Just a few days ago, companies received an unsolicited email, which has now received a continuation.

The transparency register rip-off – the most important thing to start with:

  1. A club sent threatening emails demanding payment
  2. In the new email there is a half-hearted apology for this
  3. Companies can still register themselves in the transparency register free of charge

Many companies received an email from an organization called “Transparenzregister eV”, which seemed rather threatening in the subject of the email ( we reported ). The email already had the subject “ Request for payment in violation of the Money Laundering Act ”, and the email itself urged you to register within 10 days, otherwise you could face high fines.

However, you did not register on the transparency register page (where registration is free), but rather with the association, which, according to its own information, takes care of the registration for the company and charges an annual fee of 49 euros.

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A new email with a correction

A new email has now been sent to the companies, which attempts to explain the first email and admits “administrative errors”:

The new email from “Transparenzregister eV”
The new email from “Transparenzregister eV”

In the email, the association adopts a more conciliatory tone and now calls itself by its name: “Organization Transparency Register eViG ”. According to this, the association is an interest group that would like to “inform and support” affected people in registering them in the transparency register.

Below we would like to reproduce the most important paragraphs of the email.

“On January 21/22, 2020, you were sent an email asking you to register in the transparency register. This is also possible via our association’s link, among other things.”

It should be noted that the first email never mentions the direct link to the Transparency Register , where you for free The new email also only says that registration is possible “among others” via the association’s link.

“The annual membership fee for the service charged by the association, including registration fees, amounts to 49.00 euros. According to our knowledge, your tax advisor will also take care of this entry. The costs are between 90.00 and 150.00 euros.”

The implication here is that the annual membership fee of 49 euros is still cheaper than if the tax advisor does it for you. However, it was never mentioned in the first email that it was a membership fee, and you don't necessarily need a tax advisor for the registration.

“Unfortunately, we made an administrative error when sending the email you are familiar with, as the Organization Transparency Register eViG was not explicitly stated and it was therefore not clear that our association is in the founding phase.”

The fact whether a club already exists or is just in the founding phase is irrelevant to the matter, since the letter was sent either way in the name of the club, which can also be seen in the header of the first email.

“At this point we would like to point out that an association that is currently being founded is legally allowed to act in the same way as, for example, a GmbH iG and therefore any suspicions expressed are unfounded.”

This is correct in that an association is legally allowed to take action right from the start-up phase. What an association is not allowed to do, however, is send threatening-looking emails that give the impression that they come from an official authority and pressure companies to register with the association using a time pressure of 10 days.

Looking at the first email, one can say that it is clear, at least in the header, that it is from an association, not an authority. However, the overall character of the first email, including the red font and bold type, shows that the letter is less like an offer and more like a threat.

The reactions of many users to the email show us that the association caused great uncertainty, which probably meant that an unknown number of companies willingly paid the sum.

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Conclusion

The second email has no red font or bold type, instead it explains soberly what exactly the club does, but at the same time it also makes a half-hearted attempt to explain the first email.

Since the first email is in principle an unsolicited advertisement for which the companies did not give their express consent, it is also a violation of Section 7 (2) No. 3 UWG (Unfair Competition Act).

Companies are now free to register directly in the transparency register , hire a tax advisor or register with an association that is currently being founded for 49 euros per year.

To the previous article: Rip-off with transparency register


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