expected 
to be launched in 2028, with the eventual possibility to also link it to the courts in the Länder 
at a later stage35.  

Specialised  commercial  courts  and  chambers  have  been  created  in  over  half  of  the 
Länder and have become operational. Following the entry into force of the law providing 
for  their  establishment  in  April  202536,  in  nine  Länder,  Commercial  Courts  and/or 
Commercial Chambers have been created, with the others having concluded that there is no 
necessity  for  such  a  court  or  chamber,  mainly  due  to  low  case  numbers37.  The  number  of 
incoming  cases  at  the  different  courts  varies  but  is  relatively  low  at  this  stage38.  Some 
business stakeholders continue to express certain hesitations as regards the high threshold for 
the  disputed  value  to  be  heard  at  a  commercial  court39.  As  regards  the  traditional,  separate 
institution of chambers for commercial matters (Kammern für Handelssachen), composed of 
one ordinary judge and two lay judges with expertise in commercial matters, the Conference 
of the Justice Ministers created a working group that gathered input from representatives of 
the judiciary, lawyers and businesses. This working group – whose establishment responds to 
a notable decline in incoming cases – is tasked with making proposals for the future of these 
chambers  in  terms  of  their  organisation,  personnel  and  overall  legal  framework.  It  will 
present its findings in autumn 202640.  

Certain  challenges  have  been  identified  regarding  restrictions  to  the  right  to  legal 
assistance in specific circumstances. A reform of the Residence Act adopted in December 
2025  abolished  mandatory  legal  representation  in  pre-removal  detention  cases41.  While  the 
Government underlines that the right to legal assistance in such cases remains guaranteed42, 
stakeholders have criticised that the practical difficulties for persons detained facing removal 
in obtaining timely legal representation mean that it is extremely challenging in practice if it 
is no longer mandatory43. As regards legal assistance in international criminal matters, a draft 
law  presented  in  September  2025  intends  to  improve  legal  protection  by  providing  for  the 
right to  appeal  against the admissibility  of an extradition  decision44. However, stakeholders 

33   Bar Association, Federal Bar  (2026), written inputs, p. 13 and pp. 14-15, respectively. It is expected that 

this topic could be examined under the expert commission on the criminal procedure (see below).  

34   Currently,  decisions  are  often  only  accessible  via  fee-based  databases.  Liberties  (2026),  p.  301.  See  also 

Figure 46, 2026 EU Justice Scoreboard. European Semester (2026), Germany Country Report, p. 14. 

35   German Government (2026), written input, p. 11.  
36   2025 Rule of Law Report, Germany, p. 6.   
37   Rheinland-Pfalz  remains  open  towards  the  possibility  provided  in  the  law  of  cooperation  with  a 
Commercial  Court  in  a  neighbouring  Land.  Country  visit  Germany,  EU  Affairs  Committee  of  the 
Conference of Justice Ministers.  

38   When there are no incoming cases  falling in the specific competence of commercial  courts/chambers,  the 

judges concerned continue to handle regular civil cases.  

39   Country visit Germany, DIHK.  
40   Conference of the Justice Ministers (2025c). Country visit Germany, DIHK.  
41   The reform abolishes Art. 62d of the Residence Act and will enter into force on 1 June 2026.   
42   Federal Bar, Bar Association (2026), written inputs, p. 18 and p. 18, respectively. Country visit Germany, 

Ministry of the Interior, Federal Bar, Bar Association.  

43   Country  visit  Germany,  Federal  Bar,  Bar  Association.  Federal  Bar  and  Bar  Association  (2026),  written 

inputs.  

44   Draft law on legal assistance in international criminal matters. Country visit Germany, Ministry of Justice.  

6 

 
 
 
have criticised the limitations of the appeal in the draft law, as it does not provide for a full 
appeal,  only  a  re-examination  by  the  same  chamber  with  short  deadlines  and  limits  to  the 
right to an in-person hearing45. 

Efficiency 

The justice system overall continues to perform efficiently in civil and commercial cases, 
with  changes  to  criminal  and  administrative  procedural  rules  to  simplify  proceedings 
under consideration. The disposition time decreased in litigious civil and commercial cases 
at  first  instance  (from  249  days  in  2023  to  232  days  in  2024)  and  remained  stable  in 
administrative  cases  (from  391  days  in  2023  to  389  days  in  2024).  At  the  same  time,  the 
number  of  pending  administrative  cases  at  first  instance  remained  stable  from  2022  till 
202446, while for pending litigious civil and commercial cases it has increased slightly (from 
to  0.8  in  2023  to  0.9  per  100  inhabitants  in  2024).  Previously  high  clearance  rates  in 
administrative cases have seen a notable drop (from 109 % in 2023 to 99 % in 2024), whereas 
they  increased  in  litigious  civil  and  commercial  cases  (from  97  %  in  2023  to  100  %  in 
2024)47. Following the implementation of the ‘leading decision’ procedure in October 202448, 
the first such decision, issued by the Federal Supreme Court in November 2024, has led to the 
intended  acceleration  of  proceedings  on  the  same  issue  at  the  lower  courts.  However,  this 
does not yet provide a solution to address mass civil cases directly at lower instances more 
effectively49. Meanwhile, efforts to improve procedural efficiency have been initiated in the 
field  of  administrative  proceedings,  with  the  Government  submitting  a  draft  reform  of  the 
Code of Administrative Court Procedure to the Federal Council in May 202650. To enhance 
the  efficiency  of  criminal  court  proceedings,  the  Federal  Government  together  with  the 
Länder  has  established  an  expert  commission  comprising  academics  and  practitioners51.  Its 
final report with reform  proposals is expected in  autumn 202652. These processes to reform 
different procedural codes are also part of the Pact for Rule of Law, in view of simplifying 
and speeding up judicial proceedings53.   

45   Federal Bar (2025). Bar Association, Federal Bar (2026), written inputs, p. 30 and pp. 12-13, respectively.   
46   At 0.7 per 100 inhabitants. 
47   Fig. 5, 7, 10-11, 13-14 2025 EU Justice Scoreboard. 
48   2025 Rule of Law Report, Germany, pp. 6-7.  
49   So-called  mass  cases  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.  Country  visit  Germany,  Federal  Supreme  Court.  The 
leading decision Federal Supreme Court (2024) VI ZR 10/24 concerns the so-called ‘Data Scraping’. 

50   The  draft  proposes  to  expand  the  use  of  single  judges  at  lower  instance  courts  and  three-member  panels 
(instead  of  five-member  panels)  at  the  Federal  Administrative  Court  and  to  partly  permit  ‘text-form’ 
submissions  via  email  in  administrative  proceedings,  in  place  of  the  current  ‘written  form’  with  a 
handwritten signature. Ministry of Justice (2026).  

51   With the main focus on enhancing efficiency and accelerating the main hearing, the six working groups also 
address appeals, penalty orders without oral proceeding, evidence-gathering, the transfer of evidence from 
public  prosecutors’  investigations  to  court  proceedings,  defence  rights,  and  victims’  rights.  Country  visit 
Germany, Ministry of Justice, EU Affairs Committee of the Conference of Justice Ministers. Stakeholder 
have broadly welcomed this step. Country visit Germany, German Association of Judges, Bar Association, 
Federal Bar. The German Federal Bar is hoping to implement the audio-visual documentation/recording of 
the main hearing in this context, which is also welcomed by the German Bar Association. 

52   German Government (2026), written input, p. 20. 
53  Ministry of Justice (2026a).  

7 

 
 
 
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 2025 Corruption Perceptions 
Index by Transparency International, Germany scores 77/100 and ranks 6th in the European 
Union and 7th globally54. This  perception is  relatively  stable over the past  five years.55 The 
2026  Special  Eurobarometer  on  Corruption  shows  that  58%  of  respondents  consider 
corruption  widespread  in  their  country  (EU  average  71%)  and  12%  of  respondents  feel 
personally  affected  by  corruption  in  their  daily  lives  (EU  average  30%).  As  regards 
businesses, 49% of companies consider that corruption is widespread (EU average 65%) and 
25%  consider  that  corruption  is  a  problem  when  doing  business  (EU  average  37%). 
Furthermore, 35% of respondents find that there are enough successful prosecutions to deter 
people  from  corrupt  practices  (EU  average  38%),  while  30%  of  companies  believe  that 
people  and  businesses  caught  for  bribing  a  senior  official  are  appropriately  punished  (EU 
average 31%)56. 

Revisions of Germany’s Federal strategic anti-corruption framework and its gift policy 
remain  pending.  The  revision  of  the  2003  ‘Federal  Government  Directive  Concerning  the 
Prevention  of  Corruption  in  the  Federal  Administration’  remains  to  be  finalised,  and  the 
Government  indicates  that  it  will  take  the  EU  Anti-Corruption  Directive  into  account  to 
ensure alignment57. The revision of the 2004 rules on the prohibition  to  accept  favours and 
gifts  also  remains  pending  and  is  postponed  to  the  end  of  202658.  The  new  comprehensive 
report  on  integrity,  providing  specific  data  on  corruption  suspicion  and  cases  in  the  federal 
public administration of the year 2024, was published in September 202559.  

A  proposed  legislative  reform  aims  to  increase  corporate  penalties,  including  for 
corruption  offences.  In  October  2025,  the  Government  proposed  amendments  to  the 
criminal  code  and  the  Administrative  Offence  Act  to  improve  detection  and  to  increase 
maximum  corporate  fines,  including  for  corruption  and  foreign  bribery  offences60.  Key 
elements of the planned reform include the quadrupling of maximum corporate fines and the 
broadening of the scope of liability for companies, which would still require the intentional 

54   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). 

55   In 2021, the score was 80, while, in 2025, the score is 77. 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. 

56   Data from Special Eurobarometer 573 (2026) and Flash Eurobarometer 582 (2026).  
57   The Directive entered into force on  1 June 2026. Country visit Germany, Ministry of Justice, Ministry of 
Interior.  It  was  originally  expected  to  be  finalised  by  the  end  of  2022  but  has  since  encountered  several 
delays. UNODC (2020), p. 30, encouraging a public consultation. 2025 Rule of Law Report, Germany, p. 7. 
The strategy is limited to corruption prevention. GRECO (2019b), p. 4, considers it a solid framework. 
58   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. 

59   Ministry of Interior (2025a), reporting (p. 18) 32 new  corruption cases in 2024 (2023: 22) concerning 40 

individuals within and beyond the Federal administration. 30 cases of Federal offices were closed. 

60   Ministry of Justice (2025), Proposal amending the Criminal Code – Transposition of the EU Environmental 
Crime  Directive 2024/1203. OECD (2021), recommending ensuring company penalties that are effective, 
proportionate  and  dissuasive,  Germany  decided  for  an  all-crime  approach,  German  Government  (2025a), 
pp.  48-49.  Stakeholders  supported  a  profit-based  fine  as  a  better  deterrent  instead  of  a  fixed  amount  as 
maximum  fine  that  Germany  opted  for.  Country  visit  Germany,  Transparency  International.  OECD 
(2025b). 

8 

 
 
 
commission  of  a  crime  by  the  manager61.  In  practice,  corporate  liability  in  foreign  bribery 
prosecutions  is  still  rarely  enforced,  with  an  action  plan  to  address  the  2021  OECD 
recommendations  on  corporate  liability  due  in  June  202662.  In  February  2026,  the 
Government  adopted  a  joint  action  plan  against  organised  crime  to  implement  its 
commitments  to  tackle,  among  others,  financial  crimes63  by  strengthening  Germany’s 
financial investigation and law enforcement capacities. This could serve to address the needs 
identified  by  stakeholders,  such  as  increasing  risks  of  strategic  corruption  by  third  country 
and  non-state  actors  to  secure  strategic  influence  over  policy64.  Gaps  in  the  Beneficial 
Ownership Transparency Register are planned to be addressed by July 2027, including with 
enhanced public access to, and verification of, beneficial ownership information65. 

Germany continues to provide an effective criminal justice response to 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  stakeholders66.  No  cases  led  by  the  EPPO  on  corruption-related 
investigations  have  been  reported  for  202567.  Enforcement  efforts  of  the  new  provision  of 
bribery of parliamentarians have resulted in a first conviction68. In 2025, the level of human 
and financial resources as well as the high specialisation of staff 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  effectively69.  The  2025  Situation  Report  by  the 
Federal  Criminal  Police Office illustrates in  an annual  analysis recent  trends,  developments 
and  statistics  on  corruption  and  Germany’s  efforts  to  repress  it70.  The  detected  financial 
damage  caused  by  corruption  has  notably  decreased  compared  to  the  previous  year71.  Of 
those who have been found to have accepted a bribe, 67% (+10% in the previous year) have 
been public officials. The Supreme Audit Office reports no specific findings on corruption or 
transparency72. 

The  mandatory  federal  Lobbying  Register  is  effectively  enforced,  providing  for  more 
transparency  in  the  decision-making  process73. With  6 278  interest  representative  entries 

61   Art. 30(2)(1) Act on Regulatory Offences. Corporate fines are to increase from EUR 10 to 40 million. 
62   Federal  Criminal  Police  Office  (2025),  p.  5:  one  case  in  2024  and  more  cases  of  commercial  corruption 
(Arts. 335a, 299 Criminal Code). Germany is a top enforcer against foreign bribery committed by natural 
persons,  yet  corporate  liability  for  criminal  offences  is  still  rarely  enforced,  see  OECD  (2021), 
recommendations and OECD (2025b).  

63   Ministry of Finance, Press release (2026); Ministries of Finance, Interior, Justice (2026). 
64   Transparency International (2025a), pp. 4-5.  
65   Country visit, Germany, Ministry of Justice. German Government (2025a). The register is not public so far; 
access is granted only for a legitimate interest. The Commission opened formal infringement procedures for 
failing to fully transpose the 6th Anti-Money Laundering Directive by 10 July 2025, pertaining to access to 
ownership data of legal entities and trusts. 

66   Country visit Germany, Prosecution Service, Federal Police, Transparency International. 
67   EPPO Annual Report 2025 (2026), pp. 28-29. EPPO (2026), written input.  
68   OLG München (2025), involving former members of the Parliament at Federal and Länder level. Art. 108e 

StGB. Transparency International (2025b). OCCRP (2025). 

69   Country visit Germany, Ministry of Interior, Federal Criminal Police Office, Prosecution Service. 
70   For  2024,  2 926  police-registered  corruption  cases  (i.e.  23.8%  decrease  compared  to  2023).  Federal 
Criminal  Police  Office  (2025).  The  data  is  not  segregated  by  the  16  Länder,  identifying  regional 
discrepancies.  

71   Ibid, by approximately 36.8% amounting to EUR 36 million in 2024. 
72   German Court of Auditors (2026), additional written input, pp. 1-2. 
73   At the regional level, ¾ of the 16  Länder lobbying registers in place, with the city state  Hamburg having 
most recently in 2025 decided to establish one, Bürgerschaft Hamburg, Committee for Justice (2025). For a 
Länder overview, see Transparency International (2024). 
9 

 
 
 
by  the  end  of  2025,  the  number  of  registered  lobbyists  in  the  federal  register  is  relatively 
stable74.  The  Parliament  Administration  at  the  Federal  level  is  monitoring  and  verifying  all 
published  data  content  to  ensure  correctness  and  consistency  and  follows  up  on  external 
reports on breaches of the Lobbying Register Act. In 2025, new digital features were rolled 
out  to  further  facilitate  the  registration  and  monitoring  process.  The  new  features  include 
automatic alerts regarding discrepancies when data is entered and an automatic public email 
notification system to inform the public about changes in interest representatives’ data entries 
and  new  position  papers75.  Regarding  interest  representatives’  obligations  to  disclose  along 
with  their  register  entries  current  or  previous  roles  (‘revolving  doors’)76,  such  disclosures 
regarding a role as a public or elected official over the past five years were made for less than 
3% of the individuals named in the register entries77. Until the end of 2025, sanctions were 
imposed  in  six  cases  in  proceedings  which  lasted  around  six  months78.  The  Federal 
Parliament  will  publish  its  second  report  on  the  maintenance  of  the  electronic,  machine-
readable Lobbying Register, which was created in 2022 and will be mandatory for all interest 
representatives79,  as  from  March  2027.  Stakeholders  view  the  register  as  a  positive  tool 
providing  for  more  transparency80.  Efforts  to  link  the  Lobbying  Register  to  the  future  joint 
digital legislative portal for the Government and Parliament, as previously reported, are still 
work in progress81. 

There  has  been  no  progress  to  provide  for  a  more  comprehensive  public  record  on 
lobbying  input  to  legislation  (‘legislative  footprint’),  beyond  the  already  existing 
transparency measures82.  Since June 2024,  Federal  Ministries are  required to  disclose the 
influence  of  lobbyists  on  the  law-making  process  (executive  footprint)83.  Although  largely 
welcomed  by  stakeholders,  the  obligations  do  not  yet  encompass  reporting  on  in-person 
meetings between lobbyists and officials84. The Government and stakeholders are identifying 
systematic  shortcomings  in  the  practical  application  of  the  executive  footprint,  with  three 

74   Country visit Germany, Parliament Administration. 
75   German Government (2026), written input, p. 22. 
76   Country  visit,  Germany,  Transparency  International,  LobbyControl,  while  welcoming  the  obligation,  call 

for an extension of cooling-off periods to three years. 

77   Country visit Germany, Parliament Administration. ZDF/AbgeordnetenWatch (2025). AbgeordnetenWatch 
(2025).  Transparency  International  (2025c),  p.  25:  73  of  564  revolving  door  cases  in  the  past  five  years 
concerned  parliamentarians;  the  register  shows  only  those  moves  to  the  private  sector  that  are  compliant 
with the Act; the obligation to report is on the lobby organisations. LobbyControl (2025a). 

78   Ibid. Since 2024, 61 proceedings for administrative offences were initiated for non-registration or false or 
unconfirmed data entries. 21 have been completed by the end  of 2025, 15 were closed, and two additional 
fines are not yet binding. Administrative fines can be imposed of up to EUR 50 000. 

79   Transparency  International,  noting  the  register’s  positive  value  in  displaying  the  level  playing  field  of 

NGOs versus industry representation.  

80   Country visit Germany, LobbyControl, Transparency International, Allianz Rechtssicherheit. Note however 
GRECO (2024), recommendation (i), paras. 9-16, pp. 3-4, to introduce rules for members of Parliament on 
how to interact with lobbyists and other third parties seeking to influence the parliamentary process. 

81   2024  and  2025  EU  Rule  of  Law  Report,  Germany,  pp.  16-17  (2024),  p.  9  (2025).  For  the  timeline,  see 

above. 

82   The  2025 Report recommended to Germany to “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”.  No  further  progress  was  previously  assessed  on  the 
recommendation in 2025 and some progress in 2024. 

83   More than one third. The Government prepares  80-90% of legislative drafts, i.e. the majority of proposals 
are  covered  by  the  Joint  Rules  of  Procedure  of  the  Federal  Ministries.  GRECO  concluded  in  2025  that 
recommendation iv was met.  

84   Including  all  written  contributions  received  and  topics  of  discussion  for  a  meaningful  disclosure.  Civil 
Liberties  Union  for  Europe  (2025),  p.  353.  LobbyControl  (2024):  the  disclosure  of  lobbyists’  arguments 
that did not influence the respective draft law is equally in the public’s interest. 

10 

 
 
 
quarters  of  new  legislation  lacking  information  on  lobbying  input85.  Stakeholders  also 
highlight good practices, including by the Ministry of Justice86. 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 received87. 
Stakeholders  call  for  a  comprehensive  federal  transparency  law88.  While  the  Federal 
Government rejected a motion of opposition members of Parliament to introduce a legislative 
footprint  on  16  October  202589,  the  Federal  Government,  the  Federal  Parliament  and  the 
Länder  continue  to  work  on  the  digitalisation  of  the  law-making  process,  envisaging  a 
publicly  available joint, digitalised portal,  which is  expected to  be finalised by 2027 with a 
testing  phase  planned  for  202890.  The  creation  of  such  a  joint  digital  legislative  portal  for 
Government  and  Parliament  could  present  an  opportunity  to  include  a  fully-fledged 
legislative  footprint.  Against  this  background,  there  has  been  no  further  progress  on  the 
recommendation. 

Oversight and enforcement of conflicts of interest and asset declaration rules remain a 
challenge. Disclosure obligations for members of Parliament on conflicts of interest and their 
financial  interests  remain  limited  and  notably  do  not  include  ad  hoc  disclosures  in  plenary 
debates substantial investments in companies below 5%, and the time spent on remunerated 
side jobs91. Stakeholders continue to  remark  the lack of a fully independent  oversight  body 
considering  the  Parliament  Administration’s  structural  subordination  to  the  Parliament 
Presidium  as well as  its limited mandate to  investigate breaches92. Enforcement remains  an 
obstacle with several cases of non-compliance and significant publication delays of side job 
remuneration having raised public attention93. Allegations of nepotism for the employment of 

85   Country visit Germany, Ministry of Justice referring to Federal Statistics Office evaluation. LobbyControl 
(2025). Transparency International (2025d). Allianz für Lobbytransparenz (2025): of 120 legislative drafts 
submitted to Parliament (June 2024-June 2025), an executive footprint was illustrated in 30 and missing in 
90 drafts (75%). Of the 30 with an executive footprint, more than one third of the draft legislative proposals 
stated no influence had been exerted. Notably, only lobbying input that contributes to a significant extent or 
that has led to changes of the core aspects of the legislative proposal must be disclosed (Art. 43(1)GGO), 
providing for a wide discretion for Ministries preparing the drafts. LobbyControl (2025b). LobbyControl to 
publish an analysis in 2026. AbgeordnetenWatch (2026), suggesting more awareness-raising in ministries.  
86   LobbyControl  (2025b):  e.g.  the  Act  against  unfair  competition  (21/1855),  indicating  in  its  executive 
footprint  several  paragraphs  to  which  amendments  were  introduced  upon  interest  representatives’ 
contributions. 

87   Experts’ statements made in public hearings are published  (Section 70 Rules of Procedure of the  Federal 
Parliament). For lobbyists, there is an obligation to upload their inputs in the register, yet it is not connected 
to the legislative outputs or ongoing work. GRECO (2024), para. 9-16, concluding that the reform addresses 
recommendation (i). German authorities consider the disclosure of the content and objective of lobbying as 
a ‘more effective’ alternative than the disclosure of all individual contacts. 

88   Country visit Germany, LobbyControl, AbgeordnetenWatch. Transparency International (2024). 
89   Federal Parliament (2025a). 
90   The Government to finalise the technical parts by end 2026; the Parliament to finalise in the course of 2027. 

Country visit Germany, Parliament Administration. 

91   Members of 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.  Financial 
interests  are  only  subject  to  notification  in  the  context  of  their  parliamentary  committee  work.  GRECO 
(2021), p. 4. Ministers and parliamentary state secretaries are also not yet under any unequivocal obligation 
to  disclose  conflict  of  interests  on  an  ad  hoc  basis,  GRECO  (2023),  recommendation  vi,  pp.  8-9. 
AbgeordnetenWatch (2024). 

92   Country visit, Germany, LobbyControl, Transparency International. GRECO (2022), p. 9. 
93   Ibid.  AbgeordnetenWatch  (2025a):  despite  a  3-months  deadline,  not  all  declarations  on  parliamentarian’s 
side jobs were published by end October, i.e. seven months after the start of the new parliamentary term, 
due  to  the  necessity  to  review  the  disclosure  requirements  and  to  process  the  data.  Federal  Parliament 
(2025b)  for  data  on  initiated  investigations,  breaches,  sanctions  applied  and  amounts  paid  to  the  Federal 
11 

 
 
 
relatives of members of Parliament in other deputies’ offices have been in the public’s focus 
in  2026,  triggering  parliamentary  debates94.  The  asset  disclosure  rules  for  Government  top 
executives also remain limited in terms of oversight and transparency95. 

While  the  legislative  scope  is  broad  and  disclosures  are  increasing,  some  obstacles  for 
whistleblower  protection  in  practice  remain.  The  Act  for  the  Better  Protection  of 
Whistleblowers  encompasses  breaches  related  to  all  types  of  corruption  crimes  without  the 
need of  a link to  the EU budget96.  In practice, several  reporting offices exist  at  the Federal 
Government level, including in anti-corruption units97. The Federal Office for Justice, which 
administers the Federal external reporting channel, published its second annual report in 2025 
reporting  a  significant  increase  in  disclosures98.  Practitioners  and  stakeholders  consider  the 
legal  framework  and  whistleblower  disclosures  to  be  essential  to  uncover  large-scale 
corruption,  economic  crimes,  and  other  wrongdoings,  indicating  however  that  restrictive 
court  interpretation  impacts  the  granting  of  whistleblower  protection  status  and  that  rather 
high  compliance  requirements  raise  difficulties  for  SMEs99.  Following  two  external 
evaluations100,  the  Government  is  still  considering  conducting  an  internal  evaluation  of  the 
Act for the Better Protection of Whistleblowers, as originally planned two years after its entry 
into force in July 2023.  

The new political party sponsoring rules are expected to show effect in 2027, while other 
shortcomings  persist  in  party  and  campaign  finance.  Specific  reports  on  political  party 
sponsoring, required since 1 January 2025101, will be published and annexed for the first time 
to the general 2025 parties’ financial accountability reports in 2027102. These new reporting 
requirements  aim  to  increase  transparency  in  party  financing  and  prevent  hidden  campaign 
finance  at  federal  and  Länder  level.  Challenges  in  practice  relate  to  the  inaccessible,  non-
machine-readable format of the publicly available data and the significant time lapse until the 
reporting  of  party  income,  which  make  outside  monitoring  more  difficult103.  To  reduce  the 
time  lapse,  an  internal  administrative  decision  of  the  Parliament  Administration  aims  at 
having  financial  accountability  reports  published  already  during  its  review  process  in  the 
future104. Stakeholders also note that party and campaign donations are still not capped, with 
a tendency of an increasing number of large-scale donations being reported105. Furthermore, 
the  employment  of  relatives  and  close  associates  by  members  of  Parliament  for  taxpayer-

budget  in  the  last  electoral  term.  AbgeordnetenWatch  (2025b).  GRECO  (2024),  recommendation  (iv), 
paras. 21-27, pp. 5-6. 
94   Federal Parliament (2026b). 
95   GRECO recommendation (viii) is not implemented, GRECO (2025), paras. 47-51, p. 11. 
96   Apart from all crimes also misdemeanours are covered in as much as they concern important legal interests. 
97   Also the ‘Bundesanstalt für Finanzdienstleistung’ and ‘Bundeskartellamt’ provide reporting channels.  
98   Federal Office for Justice (2025) for 2024. Of the 1 802 reports (in 2023, 410), 71 cases (in 2023, 90) were 

transferred to prosecutors, 143 (in 2023, ca. 160) to other authorities.  

99   Country visit, Germany, Prosecution Service, Transparency International.  Whistleblowers helped to unveil 
major scandals, such as the Cum-Ex, Wirecard and tax leaks. 2025 Rule of Law Report, Germany, p. 12. 

100   Including by the Federal Statistical Office. 
101   Section 24 (8a) PartG, introduced in 2025, lowering donation reporting requirements from EUR 50 000 to 

35 000. 2025 Rule of Law Report, Germany, p. 12.  
102   Parliament Administration (2026), written input, p. 1. 
103   Country  visit  Germany,  LobbyControl,  Transparency  International.  See  also  LobbyControl  (2023). 

Transparency International (2023).  

104   Parliament Administration (2026), written input, p. 1. 
105   LobbyControl, AbgeordnetenWatch, Transparency International (2025). LobbyControl (2026) and (2025c), 
reporting about EUR 24 million as a record amount in campaign donations in the 2024/25 Federal elections. 
Transparency International (2025a). 

12 

 
 
 
funded  jobs106  and  the  collection  and  channelling  of  party  donations  through  foundations 
present  a  challenge,  circumventing  transparency  rules107.  The  Parliament  Administration’s 
oversight and investigative enforcement powers remain limited, with stakeholders proposing 
the establishment of an independent control body108.  

An  evaluation  of  the  law  on  the  Competition  Register  was  carried  out,  laying  out 
avenues  for  synergies  between  different  registers  for  the  investigation  of  data  of 
companies participating in public procurement. Businesses’ attitudes towards corruption 
in the EU show that 26% of companies in Germany (EU average 30%) think that corruption 
has prevented them from winning a public tender in practice in the last three years.  63% of 
businesses perceive the level of independence of the Federal public procurement review body 
(the  Federal  Cartel  Office)  as  very  or  fairly  good,  which  has  significantly  increased  in 
comparison  with  2025  (53%)109.  The  Single  Market  and  Competitiveness  Scoreboard  on 
access to public procurement in Germany reports 18% of single bids for 2025 (EU average 
27%).  In  2025,  the  Government  conducted  an  evaluation  of  the  law  on  the  Competition 
Register,  which  allows  potential  contracting  authorities  to  identify  bidders’  past  corruption 
fines  and  convictions.  The  evaluation  recommends  considering  linking  the  already  fully 
electronic Competition Register to the Company Data Register to create further synergies for 
the  investigation  of  company  data110.  In  the  context  of  ongoing  draft  revisions  proposed  in 
October 2026 to accelerate public procurement procedures while increasing the threshold for 
direct  awards111,  business  stakeholders  point  to  the  lack  of  competition  in  ‘below-the-
threshold’ procurements and increased corruption risks, which could affect the level playing 
field for businesses112. The 2025 report of the Federal police also identifies the services and 
construction sectors as particularly exposed to corruption-related offences 113.  

III.  MEDIA PLURALISM AND MEDIA FREEDOM  

independently 

The 
functioning  media  regulators  assumed  new  enforcement 
responsibilities.  The  14  media  regulators  continued  to  operate  independently,  with 
stakeholders  reporting  that  they  continue  to  function  well114.  The  6th  Interstate  Media 
Amendment  Treaty  entered  into  force  in  December  2025.  The  reform  aims  to  modernise 
protection of minors by strengthening technical safeguards and to enhance media supervision 
and  law  enforcement  by  expanding  the  powers  of  the  media  regulators  to  ensure  more 
effective compliance with youth protection rules115. Despite the growing number of tasks, the 
Government  reported  that  the  Courts  of  Auditors  found  that  the  state  media  authorities  are 
adequately financed116. 

106   Federal Parliament (2026). See also above in “conflict of interest” section. 
107   Country visit Germany, GFF. 
108   Country  visit  Germany,  LobbyControl,  AbgeordnetenWatch.  It  does  not  have  access  to  donors’  tax 
information for data verification and is subordinated to the Parliament’s Presidium. UNODC (2020), p. 67. 
Transparency International (2023). 
109   Figure 59, 2026 EU Justice Scoreboard. 
110   Federal Ministry of Economy and Energy (2025), p. 11. See also 2023 Rule of Law Report, p. 21. 
111   Law 21/1931 of 1 October 2025. Law 21/1934 of 1 October 2025, increasing thresholds from EUR 15 000 

to EUR 50 000.  

112   German Chamber of Commerce DIHK (2025). Country visit, Germany, Transparency International. 
113   Federal Criminal Police Office (2025). 
114   Vaunet  (2026),  written  input,  pp.  14-15;  Country  visit  Germany,  ZDF  and  ARD;  2026  Media  Pluralism 

Monitor, country report for Germany, p. 17; 2025 Rule of Law Report, Germany, p. 13.  

115   German Government (2026), written input, p. 32. 
116   German Government (2026), written input, p. 32. 

13 

 
 
 
Self-regulation  of  the  media  is  well  established,  and  reprimands  increased,  reaching  a 
very  high  level.  In  2025,  the  number  of  complaints  on  press  publications  that  the  German 
Press Council117 received increased for the third year in a row to 2 636 (compared to 2 215 in 
2024).  The  most  frequently  raised  complaints  concerned  alleged  serious  breaches  of 
journalistic due diligence, followed by infringements 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 102 in 2025118. 

the 

Reforms  to  further  strengthen  the  independent  functioning  of  the  public  service 
broadcasters  entered  into  force,  while  future  funding  remains  under  discussion.  The 
Media  Pluralism  Monitor  (MPM)  2026  reports  a  low  risk  for  the  independence  of  public 
service media119. In December 2025, the Interstate Reform Treaty entered into force. It aims 
to  modernise  the  structure  of  the  public  service  broadcasting  corporations  and  improve 
efficiency, including through increased flexibility in programme offerings120. The Treaty also 
further  strengthens 
independent  functioning  of  public  service  broadcasters  by 
strengthening  the  dismissal  and  appointment  procedures  of  members  of  the  management 
bodies121. A license fee remains the main source of funding for public service broadcasters. 
The  decision  by  the  Länder  not  to  follow  the  recommendation  of  the  independent  expert 
commission  (KEF)  to  increase  the  license  fee  by  3.2%  for  the  2025-2026  period  has  been 
challenged by the public service broadcasters before the Federal Constitutional Court, and the 
case is still pending. In the meantime, in February 2026, the KEF presented an updated, lower 
proposal  for  the  adjustment  of  the  licence  fee  as  of  2027122.  This  ongoing  challenge  has 
contributed  to  delays  in  the  adoption  of  the  Interstate  Broadcasting  Financing  Amendment 
Treaty, which had been proposed in 2024 to adjust the funding procedure from 2027123.  

The  business  environment  for  media  service  providers  remained  overall  stable,  and 
plans  to  adopt  new  measures  to  support  media  pluralism  are  progressing.  Access  to 
ownership information about media service providers continued to be provided via a public 
database124.  However,  some  stakeholders  expressed  concerns  about  concentration  in  the 
media market125. The 2026 MPM reports a very high risk to the plurality of media providers 
and a high risk to the plurality in digital markets126. Work is currently ongoing to adopt the 
Digital Media Treaty. The first part of the Treaty, whose draft was agreed upon by the Länder 
in June 2025, aims to cover aspects such as state advertising, with  a view to align with the 
European  Media  Freedom  Act.  In  October  2025,  the  Länder  agreed  on  the  objectives  for  a 
planned second part of the Digital Media Treaty. These include strengthening the economic 
foundation  of  private  media,  reinforcing  the  discoverability  of  media  content,  and 

117   2025 Rule of Law Report, Germany, p. 13. The Press Council (the self-regulatory body for press and online 
media) is widely accepted in the print and online media sectors. Reporters Without Borders (2026), written 
input, p. 16; Vaunet (2026), written input, p. 15; Country visit Germany, Press Council. 

118   Presserat (2026b). 
119   2026 Media Pluralism Monitor, country report for Germany, p. 28. 
120   Country visit Germany, Media authorities of the Länder, ZDF and ARD. 
121   German Government (2026), written input, pp. 33-34. 
122   It envisages an increase from EUR 18.36 to EUR 18.64, instead of EUR 18.94. KEF (2026).  
123   Country visit Germany, Media authorities of the Länder, ZDF, ARD and Journalists Association; Reporters 

Without Borders (2026), written input, p. 15. 

124   2025 Rule of Law Report, Germany, p. 15; Vaunet (2026), written input, p. 17. 
125   European  Centre  for  Press  and  Media  Freedom  (2026),  written  input,  p.  17;  Media  Ownership  Monitor, 

Germany. 

126   2026 Media Pluralism Monitor, country report for Germany, pp. 20-21. 

14 

 
 
 
safeguarding  media  pluralism  via  a  reform  of  the  media  concentration  rules127.  Some 
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 platforms, which could pose a threat to media pluralism128. 

There has been no further progress on the recommendation to establish a codified right 
of the press to information from federal authorities129. Following the early parliamentary 
elections  in  2025,  internal  preparations  for  a  codification  of  the  right  of  the  press  to 
information  from  federal  authorities  were  not  pursued  further130.  The  establishment  of  a 
statutory  framework  remains  under  consideration,  but  no  concrete  proposals  have  been 
presented131.  Stakeholders  expressed  concerns  about  the  absence  of  a  clear  legal  basis  for 
access to information from federal authorities  132. Therefore, no progress has been made on 
the recommendation.  

The  overall  protection  framework  for  journalists  has  remained  stable,  but  reports  of 
physical and online attacks raise concern. An increased risk to the journalistic profession, 
standards,  and  protection  was  reported  by  the  2026  MPM  partly  due  to  a  rise  in  observed 
attacks taking place during demonstrations133. Since the last rule of law report, the Council of 
Europe Platform to promote the protection of journalism and safety of journalists issued one 
new alert concerning Germany134, while the Mapping Media Freedom platform recorded 98 
new  alerts  related  to  media  freedom.  The  alerts  mainly  concern  cases  of  attacks  or  threats 
against  journalists,  as  well  as  the  obstruction  of  journalistic  activity,  of  which  many  took 
place during the coverage of demonstrations135.Police statistics on politically motivated crime 
for 2025 show a total of 486 registered offenses within the broad target category of "media", 
representing  an  increase  of  14.89%  (compared  to  423  offenses  in  2024)136.  The  public 
authorities at federal and Länder level continue to take measures to ensure journalists’ safety, 
including  during  protests  and  demonstrations.  This  involves  exchanges  between  the  police 
and  the  media,  as  well  as  training  on  press  law  to  the  Federal  Police  and  Federal  Criminal 
Police  Office  officers137.  However,  some  stakeholders  expressed  concerns  that  the  level  of 

127   German Government (2026), written input, pp. 34-35. 
128   Reporters without Borders (2026), written input,  p. 20; Vaunet (2026), written input,  p. 18; Country visit 

Germany, Vaunet and Publishers Association. 

129   The 2025 Rule of Law Report recommended Germany to “[a]dvance 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.” Limited progress was previously assessed on the recommendation in 2025 and, no 
further progress in 2024 and some progress in 2023. 

130   German Government (2026), written input, p. 2.  At the same time, the coalition agreement has committed 
to  review  the  broader  freedom  of  information  legislation  to  benefit  both  citizens  and  the  public 
administration.  German  Government  (2025a),  p.  59.  The  press's  constitutional  right  to  information  from 
federal authorities—which, according to established case law, derives directly from Article 5, Paragraph 1 
of the Basic Law—remains unchanged. 

131   German  Government  (2026),  written  input,  p.  2;  Reporters  Without  Borders  (2026),  written  input,  p.  19; 

Country visit Germany, Vaunet. 

132   Transparency  International  (2026),  written  input,  p.  19;  Vaunet  (2026),  written  input,  p.  18;  European 
Centre for Press and Media Freedom (2026), written input, pp. 19-20; Reporters Without Borders (2026), 
written input, p. 21. 

133   2026 Media Pluralism Monitor, country report for Germany, pp. 11-12. 
134   Council of Europe Safety of Journalist Platform (2026). 
135   Mapping Media Freedom (2026). 
136  Federal Criminal Police Office (2026).   
137   European Centre for Press and Media Freedom (2026), written input, p. 18; Country visit Germany, Vaunet, 

Media authorities of the Länder. 

15 

 
 
 
protection  varies  across  the  Länder138.  Some  stakeholders  reported  persisting  challenges 
related  to  effective  investigations  of  threats  or  attacks  as  well  as  concerns  related  to  the 
protection  of  their  personal  data,  which  sometimes  discouraged  journalists  from  filing 
criminal complaints after threats or attacks139. In addition, potentially inadequate safeguards 
to  prevent  unjustified  law  enforcement  access  to  electronic  communications  data  in  recent 
draft  legislation  have  also  been  raised  by  stakeholders,  citing  risks  to  the  protection  of 
journalistic sources140. 

Work  is  ongoing  to  establish  anti-SLAPP  safeguards  in  legislation.  Strategic  lawsuits 
against public participation (SLAPPs) targeting journalists are generally not seen as a major 
concern  for  the  media  sector141.  Since  2024,  the  Government  co-finances  a  civil  society 
helpline  that  offers  psychosocial  support  to  victims  of  SLAPPs.  In  2025  the  contact  point 
reported 48 support requests142. In December 2025, the Government submitted to Parliament 
a draft law aiming to transpose the EU Anti-SLAPP Directive. The draft establishes rules to 
ensure that abusive proceedings against critical expression or reporting are swiftly concluded 
and unfounded claims dismissed at  an early stage143. Moreover, it will be made possible to 
collect  data on SLAPP cases144. Stakeholders regretted that the draft law, unlike a previous 
draft, covers only cross-border cases and not domestic cases and does not contain protection 
provisions for intimidation attempts that precede litigation145.  

IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

The length of stakeholder consultations and use of impact assessments continues to vary 
in practice among Ministries. While the recommended consultation period for draft laws at 
the federal level is four weeks, no centralised statistics on consultation length are available, 
also due to the absence of a central consultation platform146. The National Regulatory Control 
Council  (NKR)147  as  well  as  stakeholders,  including  from  the  business  sector,  continue  to 
report notable variations in practice between Ministries as regards the length of consultation 
periods148.  The  NKR  further  underlines  that  impact  assessments  usually  remain  limited  to 

138   European Centre for Press and Media Freedom (2026), written input, p. 18. 
139   For  example,  cases  where  local  authorities  refuse  to  restrict  access  to  journalists’  personal  data  in  the 
population  register,  or  in  criminal  proceedings,  where  access  to  case  files  may  expose  private  home 
addresses to opposing parties. European Centre for Press and Media Freedom (2026), written input, p. 18. 
140   Stakeholders  are  particularly  concerned  about  potentially  inadequate  safeguards  in  the  draft  law  on  IP 
address retention and the draft reform of the Federal Intelligence Service Act, both of which aim to expand 
authorities’ competencies relating to data storage, surveillance, and cyber capabilities. European Centre for 
Press and Media Freedom (2026), written input, p. 18; European Federation of Journalists (2026), written 
input,  p.  17;  Reporters  Without  Borders  (2026),  written  input,  pp.  17,  21;  Country  visit  Germany, 
Journalists Association. 

141   European  Centre  for  Press  and  Media  Freedom  (2026),  written  input,  p.  20;  Reporters  Without  Borders 

(2026), written input, p. 20; Country visit Germany, Press Council, ZDF and ARD. 

142   Reporters Without Borders (2026), written input, p. 20. 
143   German Government (2026), written input, p. 36. 
144   County visit Germany, Joint Office of Media Authorities and BKM.  
145   Country visit Germany, Journalists Association and Publishers Association; European Centre for Press and 
Media Freedom (2026), written input, pp. 20-21; European Federation of Journalists (2026), written input, 
pp. 17-18; Reporters Without Borders (2026), written input, p. 20.  

146   2025 Rule of Law Report, Germany, pp. 16-17. 
147   The  National  Regulatory  Control  Council  (NKR)  is  tasked  to  review  draft  legislation  with  regards  to  the 
costs  imposed  and  whether  less  burdensome  alternatives  exist.  According  to  its  annual  Report  2025,  the 
four-week deadline for consultation of the NKR was only met in 48% of cases in 2024-2025, while in 26% 
of cases the deadline was less than five days. NKR (2026), p. 5.  

148   Country visit Germany, NKR, GFF, Federal Bar, Bar Association, DIMR.   

16 

 
 
 
 
assessing compliance costs of proposals, instead of broader cost-benefit analyses. As part of 
the  federal  modernisation  agenda,  the  role  of  impact  assessments  at  an  early  stage  of  the 
process  is  intended  to  be  strengthened149.  OECD  indicators  show  that  Germany  performs 
below the EU average for engagement of stakeholders in policy-making, but above-average 
for regulatory impact assessments150. As regards parliamentary hearings, the German Institute 
for Human Rights (DIMR), which is the National Human Right Institution accredited with A-
Status,  continues  to  highlight  the  lack  of  follow-up  to  the  recommendation  by  the  Global 
Alliance  for  National  Human  Rights  Institution’s  Sub-Committee  for  Accreditation  to 
formalise the institute’s participation therein151.  

On  1  January  2026,  Germany  had  four  leading  judgments  of  the  European  Court  of 
Human  Rights  pending  implementation,  a  decrease  of  five  compared  to  the  previous 
year152. At that time, Germany’s rate of leading  judgments  from  the past  10 years that had 
been implemented was at 86% (compared to 71% in 2025; 14% remained pending), and the 
average time that the judgments had been pending implementation was 2 years and 5 months 
(compared to 3 years and 8 months in 2025)153. As regards the respect of payment deadlines, 
on  31  December  2025  there  was  1  case  awaiting  confirmation  of  payments  (compared  to 
none in 2024)154. By 17 June 2026, the number of leading judgments pending implementation 
had remained at 4155. As regards the implementation of national judgments, individual cases 
of non-implementation or disregarding by public authorities of binding court judgments have 
been raised  as  a concern156. As part of the revision of the Administrative Procedural  Code, 
the Government is proposing limited adjustments to improve enforcement of administrative 
court decisions against public authorities, notably raising the maximum level of the possible 
fine and allowing courts to impose repeated fines157.  

More  than  half  of  companies  surveyed  in  Germany  express  confidence  in  the 
effectiveness of investment protection. 56% of companies are very or fairly confident that 
investments  are  protected  by  law  and  courts,  a  figure  which  has  slightly  decreased  in 
comparison with 2025 (58%)158. As regards authorities relevant for economic operators 50% 
perceive the level of independence of the Federal Cartel Office as very or fairly good when it 
is deciding in competition matters, a figure which has significantly decreased in comparison 

149   Country visit Germany, NKR. German Government (2025b), pp. 19-22.   
150   OECD (2025a), p. 153.  
151   DIMR (2026), written input.   
152   For an explanation of the supervision process, see the website of the Council of Europe.   
153   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 2026. EIN (2026), written input, pp. 4-5. 
154   Council of Europe (2026), p. 162. The payment was made on time, and the confirmation was provided on 

19 January 2026. Subsequently, on 29 April 2026, the Committee of Ministers closed the procedure.  

155   Data according to the online database of the Council of Europe (HUDOC). 
156   Most  notably  a  ruling  of  the  Berlin  Administrative  Court  of  2  June  2025  that  found  rejections  at  border 
controls to be unlawful (the decision in the  main proceedings is still pending). Liberties (2026), pp. 305-
306. This case also resulted in significant online attacks against the judge as well as the lawyers and NGOs 
supporting  the  applicants.  German  Judges’  Association,  German  Association  of  Administrative  Judges 
(2026), written inputs, p. 12 and p. 12 respectively.  

157   Ministry  of  Justice  (2026).  The  maximum  fine  is  increased  from  EUR  10 000  to  EUR  25 000.  It  is 

furthermore envisaged that the fine does not benefit the concerned administrative authority. 

158   Figures  52  and  53,  2026  EU  Justice  Scoreboard.  28%  and  23%  of  the  surveyed  investors  respectively 
perceive  the  frequent  changes  in  legislation  or  concerns  about  the  quality  of  the  law-making  process  and 
concerns  about  quality,  efficiency  or  independence  of  justice  as  a  reason  for  the  lack  of  confidence  in 
investment protection. 

17 

 
 
 
with  2025  (56%)159.  The  Federal  Administrative  Court  has  jurisdiction  in  several  business-
related cases, including in cases related to public concessions, public contracts and economic 
regulation.  A  number  of  judicial  mechanisms  to  improve  efficiency  are  available  in  these 
cases, including the possibility to apply interim measures, joint examination of similar cases 
and the consolidation of multiple appeals160. 

the 

to  reform 

legal  framework  regarding 

There has been no progress  on the recommendation to adapt the tax-exempt status of 
non-profit organisations, which still creates obstacles for civil society in practice161. The 
authorities  confirm  that,  following  an  examination  of  the  recommendation,  there  are  no 
intentions 
tax-exemptions  for  non-profit 
organisations,  as  they  consider  the  rules  in  place  to  be  sufficient162.  However,  civil  society 
organisations (CSOs) continue to experience challenges in practice related in particular to the 
uncertainty  as  to  what  type  of  political  activity  unrelated  to  the  non-profit  purpose  of  their 
organisation is permissible, to the limits to the catalogue of grounds for non-profit status and 
to limitations on the use of ‘political means’ to achieve the organisation’s stated purpose163. 
In this context CSOs continue to report  cases of instrumentalisation of the current system’s 
ambiguity as an intimidation strategy by certain political parties who report CSOs to the tax 
authorities for alleged political activity164, which continues to create a chilling effect in view 
of their wiliness and capacity to participate in public debates. Overall, no progress has been 
made on the recommendation.  

Civil  society  organisations  continue  to  face  some  challenges  to  their  operations,  and 
funding  schemes  for  organisations  in  the  area  of  democracy  promotion  are  currently 
under  review.  In  December  2025,  Germany’s  civic  space  rating  was  downgraded  from 
‘narrowed’ to ‘obstructed’ by Civicus165. Concerns persist regarding restrictions to the rights 
of  freedom  of  expression  and  assembly  including  excessive  use  of  force  by  police  and 
suppression of protests166, as has been raised by several UN Special Rapporteurs and the UN 
Human  Rights  Council167,  the  Council  of  Europe  Commissioner  for  Human  Rights168  and 

159   Figure 60, 2026 EU Justice Scoreboard.  
160   Figures 66 and 67, 2026 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. 

161   The 2025 Rule of Law  Report recommended Germany to “[t]ake 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”. No progress was previously assessed on this recommendation in 2025, 2024, 2023.  
162   Reference is notably made to  an existing administrative decree (Anwendungserlass zur  Abgabenordnung) 
which  provides  certain  clarifications  as  regards  what  constitutes  “occasional  political  activity”.  German 
Government (2026), written input, pp. 2-3 and Country visit Germany, Ministry of Finance.  

163   2025 Rule of Law Report, Germany, p. 18. DIMR (2026), written input. Liberties, European Civic Forum 
(2026), written inputs, pp. 313 and p. 7, respectively. Country visit Germany, Allianz Rechtssicherheit. An 
overview of key concerns with the current system by an alliance of over 200 CSOs can be found here.  

164   European Civic Forum (2026), written input, p. 7. Country visit Germany, Allianz Rechtssicherheit.  
165   Germany’s  score  is  60/100.  Ratings  by  Civicus  are  on  a  five-category  scale  defined  as:  open,  narrowed, 

obstructed, repressed, and closed. 

166   2025 Rule of Law Report, Germany, pp. 18-19. Liberties (2026), written input, p. 314.  
167   UN Special Rapporteur for freedom of opinion and expression (2026); Letter by the Special Procedures of 
the UN Human Rights Council (2025b) and Press release (2025a), reacting to the response by the German 
Government (2025c). 

168   Memorandum  of  15  April  2026,  following  the  visit  by  the  Council  of  Europe  Commissioner  for  Human 
Rights in October 2025, following up to a letter of 6 June 2025. Germany responded to the letter on 23 June 
2025, considering the criticism to be unfounded. 

18 

 
 
 
national stakeholders169. The German authorities note that these freedoms may be restricted 
under certain  conditions as also  provided under the EU Charter of Fundamental Rights  and 
the  European  Convention  on  Human  Rights  and  that  measures  are  generally  subject  to 
judicial control170.  In some cases, courts have subsequently found the police’s use of force or 
disruption  of  events  to  be  unlawful,  with  appeals  in  a  number  of  cases  still  pending171.  A 
media analysis published in December 2025 has shown a proliferation of anti-CSO narratives 
from  political  actors  and  in  broader  public  discourse,  which  is  also  observed  by 
stakeholders172.  CSOs  further  raise  concerns  regarding  the  increased  questioning  of  their 
funding by Government programmes and perceived attempts to delegitimise their activity173. 
As regards funding for  civil  society, the Government has announced a  further development 
and  reorientation  of  the  ‘Demokratie  Leben’  programme,  which  supports  initiatives 
promoting diversity, tolerance and democracy for the period 2025-2032, by summer 2026174, 
which  has  drawn  criticism  from  some  stakeholders175.  The  engagement  strategy  for  the 
voluntary sector adopted in December 2024 continues to be implemented, with stakeholders 
welcoming the round table with the Federal Chancellery established to discuss issues related 
to voluntary engagement in view of the ‘Future Pact for Engagement’176  

169   Country  visit  Germany,  DIMR,  GFF,  Allianz  Rechtssicherheit.  European  Civic  Forum,  Liberties  (2026), 

written inputs, p. 4-9 and pp. 316-318, respectively. DIMR (2026), written input.  

170  Country visit Germany, Ministry of Justice. German Government (2026a), additional written input.  
171   European Civic Forum (2026), written input, p. 5. Liberties (2026), written input, p. 317.  
172   Maecenata Foundation (2025). European Civic Forum (2026), written input, pp. 4-5. In 2025, trust in NGOs 

declined to 40%, down by 2 percentage points compared to 2024. Edelman Trust Barometer (2025). 

173   See also a study by Maecenata Foundation (2026) showing that around 47% of all parliamentary questions 
during the current legislature mentioning CSOs engage in rhetoric delegitimising their activity (compared to 
32% and 10% in the two preceding parliamentary terms). Liberties (2026), written input, p. 316.  

174   2025  Rule  of  Law  Report,  pp.  18-19.  European  Civic  Forum  (2026),  written  input,  p.  5.  DIMR  (2026), 
written  input.  CSOs  note  that  recipients  received  in  the  most  recent  funding  agreements  more  restrictive 
conditions, including as regards responsibilities for third parties (e.g. speakers at events) and requirements 
to pre-approve publications or statements with any political content. Country visit Germany, GFF, BBE.   
175   Country  visit  Germany,  GFF,  Allianz  Rechtssicherheit,  DIMR,  Bündnis  Bürgerschaftliches  Engagement 

(BBE). BBE (2026). 

176   The “Zukunftspakt Engagement”. Country visit Germany, BBE. 2025 Rule of Law Report, Germany, p. 19.  

19 

 
 
 
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2026 Rule of Law Report 
can 
https://commission.europa.eu/publications/2026-rule-law-report-targeted-
found 
stakeholder-consultation_en . 

be 

at 

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

immer 

Volle 

noch 

2.0? 

gibt 

es 

Abgeordnetenwatch  (2024),  These  are  the  additional  earnings  of  members  of  the  Bundestag  (Diese 
Nebeneinkünfte 
Bundestag), 
https://www.abgeordnetenwatch.de/recherchen/nebentaetigkeiten/diese-nebeneinkuenfte-haben-die-
abgeordneten-im-bundestag.   

Abgeordneten 

haben 

die 

im 

AbgeordnetenWatch  (2025),  The  hidden 
Lobbynetzwerke 
Konzerne) 
https://www.abgeordnetenwatch.de/recherchen/lobbyismus/die-verdeckten-lobbynetzwerke-der-
konzerne#:~:text=JavaScript%20muss%20aktiviert%20sein%2C%20um%20dieses%20Formular%20
zu%20verwenden.  

lobby  networks  of  corporations  (Die  verdeckten 
2025) 

July 

der 

(15 

AbgeordnetenWatch  (2025a),  Transparency  on  hold:  Federal  Parliament  cannot  keep  up  with  the 
publication  of  side  incomes  (Transparenz  stockt:  Bundestag  kommt  mit  Veroeffentlichung  von 
Nebeneinkuenften 
2025), 
https://www.abgeordnetenwatch.de/recherchen/nebentaetigkeiten/bundestag-kommt-mit-
veroeffentlichung-von-nebeneinkuenften-nicht-hinterher.     

hinterher) 

October 

nicht 

(30 

AbgeordnetenWatch (2025b), Breach of transparency obligations: Julia Kloeckner and the exclusive 
lobby  club  (Verstoß  gegen  Transparenzpflichten:  Julia  Klöckner  und  der  exklusive  Lobbyclub)  (9 
June  2025),  https://www.abgeordnetenwatch.de/recherchen/interessenkonflikte/julia-kloeckner-und-
der-exklusive-lobbyclub.   

AbgeordnetenWatch (2026), Good intention, bad practice; why the ministries fail with the lobbying 
footprint (Gut gedacht, schlecht gemacht: Warum die Ministerien beim Lobby-Fußabdruck versagen) 
(6  March  2026),  https://www.abgeordnetenwatch.de/kampagnen/warum-die-ministerien-beim-lobby-
fussabdruck-versagen.   

Allianz  Rechtssicherheit  (not  dated),  Demands  for  changing  the  legal  situation  (Forderungen  zur 
Änderung der Rechtslage), https://www.zivilgesellschaft-ist-gemeinnuetzig.de/forderungen/.  

Bar Association (2026), input by the German Bar Association for the 2026 Rule of Law Report.  

Bundesnetzwerk  Bürgerschaftliches  Engagement  (BBE)  (2026),  Newsletter  of  26  March  2026, 
https://www.b-b-e.de/bbe-newsletter/newsletter-nr-5-vom-26-maerz-2026/#engagementpolitik1.  

Bürgerschaft  Hamburg,  Committee  for  Justice  (2025),  Report:  Another  milestone  for  more 
transparency  and  trust  in  politics:  After  the  transparency  portal  Hamburg  is  now  getting  also  a 
lobbying  register  (Bericht:  Ein  weiterer  Meilenstein  fuer  mehr  Transparenz  und  Vertrauen  in  die 
Politik:  Nach  dem  Transparenzportal  bekommt  Hamburg  nun  auch  ein  Lobbyregister  –  Antrag 
SPD/Gruene) 
https://www.buergerschaft-
hh.de/parldok/dokument/90016/22_17692_bericht_des_ausschusses_fuer_justiz_und_verbrauchersch
utz_ueber_die_drucksachen_22_17395_ein_weiterer_meilenstein_fuer_mehr_transparenz_und_vertra
uen_.  

(22/17692), 

Civicus, Monitor tracking civic space – Germany, https://monitor.civicus.org/country/germany/.  

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

for  Europe 

(2025a), 

Liberties  Rule 

of 

Law  Report, 

20 

 
 
Civil Liberties Union for Europe (Liberties) (2026), input from Civil Liberties Union for Europe for 
the 2026 Rule of Law Report, https://www.liberties.eu/f/wtaqoq.  

Conference  of  the  Justice  Ministers  (2026a),  Preserving  the  rule  of  law  and  strengthening  the 
resilience  of  the  judiciary  (Den  Rechtsstaat  bewahren  und  die  Resilienz  der  Justiz  stärken), 
https://www.justiz.nrw.de/sites/default/files/2026-06/TOP%20I.20.pdf.  

Conference  of  the  Justice  Ministers  (2026b),  Rule  of  law  campaign  of  the  Länder  to  promote  the 
recruitment  of  young  talent  in  the  judiciary  (Rechtsstaatskampagne  der  Länder  zur  Förderung  der 
https://www.justiz.nrw.de/sites/default/files/2026-
Nachwuchsgewinnung 
06/TOP%20I.19.pdf.  

Justiz), 

der 

in 

Conference of the Justice Ministers (2025a), Pact for the rule of law – three pillars for a strong justice 
system 
Justiz), 
den  Rechtsstaat 
https://www.justiz.nrw.de/sites/default/files/2025-11/TOP%20I.28%20-
%20Pakt_f%C3%BCr_den_Rechtsstaat.pdf.  

Säulen 

starke 

(Pakt 

eine 

drei 

für 

für 

– 

Conference  of  the  Justice  Ministers  (2025b),  Constitutional  loyalty  of  lay  judges  (Verfassungstreue 
ehrenamtlicher  Richterinnen  und  Richter),  https://www.justiz.nrw.de/sites/default/files/2025-
11/TOP%20I.24%20-%20SN%20Verfassungstreue%20ehrenamtliche%20Richter.pdf.  

Conference of the Justice Ministers (2025c), Future of the chamber for commercial matters (Zukunft 
https://www.justiz.nrw.de/sites/default/files/2025-
der 
06/TOP%20I.24%20-%20Zukunft%20der%20Kammer%20f%C3%BCr%20Handelssachen.pdf.  

Handelssachen), 

Kammer 

für 

Council of Europe (2026), Supervision of the execution of judgments decisions of the European Court 
of Human Rights – 19th Annual Report of the Committee of Ministers – 2025, https://rm.coe.int/2025-
annual-report/48802b1633.  

Council  of  Europe  Commissioner  for  Human  Rights  (2025),  Human  Rights  Commissioner 
O’Flaherty’s  visit  to  Germany:  focus  on  migration,  freedoms  of  assembly  and  expression, 
antisemitism  and  anti-Muslim  hatred,  https://www.coe.int/en/web/commissioner/-/human-rights-
commissioner-o-flaherty-s-visit-to-germany-focus-on-migration-freedoms-of-assembly-and-
expression-antisemitism-and-anti-muslim-hatred.  

Council  of  Europe  Commissioner  for  Human  Rights  (2026),  Memorandum  following  the 
Commissioner’s  visit  to  Germany  from  13  to  17  October  2025,  https://rm.coe.int/memorandum-on-
germany-following-visit-from-13-17-october-2025-by-micha/48802b4fc7.  

Council of Europe: Platform to promote the protection of journalism and safety of journalists. 

Deutsche  Industrie-  und  Handelskammer  (DIHK),  Position  to  the  draft  law  on  the  accelration  of 
public  procurement 
(28  July  2025), 
(Stellungnahme  zum  Vergabebeschleunigungsgesetz) 
https://www.dihk.de/resource/blob/135050/3663e6f5eeaef6479c3499f8cc31412f/recht-dihk-
stellungnahme-vergabebeschleunigungsgesetz-data.pdf.  

Directorate-General  for  Communication  (2026),  Flash  Eurobarometer  582  on  Businesses’  attitudes 
towards corruption and businesses’ perception of the independence of national justice systems in the 
EU and in selected enlargement countries in 2026. 

Directorate-General  for  Communication  (2026),  Special  Eurobarometer  573  on  citizens’  attitudes 
towards corruption in the EU in 2026. 

Edelmann  Trust  Survey 
https://www.edelman.de/sites/g/files/aatuss401/files/2025-
01/2025%20Edelman%20Trust%20Barometer_Germany%20Report.pdf.  

(2025),  Trust  and 

the  Crisis  of  Grievance  Germany  Report, 

EU Affairs Committee of the Conference of the Justice Ministers (2026), additional written input for 
the 2026 Rule of Law Report.  

European Civic Forum – Germany (2026), input from the European Civic Forum for the 2026 Rule of 
Law Report.  

21 

 
 
European Centre for Press and Media Freedom (2026), input from the European Centre for Press and 
Media Freedom for the 2026 Rule of Law Report.  

European Centre for Press and Media Freedom (2026), Mapping Media Freedom, Germany country 
profile, https://www.mappingmediafreedom.org/.  

European  Centre  for  Press  and  Media  Freedom  (2026),  Media  Pluralism  Monitor  2026, 
https://cmpf.eui.eu/projects-cmpf/media-pluralism-monitor/.  

European Commission (2024), 2024 EU Justice Scoreboard.  

European Commission (2025), 2025 Rule of Law Report, Country Chapter on the rule of law situation 
in Germany.  

European Commission (2026), European Semester Country Report Germany.  

European Commission (2026), 2026 EU Justice Scoreboard. 

European Federation of Journalists (2026), input from the European Federation of Journalists for the 
2026 Rule of Law Report.  

European Implementation Network (2026), Input from the European Implementation Network for the 
2026 Rule of Law Report. 

European 
Prosecutor’s 
https://www.eppo.europa.eu/assets/annual-report-2025/index.html. 

(2026), 

Public 

Office 

Annual 

Report 

2025, 

European Public Prosecutor’s Office (2026), input from EPPO for the 2026 Rule of Law Report.   

Federal  Bar  (2025),  International  legal  assistance  in  criminal  matters:  BRAK  criticises  new  rules 
Neuregelung), 
Strafsachen: 
(Internationale 
https://www.brak.de/newsroom/newsletter/nachrichten-aus-berlin/2026/ausgabe-2-2026-v-
2112026/internationale-rechtshilfe-in-strafsachen-brak-kritisiert-neuregelung/.  

Rechtshilfe 

kritisiert 

BRAK 

in 

Federal Bar (2026), input from the Federal Bar for the 2026 Rule of Law Report.  

Federal  Criminal  Police  Office  (2026),  Politically  motived  crime  2025  (Politisch  motivierte 
Kriminalität 
2025),  
https://www.bka.de/DE/UnsereAufgaben/Deliktsbereiche/PMK/PMKZahlen/PMKZahlen.  

Federal  Criminal  Police  Office 
-  Corruption  2024, 
https://www.bka.de/SharedDocs/Downloads/DE/Publikationen/JahresberichteUndLagebilder/Korrupti
on/korruptionBundeslagebild2024.html?nn=28078. 

(2025),  Federal  Situation  Report 

Federal  Ministry  of  the  Economy  and  Energy  (2025),  Evaluation  of  the  law  on  the  competition 
register 
2025), 
https://www.bundeswirtschaftsministerium.de/Redaktion/DE/Evaluationen/Gesetze-
Verordnungen/evaluierung-des-wettbewerbsregistergesetzes.html. 

Wettbewerbsregistergesetzes) 

(Evaluierung 

July 

des 

(10 

Federal  Office  for  Justice  (2025),  Annual  report  of  the  External  Federal  Reporting  Channel 
(Bundesamt 
Bundes), 
Externe 
https://www.bundesjustizamt.de/SharedDocs/Downloads/DE/MeldestelledesBundes/Jahresbericht_20
24.pdf?__blob=publicationFile&v=2.  

Meldestelle 

Justiz, 

fuer 

des 

Federal  Parliament  (2025a)  Motion:  Strong  democracy  –  Creating  transparency  and  strengthening 
parliamentary  control  (Antrag:  Starke  Demokratie  –  Transparenz  schaffen  und  parlamentarische 
2025, 
Kontrolle 
https://dserver.bundestag.de/btd/21/022/2102231.pdf.  

staerken), 

21/2231 

October 

15 

of 

Federal Parliament (2025b), Report of the President of the Federal Parliament pursuant to Art. 51 (6) 
of the Law of Members of Parliament (Bericht der Praesidentin des Deutschen Bundestages nach § 
2025), 
des 
51 
https://dserver.bundestag.de/btd/21/001/2100185.pdf. 

Abgeordnetengesetzes) 

21  May 

(21/185 

Absatz 

of 

6 

22 

 
 
Federal Parliament (2026a), Debate on „Demokratie Leben“ – Protect engagement, maintain support 
structure  (Debatte  zu  Demokratie  leben  –  Engagement  schützen,  Förderstrukturen  erhalten) 
https://dserver.bundestag.de/btp/21/21069.pdf#P.8396.  

Federal Parliament (2026b), Debate on employment of relatives by AfD members of the Parliament 
AfD-Abgeordneten), 
(Aussprache 
https://www.bundestag.de/dokumente/textarchiv/2026/kw09-de-aktuelle-stunde-verwandtenaffaere-
1149754.  

Verwandtenbeschaeftigung 

zur 

bei 

German  Association  of  Administrative  Judges  (2026),  input  from  the  German  Association  of 
Administrative Judges for the 2026 Rule of Law Report.   

German  Constitutional  Court,  judgment  17  September  2025,  Beamtenbesoldung  Berlin,  2  BvL  5/18 
u.a.  

German Court of Auditors (2026), additional written input.  

German 
https://www.koalitionsvertrag2025.de/sites/www.koalitionsvertrag2025.de/files/koav_2025.pdf.   

Government 

Agreement 

Coalition 

(Koalitionsvertrag), 

(2025a), 

German  Government 
(Modernisierungsagenda 
für 
https://bmds.bund.de/fileadmin/BMDS/Dokumente/Modernisierungsagenda_barrierefrei-neu.pdf.  

the  State  and  administration 
Verwaltung), 

(2025b),  Modernisation  agenda 

for 
Staat 

und 

– 

German  Government  (2025c),  Germany’s  response  to  the  Joint  Communication  AL  DEU  2/2025, 
https://spcommreports.ohchr.org/TMResultsBase/DownLoadFile?gId=39294.  

German Government (2026), input from Germany for the 2026 Rule of Law Report.  

German  Institute  for  Human  Rights  (DIMR)  (2026),  input  from  the  German  Institute  for  Human 
Rights for the 2026 Rule of Law Report.  

German  Judges  Association  (2025),  Prudence  needed  in  the  election  of  constitutional  judges 
https://www.drb.de/newsroom/presse-
(Besonnenheit 
mediencenter/pressemeldungen-auf-einen-blick/pressemeldung/news/besonnenheit-bei-
verfassungsrichterwahl-noetig.  

Verfassungsrichterwahl 

nötig), 

bei 

German Judges’ Association (2026), input from the German Judges’ Association for the 2026 Rule of 
Law Report.  

German  Judges’  Association  (2026a),  Bottleneck  criminal  justice  (Flaschenhals  Strafjustiz), 
https://www.drb.de/newsroom/presse-mediencenter/nachrichten-auf-einen-
blick/nachricht/news/flaschenhals-strafjustiz.  

German Judges’ Association (2026b), The justice system is falling behind in terms of income (Justiz 
wird  beim  Einkommen  abgehängt),  https://www.drb.de/newsroom/presse-mediencenter/nachrichten-
auf-einen-blick/nachricht/news/justiz-wird-beim-einkommen-abgehaengt.  

nach 

BVerfG-Kriterien 

German  Judges’  Association  (2026c),  Judges’  remuneration  2025  at  Federal  and  Länder  level 
according  Constitutional  Court  criteria  of  17  September  2025  (R-Besoldung  2025  in  Bund  und 
Ländern 
2025), 
https://www.richterbesoldung.de/fileadmin/Richterbesoldung/Dokumente/2025/DRB_Musterberechn
ung_R-Besoldung_2025_Tabelle.pdf.  
GRECO (2019a), 3rd Evaluation, Second Addendum to the Second Compliance Report on Germany, 
https://rm.coe.int/third-evaluation-round-second-addendum-to-the-second-compliance-
report/168094c73a. 
GRECO  (2019b),  5th  Evaluation  Round  -  Evaluation  Report  Germany,  https://rm.coe.int/fifth-
evaluation-round-preventing-corruption-and-promoting-integrity-i/1680a0b8d7. 

Sept. 

vom 

17. 

23 

 
 
(2021),  4th  Evaluation  Round  – 

Interim  Compliance  Report  on  Germany, 

GRECO 
https://rm.coe.int/fourth-evaluation-round-corruption-prevention-in-respect-of-members-
of/1680a26425. 
GRECO  (2022),  4th  Evaluation  Round  –  Second  Interim  Compliance  Report  on  Germany, 
https://rm.coe.int/fourth-evaluation-round-corruption-prevention-in-respect-of-members-
of/1680a9173f. 
GRECO  (2023),  5th  Evaluation  Round  –  Compliance  Report  on  Germany,  https://rm.coe.int/fifth-
evaluation-round-preventing-corruption-and-promoting-integrity-i/1680aa89ee. 
GRECO  (2024),  4th  Evaluation  Round  -  Addendum  to  the  Second  Compliance Report  on  Germany, 
https://rm.coe.int/fourth-evaluation-round-prevention-of-corruption-in-respect-of-
members/1680b0d2fd. 

GRECO 
https://rm.coe.int/grecorc5-2025-8-final-eng-2nd-compliance-report-germany-public/488027d7cc. 

(2025),  5th  Evaluation  Round  –  Second  Compliance  Report  on  Germany, 

Institute  for  Economic  Research  (ifo)  (2025),  A  comparison  of  judicial  budgets:  Development, 
structure and  action  required  for  a  resilient  rule  of  law  (Justizhaushalte im  Vergleich:  Entwicklung, 
Struktur 
Rechtsstaat), 
einen 
für 
https://collections.fes.de/publikationen/content/titleinfo/1852081.  

Handlungsbedarfe 

resilienten 

und 

KEF (2026), KEF recommends a significantly smaller increase in the broadcasting fee (KEF empfiehlt 
deutlich geringere Anhebung des Rundfunkbeitrags), https://kef-online.de/presse/detail/kef-empfiehlt-
deutlich-geringere-anhebung-des-rundfunkbeitrags.  

LobbyControl (2024), Traffic Light coalition finally decide on lobbying footprint (Ampel-Regierung 
beschließt 
(6  March  2024),  https://www.lobbycontrol.de/lobby-
fussspur/ampel-regierung-beschliesst-endlich-lobby-fussspur-114234/. 

endlich  Lobby-Fußspur) 

LobbyControl (2025), Lobby influence on the law-making process still not transparent (Lobbyeinfluss 
auf Gesetzgebung noch immer intransparent) (23 October 2025), https://www.lobbycontrol.de/lobby-
fussspur/lobbyeinfluss-auf-gesetzgebung-noch-immer-intransparent-122894/.  

LobbyControl (2025a), Change of sides: The soft fall of Christian Lindner – also due to Springer and 
KKR (Seitenwechsel: Christin Lindners weicher Fall – auch dank Springer und KKR) (14 November 
2025), https://www.lobbycontrol.de/seitenwechsel/lindner-123206/.  

LobbyControl  (2025b),  Current  lobby  footprint  with  almost  no  impact  (Derzeitige  Lobby-Fussspur 
fast wirkungslos) (10 Dezember 2025), https://www.lobbycontrol.de/lobby-fussspur/derzeitige-lobby-
fussspur-fast-wirkungslos-123475/.  

LobbyControl  (2025c),  Policy  paper:  Party  donations,  straw  men  and  Elon  Musk  in  the  election 
campaign  (Policy  Paper:  Parteispenden,  Strohmaenner  und  Elon  Musk  im  Wahlkampf)  (1  August 
2025),  https://www.lobbycontrol.de/parteienfinanzierung/policy-paper-parteispenden-strohmaenner-
und-elon-musk-im-wahlkampf-122016/.  

LobbyControl (2026), Party donations 2025: AfD large-scale donations are exploding (Parteispenden 
2025: 
explodieren), 
https://www.lobbycontrol.de/parteienfinanzierung/parteispenden-2025-afd-grossspenden-explodieren-
123936/.  

AfD-Grossspenden 

LobbyControl/  AbgeordnetenWatch/  Transparency  International  (2025),  Party  financing  –  Open 
Letter: Transparency organisations demand the introduction in the coalition agreement of a ceiling for 
fordern 
party  donations  (Parteienfinanzierung  –  Offener  Brief:  Transparenz-Organisationen 
Parteispendendeckel 
2025), 
Koalitionsvertrag) 
https://www.lobbycontrol.de/parteienfinanzierung/offener-brief-transparenz-organisationen-fordern-
parteispendendeckel-im-koalitionsvertrag-120019/. 

March 

(13 

im 

24 

 
 
Maecenata  Foundation  (2025),  The  anti-NGO  discourse  –  attacks  on  civil  society  in  the  media  and 
public  sphere  (Der  Anti-NGO-Diskurs  –  Angriffe  auf  die  Zivilgesellschaft  in  der  medialen 
Öffentlichkeit), https://www.maecenata.eu/2025/12/02/anti-ngo-diskurs-social-media-analyse/.  

Maecenata  Foundation  (2026),  The  anti-NGO  discourse:  small  questions  –  big  impact?  (Der  Anti-
Wirkung?), 
NGO-Diskurs: 
https://www.ssoar.info/ssoar/bitstream/handle/document/108344/ssoar-2026-buttner_et_al-Der_Anti-
NGO-Diskurs_Kleine_Anfragen_-.pdf?sequence=5&isAllowed=y&lnkname=ssoar-2026-
buttner_et_al-Der_Anti-NGO-Diskurs_Kleine_Anfragen_-.pdf.  

Anfragen 

Kleine 

große 

– 

Media Ownership Monitor, Germany (2026), https://germany.mom-gmr.org/en/.  

Ministry of Finance (2026), Press release: Federal Government adopts action plan against organised 
crime: legal, technical and human resources of the customs and the Federal Office of the Police will 
be strengthened (Bundesregierung beschliesst Aktionsplan gegen Organisierte Kriminalitaet: Zoll und 
Bundeskriminalamt  werden  rechtlich,  technisch  und  personell  gestaerkt)  (25  February  2026), 
https://www.bundesfinanzministerium.de/Content/DE/Pressemitteilungen/Finanzpolitik/2026/02/2026
-02-25-aktionsplan-gegen-ok.html.  

Ministry  of  Finance,  Ministry  of  the  Interior,  Ministry  of  Justice  (2026),  New  Era  for  Internal 
Security:  Refocusing  of  the  fight  against  organised  crime  as  well  as  financial  and  drug  crimes 
(Zeitenwende  der  Inneren  Sicherheit:  Neuasurichtung  der  Bekaempfung  von  Organisierter 
Rauschgiftkriminalitaet), 
Kriminalitaet 
https://www.bundesfinanzministerium.de/Content/DE/Downloads/Zoll/aktionsplan-gegen-
organisierte-kriminalitaet.pdf?__blob=publicationFile&v=9. 

Finanz- 

sowei 

und 

Ministry of Justice (2025), Proposal amending the Criminal Code – Transposition of Directive (EU) 
2024/1203  on  the  protection  of  the  environment  through  criminal  law  (17  October  2025), 
https://www.bmjv.de/SharedDocs/Downloads/DE/Gesetzgebung/RefE/RefE_Umweltstrafrecht.pdf?_
_blob=publicationFile&v=2.  

Ministry  of  Justice 
https://www.bmjv.de/DE/themen/pakt_fuer_den_rechtsstaat/pakt_fuer_den_rechtstaat_ueberblick_no
de.html.  

the  Rule  of  Law 

für  den  Rechtsstaat), 

(2026a),  Pact 

(Pakt 

for 

Ministry  of  Justice  (2026b),  Government  proposal  for  a  seventh  law  amending  the  code  of 
administrative  procedure  and  other  laws  (Gesetzesnetwurf  der  Bundesregeriung  eines  Siebten 
Gesetzes 
anderer  Gesetze), 
https://www.bmjv.de/SharedDocs/Downloads/DE/Gesetzgebung/RegE/RegE_7_VwGOAendG.pdf?_
_blob=publicationFile&v=4.  

Verwaltungsgerichtsordnung 

Änderung 

und 

der 

zur 

Ministry of the Interior (2025a), Integrity in the Federal public administration - Annual Report 2024, 
https://www.bmi.bund.de/SharedDocs/downloads/DE/publikationen/themen/oeffentlicher-
dienst/BMI25073-Integritaetsbericht-2024.pdf?__blob=publicationFile&v=3.  

Ministry  of  the  Interior  (2025b),  Reply  to  the  letter  of  the  Council  of  Europe  Commissioner  for 
Human  Rights  of  6  June  2025,  https://rm.coe.int/reply-of-german-minister-of-interior-to-the-
commisisoner-s-letter/1680b678ee.  

Ministry of the Interior (2026), additional written input for the 2026 Rule of Law Report.  

National  Regulatory  Control  Council  (NKR)  (2026),  Annual  Report  2025  (Jahresbericht  2025), 
https://www.normenkontrollrat.bund.de/Webs/NKR/SharedDocs/Downloads/DE/Jahresberichte/2025-
jahresbericht.pdf?__blob=publicationFile&v=5.  

Oberlandesgericht  Muenchen  (2025),  Press  release:  Criminal  proceeding  against  Eduard  L.  for 
suspicion  of  bribery  of  members  of  Parliament  (Pressemitteilung:  Strafverfahren  gegen  Eduard  L. 
wegen 
2025), 
https://www.justiz.bayern.de/gerichte-und-
behoerden/oberlandesgerichte/muenchen/presse/2025/49.php.  

von  Mandatstraegern) 

der  Bestechung 

des  Verdachts 

July 

(30 

25 

 
 
OCCRP (2025), Organised Crime and Corruption Reporting Project: Former German lawmakers on 
trial over alledged bribes form Azerbaijan (16 January 2025), https://www.occrp.org/en/news/former-
german-lawmakers-on-trial-over-alleged-bribes-from-
azerbaijan#:~:text=Reported%20by,%2DAzerbaijani%20Relations%20(GEFDAB). 

OECD (2021), Working Group on Bribery, Implementing the OECD Anti-Bribery Convention, Phase 
4 - Two Year Follow-Up Report: Germany, https://www.oecd.org/daf/anti-bribery/germany-phase-4-
follow-up-report.pdf. 

(2025a),  Better 

practices 
OECD 
https://www.oecd.org/content/dam/oecd/en/publications/reports/2025/09/better-regulation-practices-
across-the-european-union-2025_a3dfd5e6/6f007516-en.pdf.  

the  European  Union 

regulation 

across 

2025, 

OECD (2025b), OECD Working Group on Bribery, Public Summary Record of the Plenary Meeting 
June  2025,  https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/fighting-
25-27 
foreign-bribery/oecd-working-group-on-bribery-public-summary-record-june-2025.pdf.  

Parliament Administration (2026), input from the Parliament Administration for the 2026 Rule of Law 
Report.  

Presserat 
the 
(2026a),  History 
https://www.presserat.de/pressefreiheit.html.  

of 

Press  Council 

(Geschichte 

des  Presserats), 

Presserat (2026b), 2025: More than 100 reprimands for the first time (2025: Erstmals mehr als 100 
Rügen), https://www.presserat.de/jahresberichte-statistiken.html. 

Reporters  without  Borders  (2026),  input  from  Reporters Without  Borders for the  2026  Rule  of  Law 
Report – Germany.  

Special  Procedures  of  the  UN  Human  Rights  Council  (2025a),  Press  release:  UN  experts  urge 
Germany  to  halt  criminalisation  and  police  violence  against  Palestinian  solidarity  activism, 
https://www.ohchr.org/en/press-releases/2025/10/un-experts-urge-germany-halt-criminalisation-and-
police-violence-against.  

Special Procedures of the UN Human Rights Council (2025b),  Letter to Germany  AL DEU 2/2025, 
https://spcommreports.ohchr.org/TMResultsBase/DownLoadPublicCommunicationFile?gId=30045.  

Transparency  International  (2023),  Statement  on  the  hearing  for  the  Political  Parties  Act 
(Stellungnahme 
Parteiengesetz), 
https://www.bundestag.de/resource/blob/979884/5a65362863a0fb68ccf61995d2f64927/20-4-344.pdf. 

anlässlich 

Anhörung 

zum 

der 

Transparency  International  (2024),  Lobbyranking  2024:  Slow  progress  in  most  of  the  Laender 
(Lobbyranking 
Bundesländern), 
https://www.transparency.de/aktuelles/detail/article/lobbyranking-2024.  

Fortschritte 

Zaghafte 

meisten 

2024: 

den 

in 

Transparency International (2025a), Key demands for more transparency and a strong anti-corruption 
für  mehr  Transparenz  und  eine  starke  Antikorruptionspolitik), 
policy 
https://www.transparency.de/fileadmin/Redaktion/Publikationen/2025/BTW_2025_Kernforderungen_
TI-DE_Erlaeuterungen.pdf. 

(Kernforderungen 

Transparency International (2025b), First conviction for strategic corruption: Transparency Germany 
welcomes  historic  judgement  in  the  Azerbaijan  affaire  (Erste  Verurteilung  wegen  strategischer 
Korruption: Transparency Deutschland begruesst historisches Urteil in der Aserbaidschan-Affaere) , 
30 
https://www.transparency.de/aktuelles/detail/article/erste-verurteilung-wegen-
strategischer-korruption-transparency-deutschland-begruesst-historisches-urteil-in-der-aserbaidschan-
affaere-1.  

2025, 

July 

Transparency  International  (2025c),  Scheinwerfer:  The  magazine  against  corruption  (Scheinwerfer: 
Das 
2025), 
(December 
https://www.transparency.de/fileadmin/Redaktion/Publikationen/2025/Scheinwerfer-
107_Geldwaesche.pdf.  

Korruption) 

Magazin 

gegen 

26 

 
 
Transparency  International  (2025d),  Alibi-footprint  instead  of  a  real  executive  footprint  (Alibi-
Fussspur 
2025), 
https://www.transparency.de/aktuelles/detail/article/ein-jahr-exekutiver-fussabdruck. 

Fussabdruck) 

exekutivem 

echtem 

June 

statt 

(2 

Transparency International (2026), input from Transparency International Germany for the 2026 Rule 
of Law Report.  

UN  Special  Rapporteur  for  freedom  of  opinion  and  expression  (2025),  Preliminary  observations, 
https://www.ohchr.org/sites/default/files/statements/20260206-eom-stm-europe-central-asia-region-
sr-protection-right-en.pdf.  

UNODC  (2020),  United  Nations  Convention  against  Corruption  -  Country  Review  Report  of 
Germany 
2016-2021, 
https://www.unodc.org/documents/treaties/UNCAC/CountryVisitFinalReports/2020_11_06_Germany
_Final_Country_Report.pdf.  

Review 

Cycle 

the 

for 

VAUNET (2026), input from VAUNET for the 2026 Rule of Law Report.  

ZDF/  AbgeordnetenWatch  (2025),  Revolving  doors  in  the  Federal  Parliament  (Drehtuereffekt  im 
Bundestag)  (15  July  2025),  https://www.zdfheute.de/politik/deutschland/lobbyregister-bundestag-
drehtuereffekt-bekannte-lobbyisten-100.html.  

27 

 
 
 
Annex II: Country visit to Germany 

The Commission services held virtual meetings in March and April 2026 with: 

•  Abgeordnetenwatch  
•  Allianz Rechtssicherheit 
•  ARD 
•  Association of Private Media (VAUNET) 
•  Bündnis Bürgerschaftliches Engagement 
•  Committee for EU Affairs of the Conference of the Justice Ministers 
•  Court of Audit [in writing] 
•  Federal Administrative Court [in writing]  
•  Federal Bar 
•  Federal Constitutional Court 
•  Federal Criminal Police Office 
•  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 Newspaper Publishers and Digitalpublishers Association 
•  Gesellschaft für Freiheitsrechte 
•  Joint Office of the Media Authorities and Media Authorities of the Länder 
•  Lobbycontrol Germany 
•  Media Association of the Free Press 
•  Ministry of Education, Family Affairs, Senior Citizens, Women and Youth  
•  Ministry of Finance 
•  Ministry of Foreign Affairs  
•  Ministry of Justice 
•  Ministry of State for Culture and Media  
•  Ministry of the Interior 
•  National Regulatory Control Council  
•  Parliament Administration 
•  Press Council 
•  Prosecution Service 
•  Transparency International Germany 
•  ZDF 

* The Commission also met the following organisations in a number of horizontal meetings:  

•  Civil Liberties Union for Europe 
•  Civil Society Europe 
•  End FGM EU 
•  European Civic Forum 
•  European Partnership for Democracy 

28 

 
 
 
•  Human Rights Watch 
• 
ILGA-Europe 
• 
International Federation for Human Rights 
•  Philea - Philanthropy Europe Association 
•  Transparency International EU 

29