GRECO ¦ Report on Germany’s Progress in Anti-Corruption Measures Regarding the Central Government and Law Enforcement

Germany’s Integrity Reform – Progress and gaps in preventing corruption at the top and in police forces

The Group of States against Corruption (GRECO) published its Second Compliance Report assessing Germany’s progress on 14 recommendations from the Fifth Evaluation Round, which focuses on preventing corruption and promoting integrity in central government top executive functions and in law enforcement agencies. The compliance review covers measures taken since GRECO’s original evaluation in 2020 and the first compliance review in 2022. The German authorities submitted a Situation Report in September 2024; GRECO adopted its Second Compliance Report in March 2025 and made it public in August 2025. The report finds meaningful reforms in some areas – notably lobbying transparency, codes of conduct in police agencies and whistleblower protection – but identifies persistent gaps in oversight of political executives, financial disclosure, proactive police monitoring and recruitment screening.

Strengthened transparency on legislative influence – the executive footprint and an expanded lobbying register

One of the most tangible advances is the introduction of an executive footprint in the Joint Rules of Procedure of the Federal Ministries, effective from 1 June 2024. Ministries must now indicate in draft bills’ explanatory memoranda the extent to which representatives of special interests and third-party contractors contributed significantly to draft legislation, including substantive inputs received before formal consultations. GRECO accepted this mechanism as meeting its recommendation to identify, document and disclose substantive external inputs to legislative proposals and their origin.

Complementing the executive footprint, the Lobbying Register Act was tightened and expanded with effect from 1 March 2024. Key changes include lowering the registration threshold to 30 contacts within three months, extending covered contacts down to head of division level, and enhancing disclosure obligations. Lobbyists must now specify which legislative or regulatory projects their activities relate to, publish basic opinions and reports in the register, disclose principal funding sources and membership fees, and record significant gifts. The register also requires former government officials who lobby to disclose past offices and relevant government activities, enabling better scrutiny of revolving-door risks. GRECO welcomed these reforms while noting that direct disclosure by officials of their meetings with lobbyists remains limited – an outstanding transparency issue.

Post-employment rules for senior civil servants – longer cooling-off and clearer reporting

Germany tightened the post-employment framework for former political officials and security-sensitive civil servants through amendments to section 105 of the Act on Federal Civil Servants, effective 1 April 2024. The amendment requires advance notification of new employment for two targeted groups – retired political officials (including state secretaries and directors general) and those who had security clearances prior to retirement – and extends reporting obligations to five years for retirement after regular pensionable age and seven years in other termination cases. All retirees must report new occupations one month in advance; employers may prohibit commencement of the activity for up to the notification period where necessary. The Federal Ministry of the Interior and Community published a circular guiding uniform application. GRECO regarded these measures as important progress toward consistent decisions on authorized post-public service occupations but noted that enforcement mechanisms for cooling-off rules, the composition of advisory bodies and possible extension of the cooling-off period for ministers and parliamentary state secretaries still need further consideration.

Bastian Schwind-Wagner _Follow

"Germany has taken concrete steps to increase transparency around lobbying and strengthen protections for whistleblowers, and tailored codes of conduct for federal police services have been introduced. These measures improve the institutional framework to detect and deter corruption within government and law enforcement.

However, significant gaps remain: there is no dedicated monitoring mechanism for top executives’ integrity, ad hoc conflict disclosure and public financial declarations are still missing, and the Federal Police lacks routine, repeated screening and proactive internal oversight. Closing these gaps is essential to translate reform momentum into durable prevention of corruption and financial crime."

Integrity guidance and enforcement for political executives – guidance exists, monitoring does not

Germany has produced a guidance manual for members of the Federal Government and parliamentary state secretaries, alongside an Anti-Corruption Directive and a code of conduct. GRECO accepted these instruments as meeting the recommendation to adopt a specific code of conduct and complementary guidance for top executive functions. However, the compliance report underlines a persistent weakness – the absence of a dedicated monitoring mechanism for top executives’ compliance with integrity standards. Supervision of staff integrity remains primarily the responsibility of supervisors and political accountability to Parliament, and ministers can be dismissed under political processes. GRECO stresses that these arrangements fall short of a formal, targeted monitoring and enforcement mechanism for adherence to the guidance manual and code of conduct for persons exercising top executive functions.

Conflicts of interest and ad hoc disclosure – partial progress, ad hoc rules still lacking

GRECO requested clear provisions and guidance for ministers and parliamentary state secretaries on prevention and management of conflicts of interest and an unequivocal requirement for ad hoc disclosure when private interests collide with official duties. While Germany points to various legal and non-legislative disclosure requirements and the guidance manual, the Second Compliance Report finds that the manual lacks an unequivocal ad hoc disclosure obligation and practical tools such as real-life examples. No new measures were reported in the 2024 Situation Report. GRECO concluded that the recommendation remains partly implemented and reiterated the need for explicit, operationalised ad hoc disclosure rules for top executives.

Financial declaration of assets for top executives – still missing

GRECO recommended that persons with top executive functions be required to declare financial interests publicly at regular intervals, and to consider including spouses’ and dependent family members’ financial information (the latter not necessarily public). No tangible progress was reported. Existing restrictions on paid outside employment for ministers – rooted in the Federal Ministers Act and the Basic Law – do not substitute for systematic, public financial disclosure. GRECO therefore maintains that this recommendation remains not implemented.

Police integrity – tailored codes of conduct and whistleblower protection score well

GRECO welcomed two important advances in law enforcement integrity. The Federal Criminal Police Office adopted a tailored code of conduct in March 2022; the Federal Police followed with its tailored corruption prevention code of conduct, which came into force on 14 February 2023. The Federal Police code addresses gifts, disclosure of internal information, social media use, training and contact points for corruption prevention. It has been disseminated across the force, provided to recruits, and is being integrated into training and planned e-learning modules. GRECO considers the tailored codes and the disciplinary framework for enforcement as satisfactorily implemented.

Another major achievement is the enactment of the Whistleblower Protection Act, which entered into force on 2 July 2023. The law implements the EU Whistleblower Protection Directive and extends protection beyond the Directive’s minimum in several respects. It protects all persons who report breaches in connection with their professional activity, including civil servants and police staff, covers criminal offences including corruption, provides internal and external reporting channels and contains protections against reprisals with a reversal of the burden of proof for the whistleblower. GRECO regards the strengthened whistleblower protection for the Federal Criminal Police Office and the Federal Police as satisfactorily implemented.

Shortfalls in internal oversight, proactive monitoring and recruitment screening in the Federal Police

GRECO identified persistent shortcomings in three areas within the Federal Police.

First, the body called for stronger, pro-active internal oversight and comprehensive monitoring capacities. The German authorities reiterated that intrusive surveillance without reasonable suspicion is not consistent with the Federal Police’s leadership vision and that supervision is primarily the supervisors’ responsibility. While leadership guidance is being revised to reaffirm integrity and role-model behaviour, GRECO found no significant progress toward the recommended pro-active oversight posture.

Second, recruitment and background screening remain inadequate for corruption prevention. A draft restructuring of the Federal Police Act includes a provision for a one-off “simple” security check for recruits aimed at detecting extremist links. GRECO observes that the draft was not yet adopted at the time of the report, and in any case the proposed check targets extremist risks rather than corruption vulnerabilities. The recommendation called for more systematic screening upon recruitment and repeated screening at regular intervals throughout officers’ careers – measures that have not been implemented.

Third, although the federal Annual Integrity Report publishes aggregated corruption cases and disciplinary statistics by ministry, GRECO noted that data specific to the Federal Criminal Police Office and the Federal Police are not routinely published and often require parliamentary questions to obtain. GRECO encourages more proactive, regular publication of complaints, actions taken and sanctions, preserving anonymity where required.

Publication and accountability – mixed results

GRECO’s overall conclusion was that out of the 14 recommendations, four have been implemented satisfactorily (recommendations iv – executive footprint, ix – police codes of conduct, x – unspecified in the summary but counted among positive outcomes, and xiii – whistleblower protection), six have been partly implemented (including the code for top executives’ ethics without targeted monitoring, lobbying transparency measures without official meeting logs, post-employment improvements, and limited disclosure requirements), and four remain not implemented (notably public financial declarations for top executives, improved freedom of information measures, comprehensive recruitment screening and pro-active police oversight).

Policy implications for financial crime prevention and next steps

The GRECO assessment shows that Germany has made important structural improvements in transparency of external inputs to legislation and in regulating lobbyists, tightened post-employment reporting for senior civil servants, introduced tailored integrity guidance for law enforcement and strengthened whistleblower protection. Those reforms address significant corruption risks that can facilitate undue influence, regulatory capture and concealment of wrongdoing.

Nevertheless, the remaining gaps carry real risks for integrity and financial crime prevention. Without systematic, independent monitoring and enforcement for persons with top executive functions, ad hoc conflict disclosures and regular public financial declarations, potential conflicts of interest can remain hidden behind political or administrative discretion. Absence of repeated, career-long screening in the Federal Police, together with limited proactive oversight, leaves the institution vulnerable to infiltration, corruption and abuse of power. Limited proactive publication of police-specific integrity statistics constrains public scrutiny and weakens policy feedback loops.

To strengthen the overall anti-corruption framework and reduce financial crime vulnerabilities, German authorities should prioritise the following actions:

• Establish a dedicated, independent monitoring mechanism for adherence to integrity standards by persons exercising top executive functions, with clear procedures for review and proportionate sanctions. This should complement political and parliamentary accountability with targeted compliance oversight.
• Introduce unequivocal ad hoc disclosure obligations for top executives, supported by practical guidance and real-life examples to improve detection and management of conflicts of interest, and mandate periodic public financial declarations with calibrated coverage of family interests where necessary to detect hidden conflicts.
• Ensure routine publication of police-specific integrity data – complaints, investigations, outcomes and sanctions – in anonymised form to enhance transparency, enable trend analysis and strengthen public trust.
• Adopt comprehensive screening at recruitment and introduce periodic re-screenings for Federal Police personnel that assess corruption vulnerabilities and not just extremist risks, and operationalise more proactive internal oversight measures that are compatible with fundamental rights and data protection.

GRECO has asked Germany to report back on outstanding recommendations by 31 March 2026. The next reporting round will be an opportunity to demonstrate that the legislative and administrative momentum seen in 2023–2024 translates into concrete mechanisms for monitoring, disclosure and proactive control – elements essential for effective prevention of corruption and financial crime at the highest levels of government and within law enforcement.

Conclusion – reform momentum but significant implementation work remains

Germany’s recent reforms reflect constructive responses to GRECO’s concerns: better visibility of who shaped legislation, stricter transparency for lobbyists, clearer post-employment reporting and stronger protection for whistleblowers. These are important building blocks for reducing corruption risks and countering financial crime. Yet, without independent monitoring of top executives’ integrity, binding ad hoc disclosure and public financial declarations, as well as proactive police oversight and repeated screening of recruits, key vulnerabilities will persist. Delivering those missing elements will determine whether the recent momentum leads to durable, effective prevention of corruption in central government and law enforcement.

Dive deeper

• GRECO ¦ GRECO publishes report on Germany’s progress in anti-corruption measures regarding the central government and law enforcement ¦ Link
• GRECO ¦ GRECO’s Recent Compliance Reports ¦ Link