Based on these findings it was concluded that, overall, Germany is meeting expectations in relation to sorting, preparing and validating the information. It was also noted that there is room for improvement with respect to transposition of fields when preparing files. Germany is therefore encouraged to continue its implementation process accordingly, including in relation to the area highlighted.
Recommendations:
Germany should continue to work with its exchange partners to address the issues raised.
SR 2.5 Jurisdictions should agree and use, with each exchange partner, transmission methods that meet appropriate minimum standards to ensure the confidentiality and integrity of the data throughout the transmission, including its encryption to a minimum secure standard.
Findings:
In order to put in place an agreed transmission method that meets appropriate minimum standards in confidentiality, integrity of the data and encryption for use with each of its exchange partners, Germany linked to the CTS and the CCN, which is used for exchanges within the EU.
Based on these findings it was concluded that Germany is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Germany is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.6 Jurisdictions should carry out all exchanges annually within nine months of the end of the calendar year to which the information relates.
Findings:
Two exchange partners highlighted delays in the sending of information by Germany (representing 3% of its partners). It was noted that only one of these related to the most recent year of exchange and for both partners Germany successfully addressed the issues and sent the information as soon as possible thereafter.
Based on these findings it was concluded that Germany is fully meeting expectations in relation to exchanging the information in a timely manner. Germany is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.
Findings:
Feedback from Germany’s exchange partners did not raise any concerns with respect to Germany’s use of the agreed transmission methods and therefore with Germany’s implementation of this requirement.
Based on these findings it was concluded that Germany is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Germany is therefore encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.8 Jurisdictions should have the systems in place to receive information and, once it has been received, should send a status message to the sending jurisdictions in accordance with the CRS Status Message XML Schema and the related User Guide.
Findings:
Feedback from Germany’s exchange partners did not raise any concerns with respect to Germany’s receipt of the information and therefore with Germany’s implementation of these requirements.
Based on these findings it was concluded that Germany is fully meeting expectations in relation to the receipt of the information. Germany is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.9 Jurisdictions should respond to a notification from an exchange partner as referred to in Section 4 of the Model CAA (which may include Status Messages) in accordance with the timelines set out in the Commentary to Section 4 of the Model CAA. In all other cases, jurisdictions should send corrected, amended or additional information received from a Reporting Financial Institution as soon as possible after it has been received.
Findings:
Germany has responded to notifications in a timely manner and no such concerns have been raised by Germany’s exchange partners and therefore with respect to Germany’s implementation of these requirements.
Based on these findings it was concluded that Germany is fully meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Germany is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.