Publication of financial reports: Federal Office of Justice imposes disciplinary fine on TTL Beteiligungs- und Grundbesitz-AG
Executive Summary
The Federal Office of Justice (BfJ) imposed a €50,000 disciplinary fine on TTL Beteiligungs- und Grundbesitz-AG on 7 November 2025 for failing to publish required financial reports, highlighting enforcement of financial reporting obligations under German securities law (WpHG). This case underscores BaFin's and BfJ's commitment to market transparency and integrity, serving as a warning to listed companies on the consequences of non-compliance with ad-hoc and periodic reporting duties. Compliance professionals should note it as evidence of intensified scrutiny on reporting accuracy amid BaFin's 2026-2029 strategic priorities. #
What Changed
No new regulatory changes are introduced; this is an enforcement action enforcing existing requirements under the German Securities Trading Act (WpHG § 124), which mandates timely publication of financial reports for publicly listed companies. The case reaffirms the disciplinary framework where BfJ, as the competent authority, can impose fines up to €700,000 (or 5% of turnover) for violations, with this €50,000 fine reflecting a proportionate measure for the breach. It aligns with BaFin's strategic emphasis on "risk-based financial reporting enforcement for publicly traded companies" as outlined in its 2026-2029 objectives. #
What You Need To Do
- Conduct immediate gap analysis of financial reporting processes to ensure compliance with WpHG §§ 37c, 115, and 124 on publication of annual, half-yearly, and ad-hoc reports via electronic means (e
- Implement automated monitoring and reminders for reporting deadlines, with dual sign-off by compliance and finance teams
- Train management on personal liability for reporting failures, including documentation of internal controls to demonstrate due diligence in supervisory reviews
- For firms with similar profiles, voluntarily self-report past lapses to BfJ/BaFin to potentially mitigate fines, referencing this case as precedent
Key Dates
Compliance Impact
Urgency: Medium - This fine, while modest, signals BfJ's active enforcement role in financial reporting, amplified by BaFin's 2026-2029 strategy prioritizing "market transparency and integrity" through increased monitoring of publicly traded companies. It matters because reporting breaches erode investor trust and can escalate to larger penalties or trading suspensions; firms should prioritize pro
Who is Affected
Summary
On 7 November 2025, the Federal Office of Justice (Bundesamt für Justiz - BfJ) imposed a disciplinary fine amounting to 50,000 euros on TTL Beteiligungs- und Grundbesitz-AG