MiKaDiv 2027: The countdown is on – are you ready?

What is MiKaDiv?

MiKaDiv is a standardised digital reporting procedure to the German Federal Central Tax Office (Bundeszentralamt für Steuern – BZSt) based on Sections 45b and 45c of the German Income Tax Act (Einkommensteuergesetz – EStG).

Unlike traditional tax forms, MiKaDiv constitutes a data- and process-driven compliance regime: data is passed on, validated and aggregated across several stages along the entire custody chain before being reported. MiKaDiv therefore has a significant impact on existing systems, data flows and operational processes.

Who is affected by the MiKaDiv reporting obligations?

The MiKaDiv reporting obligations apply irrespective of an institution’s place of residence or registered office. The decisive factor is whether German dividends form part of the custody chain.

In particular, the following parties are affected:

• German and foreign banks and custodian institutions
• intermediaries and custodians
• investors and corporate groups
• Asset Managers with German equity portfolios
• As a result, the new requirements affect large segments of the financial services industry.

Which data must be reported under MiKaDiv?

MiKaDiv introduces comprehensive requirements for structured data reporting. These include in particular:

• investor and beneficial owner data (German tax identification number for economic activity, where applicable LEI/EUID, tax residence)
• identification of the custody chain across all stages
• dividend and securities data
• transaction and settlement data
• financial arrangements such as repos or securities lending or derivative hedgings

New in 2026: From concept to implementation

Since spring 2026, MiKaDiv has become significantly more concrete. Institutions should keep the following developments in view:

• Communication manual as a living document: several updates with a new logic for additional data fields and adjusted return codes.
• Submission via DIP in the BZSt online portal: the new bulk data interface replaces the previous procedure.
• Following a delay on the part of the BZSt, the testing phase is expected to start on 7 October 2026: the customer test environment enables test filings and XSD validation – the available time window is tight.

MiKaDiv is not an IT project – it is an operating model

Implementation goes far beyond traditional tax or reporting processes. It requires coordinated interaction between Tax, IT, Operations and Compliance. In addition to technical tax analysis, institutions must be technically capable of generating structured reports, validating data and monitoring processes end to end. As the authorities may review every link in the chain, continuous audit and liability pressure arises throughout the process.

A precursor to FASTER: laying the groundwork for tomorrow today

MiKaDiv is regarded in the market as a precursor to the EU FASTER Directive, which will apply from 2030. Institutions that implement the requirements in a structured manner today will also create the basis for the forthcoming European harmonization of withholding tax relief. A jointly designed data model helps avoid duplication of effort.

Why act now?

The new reporting obligations will apply for the first time to investment income accruing after 31 December 2026. Institutions that only start in 2027 will not be able to establish the required operational setup in time. Without timely MiKaDiv-compliant reporting, delays in withholding tax relief, cash lock-up and increased administrative effort may arise – with direct implications for investors.

Financial institutions should therefore assess their exposure at an early stage, identify data requirements, review existing processes, define a target picture for the future operating model and start implementing structured reporting processes.

How we can support you

Grant Thornton Germany supports banks, asset managers and custodian institutions from impact assessment and target operating model design through to operational implementation. Together with our IT partner RAQUEST, we also offer “MiKaDiv as a Service” for foreign financial institutions – digitally, legally compliant and efficiently.