Publication of financial reports: Federal Office of Justice imposes disciplinary fine on pferdewetten.de AG
Executive Summary
The Federal Office of Justice (BfJ) imposed a €50,000 disciplinary fine on pferdewetten.de AG on 7 November 2025 for violations related to the publication of financial reports under the German Securities Trading Act (WpHG). This enforcement action underscores BaFin's and BfJ's strict oversight of timely and accurate financial disclosures by public companies, serving as a warning to listed firms on the consequences of non-compliance. It matters because it highlights procedural lapses in ad-hoc publicity and annual reporting, potentially increasing scrutiny on similar entities amid ongoing regulatory emphasis on market integrity. #
What Changed
This is not a regulatory change or new requirement but an enforcement decision enforcing existing obligations under § 37w WpHG (disciplinary measures for breaches of publication duties) and related provisions of the WpHG. Key requirements reiterated include: - Timely publication of annual financial reports and ad-hoc announcements via electronic means (e.g., DGAP platform). - Ensuring completeness and accuracy of published financial statements, including management reports. - Immediate correction of any publication errors or delays to prevent market misinformation. No new rules were introduced; the fine reinforces pre-existing standards without amendments. (Source: Primary publication at https://www.bafin.de/SharedDocs/Veroeffentlichungen/EN/Massnahmen/40c_neu_124_WpHG/neu/meldung_2026_01
What You Need To Do
- Conduct an internal audit of recent financial report publications (last 12-24 months) for timeliness, accuracy, and platform compliance (e
- Implement or enhance pre-publication checklists, including dual approvals and automated validation tools to flag delays or errors
- Train IR and compliance staff on WpHG §§ 15, 111-114 (ad-hoc and periodic reporting) and § 37w (sanctions)
- Review outsourcing arrangements for reporting (e
- Document remedial actions and report to the supervisory board; consider voluntary self-disclosure for any identified breaches to mitigate fines
Key Dates
Compliance Impact
Urgency: Medium. This matters as a concrete example of BfJ's willingness to levy fines (here €50,000, modest but precedential) for reporting lapses, signaling heightened enforcement post-2025 ESMA-aligned updates to transparency rules. Firms with similar profiles face elevated audit risk, especially with BaFin's 2026 focus on digital reporting resilience; non-compliance could escalate to higher pe
Who is Affected
Summary
On 07 November 2025, the Federal Office of Justice (Bundesamt für Justiz - BfJ) imposed a disciplinary fine amounting to 50.000 euros on pferdewetten.de AG.