Finance Committee Approves Customs Administration Reform

Stand: 11.11.2026

The Finanzausschuss des Deutschen Bundestages (Finance Committee of the German Bundestag) has approved the Federal Government’s draft Act to Promote Greater Justice by Strengthening the Customs Administration and Combating Financial Crime. The deliberations concerned the previously amended version of the Zollfinanzgerechtigkeitsgesetz (Customs Financial Justice Act).

The government draft is set out in Bundestagsdrucksache 21/8282 (German Bundestag Printed Paper 21/8282) dated 30 September 2026. Its first reading in the plenary session of the German Bundestag took place on 9 October 2026. On 2 November 2026, the Finance Committee held a public hearing.

According to the government draft, the Act is scheduled to enter into force on 1 January 2027. The legislative process has not yet been completed following the Finance Committee’s approval.

Restructuring of the Generalzolldirektion

The reform affects the customs administration, which has almost 49,000 employees. It is intended to simplify and digitalise its structures and place a stronger focus on combating money laundering, illegal employment, drug smuggling and organised financial crime.

Two New Functional Divisions

The current six specialist directorates of the Generalzolldirektion (General Customs Directorate) are to be replaced by two functional divisions:

• The “Customs Duties and Taxes” division is to consolidate the corresponding tax- and customs-related functions.

• The “Security and Enforcement” division is to consolidate investigative and enforcement functions.

This is intended to establish closer links between investigative and enforcement units. In future, the customs administration’s management is to consist of three Vice Presidents. The Zollkriminalamt (Customs Investigation Bureau) and the Zentralstelle für Sanktionsdurchsetzung (Central Office for Sanctions Enforcement) are to remain in place and be integrated into the Generalzolldirektion.

Special units for handling complex cases of international money laundering are also planned at local customs authorities. According to the Bundesministerium der Finanzen (Federal Ministry of Finance), the Act implements parts of the Joint Action Plan against Organised Crime of February 2026 and the Action Plan against Tax and Financial Crime of July 2026.

Digital Tools and Sanctions Enforcement

The reform also includes new powers to enforce international sanctions. At the same time, the role of the Financial Intelligence Unit is to be strengthened, including in connection with the financing of the proliferation of weapons of mass destruction.

The proposed tools include the seizure of crypto-assets, the inspection of electronic transport information and the use of artificial intelligence. These measures are intended to enable information to be analysed more quickly and to expand the customs administration’s investigative and inspection capabilities.

The amended version also provides for the customs administration to be granted access to the Ausländerzentralregister (Central Register of Foreign Nationals). This provision was only added to the draft at a later stage of the legislative process.

Administrative Securing of Assets

A key component of the draft is the administrative investigation and securing of assets. Assets of unclear origin with a value exceeding EUR 100,000 are to be subject to confiscation under less stringent conditions where they cannot be linked to a specific criminal offence.

According to the statement issued by the Deutscher Anwaltverein (German Bar Association), an asset is deemed to be of unclear origin if there are reasonable doubts as to its lawful origin. The association criticised the proposed framework as effectively reversing the burden of proof to the detriment of the persons concerned. By contrast, the Deutsche Zoll- und Finanzgewerkschaft (German Customs and Finance Union), which was heard as an expert witness, expressly supported the introduction of the instrument.

Decision by a Panel

The version amended by the Finance Committee provides that the confiscation of assets is not to be decided by a single judge alone. Instead, the decision is to be entrusted to a panel of judges of the Finanzgerichtsbarkeit (German fiscal court judiciary). This is intended to strengthen the protection of fundamental rights within the proceedings.

The provisions are intended to strike a balance between effectively combating organised crime and meeting the rule-of-law requirements governing interference with property rights. Administrative asset securing is aimed in particular at assets whose origin cannot be plausibly explained, even though they cannot be linked to a specific criminal offence.

Further Development of the Customs Reform

The Zollfinanzgerechtigkeitsgesetz forms part of the planned measures to combat money laundering and tax and financial crime. During the hearing, the Deutsche Zoll- und Finanzgewerkschaft also advocated establishing a digital centre within the Generalzolldirektion that would report directly to the authority’s President.

For companies, investors and high-net-worth individuals, the proposed investigative, asset-securing and confiscation powers may be particularly significant in relation to tax-relevant asset structures. MTR Legal advises on matters at the intersection of asset attribution, tax law and administrative proceedings as part of its tax law advisory services.