Germany restores FATCA nil-report processing and flags protocol changes

Nil reports can be processed again

The BZSt says it has fixed the defect that prevented nil reports submitted through the BZSt online portal form from being processed. Some earlier submissions were not processed and therefore were not forwarded to the US Internal Revenue Service. The affected senders were contacted separately; an institution that still wants both authorities to receive the nil report should submit it again. Paragraph 120 of the Finance Ministry's 1 February 2017 application guidance confirms the legal position: where there is no reportable data, a nil report is not required, although it may be filed voluntarily. The newsletter adds that an out-of-period nil report has no legal consequences for the institution.^[1][3]

Two acknowledgements must be tracked

For a FATCA delivery that is accepted wholly or partly, the BZSt sends both a processing protocol and, after onward transmission, the US acknowledgement for the financial institution (UEFI). The office reports intermittent problems delivering processing protocols. A sender that has not received one within a week should contact the FATCA team with its transaction or data-transfer identifier. Portal status may remain 'In Bearbeitung' even after the processing protocol arrives; it becomes final only when the UEFI has been received. Institutions should therefore reconcile the protocol, UEFI and portal status instead of treating the intermediate label as evidence that the filing failed.^[1]

A protocol-schema change is expected in December

The BZSt made a wording-only clarification to the ftc:AcctHolderType dataset description, expressly saying it produces no substantive change. More significantly for reporting systems, it expects the FATCA processing-protocol schema to change in early or mid-December 2026 and says customer-side adjustments may be necessary. Updated sample XML files are already available on its feedback-and-protocols page, but the newsletter does not set a definitive go-live date. Reporting teams should test parsers against those samples while continuing to monitor the BZSt for the final schema and activation date.^[1]

The underlying FATCA-USA Implementing Regulation still requires German reporting financial institutions to send the section 8 account data electronically to the BZSt by 31 July following the reporting year. Non-filing, incorrect, incomplete, improperly formatted or late transmission can constitute an administrative offence under section 11. The newsletter changes the reporting channel's operation, not those statutory duties.^[2][4]