Germany requires two named expertises on a public-interest entity's audit committee
Following the FISG reforms, AktG § 100(5) requires the audit committee of a public-interest entity to include at least one member with accounting expertise and at least one with auditing expertise.
1 January 2022
The Financial Market Integrity Strengthening Act sharpened the composition requirement for audit committees at public-interest entities. It is no longer sufficient for the supervisory board collectively to be financially literate: the committee must contain one member with expertise in accounting and, separately, one with expertise in auditing.
This sits within a two-tier structure that already constrains composition. The supervisory board of a listed, parity co-determined company must be at least 30% women and at least 30% men under AktG § 96(2), and an election that breaches that requirement is invalid. Employee representatives occupy half the seats above 2,000 employees and one-third above 500.
AktG § 100(2) also caps an individual at ten supervisory board seats in listed companies, with chairmanships counting double.
What it means for a cross-border candidate
This is one of the few genuinely portable, checkable credentials in European governance. 'Expertise in auditing' points at a specific population — former audit partners, chief audit executives, audit-committee chairs from other jurisdictions — and a German supervisory board that lacks it has a named gap it must fill. If that is your background, the gap is legible from the outside, which very few board vacancies are.
This paragraph is the Global ID Exchange’s own reading, not a statement by any authority named above. Everything in the body of this item is a matter of record; this is judgement.
Sources
- Aktiengesetz § 100(2), § 100(5), § 96(2)
- Finanzmarktintegritätsstärkungsgesetz (FISG)
Rules change and transitional provisions frequently apply. Verify against the primary instrument before you rely on any provision described here.
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