The latest reform of the German Tax Advisory Act (Steuerberatungsgesetz, StBerG), adopted in June 2026, fundamentally reshapes third-party investment in the German tax advisory market, tightening existing rules by extending professional eligibility requirements beyond direct shareholders to the entire ownership chain, thus introducing a full “look‑through” system.
Any direct or indirect change in ownership must now be reported immediately, enabling regulators to detect and challenge non‑compliant structures more effectively. The rules take effect upon promulgation, without a transition period or explicit grandfathering protection. This creates substantial uncertainty for existing investor structures, which may face increased scrutiny, operational constraints, or even revocation proceedings.
While the reform restricts traditional private‑equity-backed tax advisory platforms, it does not eliminate investment opportunities altogether. Instead, it shifts structuring strategies toward German audit firm (WPG) models, which remain subject to a more flexible regulatory regime.
