From 1 January 2027, German employers reporting company data must use the new electronic dialogue procedure operated by the Bundesagentur für Arbeit (the German Federal Employment Agency). It replaces the existing company data maintenance record, known as DSBD. This affects virtually all businesses with employees, even if payroll is handled by a tax consultancy or an external service provider.
What will change in company data management from 2027?
In future, reports and responses will be exchanged directly between the employer or its payroll office and the Bundesagentur für Arbeit. The current transmission route through a health insurance fund will no longer apply.
According to the Deutsche Rentenversicherung (German statutory pension insurance), the company data management dialogue procedure will begin on 1 January 2027 and replace the existing DSBD. The Bundesagentur für Arbeit will accept and process old DSBD reports only until 31 December 2026.
The main change is the direct response channel. The Bundesagentur für Arbeit can send confirmation that the data has been saved, correct information or ask the business to review specific data. These messages will be sent electronically to the payroll software or form completion software being used.
This creates a genuine dialogue. A business will not only send data, but will also need to retrieve, review and, where necessary, act on incoming responses. This requires a defined process, even if company data has rarely changed in the past.
Who must report company data from 2027?
The procedure applies to employers with a Betriebsnummer (company identification number) whenever reportable company data changes or the Bundesagentur für Arbeit requests a review. The obligation remains with the employer, even if a tax consultancy handles the technical submission.
The relevant information includes, in particular:
- Name and address of the business
- Place of employment
- Contact persons and contact details
- Business status, such as permanent closure
- The business’s industry classification
The five-digit industry subclass will become a mandatory field under the new procedure. According to IKK classic, 839 industry subclasses are currently available for classification.
This information should not be selected based on guesswork. What matters is the business’s actual primary economic activity. A company operating in several fields should therefore check which area represents its main activity and whether the classification currently on record is still correct.
What deadlines and fines apply?
Changes to company data must still be reported with the next payroll run, but no later than six weeks after the change. This deadline applies regardless of whether payroll is handled internally or externally.
The Deutsche Rentenversicherung specifies the next payroll run as the reporting date and sets a final deadline of six weeks after the change. This applies, for example, to a move, a change of business address or the permanent closure of a place of business.
According to the Bundesagentur für Arbeit, anyone who fails to report a change of address or the permanent closure of a business risks a fine of up to 5,000 euros. Not every incorrect detail automatically results in a fine. However, incomplete or outdated data can lead to queries, requests for review and additional work.
What should companies prepare during 2026?
Companies should review their master data, industry classification, software and responsibilities before the end of the year. It is advisable to carry out a brief test of the entire process, from receiving notification of a change to handling the electronic response.
- Check payroll software: Ask the manufacturer or service provider which software version will support the company data management dialogue procedure. Also clarify whether an update needs to be installed or a contract amended.
- Compare master data: Compare the company name, address, place of employment and contact persons with the documents currently in use. Any differences between the payroll software, financial accounting system and internal records should be resolved before 2027.
- Check the industry subclass: Review the five-digit classification based on the company’s actual primary activity. If there is any uncertainty, it may be helpful to contact the Betriebsnummern-Service (company identification number service) at the Bundesagentur für Arbeit.
- Assign responsibility for incoming messages: Decide who will retrieve electronic confirmations, corrections and requests for review. Arranging cover for holidays and illness will prevent messages from being left unattended.
- Involve the tax consultancy: Obtain written confirmation of who will submit reports, who will review responses and who will approve any necessary corrections. Organisational responsibility should not be left unresolved between the business and the consultancy.
The Bundesagentur für Arbeit publishes the technical specifications on its page covering the requirements for the dialogue procedure. These documents are aimed primarily at providers of payroll and form completion software. Businesses should therefore first obtain a binding statement from their software provider.
If master data is still maintained across several Excel files, paper folders or separate software systems, the change is a useful opportunity to organise the process. Digitalising recurring administrative processes can help establish a single source of data and clearly defined processing steps.
How should the business and tax consultancy divide the work?
The business should specify who identifies changes and passes them on to the payroll office. The tax consultancy or internal payroll team should document who submits the report and who handles incoming responses.
A simple process might work as follows: Management reports a change to a designated person. That person checks the master data and informs the payroll office. Once the data has been transmitted, the confirmation that it has been saved is checked and filed in the personnel records.
It is important to schedule a separate review of outstanding requests. Checking the payroll system once a month may not be sufficient if messages are only considered during a payroll run. The appropriate frequency depends on the software used and the process agreed with the tax consultancy.
Businesses that are unsure how to bring together their software, responsibilities and existing data can begin by setting out the process in a short plan. Strategic advice on sequencing and practical implementation can help without introducing a new system prematurely.
ibx company advises small and medium-sized businesses in Hannover and the surrounding region. During a no-obligation initial consultation on preparing for new digital processes, you can clarify which steps your business actually needs to take.