OnwynBrexit did not stop German companies expanding to the UK. It changed what they carry when they do.
The day a German company registers a UK branch or incorporates a UK subsidiary, a second body of obligations attaches to it — company law, direct and indirect tax, payroll and pensions, data protection, product conformity, customs. Most of it is knowable in advance. Almost none of it is written down in one place, in German, for a company of your shape.
Onwyn maintains that map: the register of obligations a company of your structure carries, each one named, dated and put on the clock it actually runs on. We are opening this line to a small number of German companies planning a UK move, and taking expressions of interest now.
What a UK presence actually costs a German company now
Not the political version of post-Brexit UK market entry. The operational one: six things attach the moment you have a UK presence, and they attach on six independent clocks, kept by six different authorities, none of which will tell you about the other five.
Company law
A registrable UK presence must be registered at Companies House — within a month — and then kept filed: confirmation statements and accounts for the establishment. Directors and people with significant control run through identity verification under ECCTA. Hold UK land as well and the Register of Overseas Entities opens on top, with its own annual update that falls due even when nothing has changed.
Tax, twice
UK corporation tax registration and permanent-establishment attribution on one side; Gewerbesteuer, transfer pricing and withholding on the other. Plus VAT on both, on separate cycles, with Making Tax Digital in the UK and mandatory B2B e-invoicing in Germany.
People
PAYE and an FPS submission every payday, pension auto-enrolment and its three-yearly re-declaration, a s.1 written statement on day one of employment, right-to-work checks, and employers’ liability cover. A1 certificates before anyone is posted — including for postings that create no UK entity at all.
Data and cyber
UK GDPR and EU GDPR have been diverging since the UK Data (Use and Access) Act. A representative may be needed on one side or both, ICO registration is its own duty, transfers need a mechanism, and a single incident can owe two regulators a report on two different clocks.
Goods
Great Britain runs a recognition regime rather than a fully parallel one, so for most product categories the marking burden itself is modest. What sits underneath it is not: economic-operator duties, labelling and language, the technical file and declaration of conformity, ten-year retention, and producer registrations that are a condition of selling.
Customs
EORI identity on both sides, who may declare and in whose name, preferential origin under the Trade and Cooperation Agreement and the supplier’s-declaration paperwork sitting behind it, special procedures, guarantees, and the border systems on each side.
The one finding that changes how this is scoped
Whether you have a UK presence is decided twice, by two regimes, using two tests that do not reference each other. Because they are independent, the answer to one is never evidence about the other — and it is the unasked one that tends to be expensive.
The Companies House “UK establishment”
Turns on what is registered — a physical presence in the UK that must be registered as an establishment, with the filings, identity verification and annual returns that follow from registering it.
The tax “permanent establishment”
Turns on what is actually happening — whether people negotiate or conclude contracts in the UK on your behalf. An agent with no office and no registration can create one. So can a salesperson with a laptop.
A company can trigger one and not the other, and the costly case is the one nobody asked about. In an Onwyn register the two are asked as two separate questions and printed as two separate rows — including when both answers are “no obligation arises.” The absence is the reassurance, and it only means something if the questions were genuinely asked apart.
The 2026–27 deadline stack, for a company with a foot on both sides
These are the dated, cross-border obligations landing on German companies right now. Not all of them will open for you — which ones do falls out of your structure. They are listed here because they are checkable against your own calendar today, without talking to anybody.
| Date | What happens |
|---|---|
| 6 Mar 2026 passed | German NIS2 registration was statutorily due. The BSI’s own published count was 15,477 registrations as at 2 April 2026, on estimates of the in-scope population that leave a large number of entities still unregistered. There is no general transition period, the BSI can register a defaulting entity itself, and the regime carries a €500,000 standalone fine alongside personal liability for management. Manufacturing sub-sectors catch ordinary Mittelstand companies at 50 employees, or where turnover and balance-sheet total are each above €10m. |
| 2 Aug 2026 passed | EU AI Act Article 50 transparency duties. Not deferred by the Digital Omnibus — Regulation (EU) 2026/1744 moved other dates, and left this one where it was. |
| 11 Sep 2026 | EU Cyber Resilience Act 24-hour vulnerability reporting begins — and it reaches products already in the field, not only new ones. |
| 18 Nov 2026 | The ECCTA identity-verification transition closes for existing UK directors. Verification has been mandatory for new appointments since 18 November 2025; this is the date the grandfathering ends for people already on the register. |
| 9 Dec 2026 | The new Product Liability Directive applies — software is a product under it. |
| 30 Dec 2026 | EUDR applies to large and medium operators. |
| 1 Jan 2027 | UK CBAM starts. It is a tax and the importer is liable — which makes the Incoterm on your UK contracts a decision to take during 2026, not a detail to discover in 2027. |
| 20 Jan 2027 | The EU Machinery Regulation applies. A draft affirmative statutory instrument before Parliament would have Great Britain recognise conformity with it from the same date — one technical file rather than two. It is still a draft, so we track it and state it as a draft; we do not assert the outcome either way. What is certain is that there is a changeover to plan for. |
The deadlines that catch people are the ones nothing prompts
Companies rarely miss the annual filings. They miss the obligations that fire on an event — a hire, a posting, a new director, a redundancy round — because no calendar knows the event happened. A new director needs identity verification before appointment. A cross-border assignment needs the A1 certificate before departure. Twenty or more redundancies at one establishment within ninety days need form HR1 before consultation opens. Every obligation in an Onwyn register is classified as one-time, recurring or event-driven, and the third column is why this is a maintained register with a named owner per obligation rather than a document you download once.
What the register covers
Five domains. Which of them open for you — and how much of each — falls out of your structure during scoping, not out of a package you pick in advance. A services company that moves no goods sees roughly a quarter of the trade domain; a manufacturer selling into Great Britain, Germany and Northern Ireland sees all of it three times over.
Establishment and people
- Companies House registration
- ECCTA identity verification
- Register of Overseas Entities
- UK corporation tax
- Permanent-establishment attribution
- Transfer pricing
- Gewerbesteuer
- PAYE & FPS
- Auto-enrolment
- Employers’ liability cover
- s.1 statements
- Right to work
- A1 & social security
- Immigration & sponsorship routing
- Berufsgenossenschaft
Trade, customs and indirect tax
- EORI & customs identity
- TCA preferential origin
- Supplier’s declarations
- Special procedures & guarantees
- UK VAT & MTD
- German VAT & B2B e-invoicing
- ENS / ICS2
- BTOM
- EU CBAM
- UK CBAM
- EUDR
- Export controls & sanctions
Goods and conformity
- UKCA / CE marking routes
- Technical file & DoC duplication
- Approved & notified bodies
- Machinery changeover
- GB type approval
- Northern Ireland dual regime
- Substance restriction
- ESPR
- Construction products
- stiftung ear
- LUCID
- UK WEEE
- pEPR
Data, cyber and AI — the cross-border delta only
- UK GDPR / DUAA divergence
- Art. 27 & UK representative
- International transfer mechanisms
- ICO registration & fee
- BSI NIS2 portal registration
- Dual incident-reporting clocks
- Cross-border AI-system duties
Regulated-sector overlay
- Medical devices
- Chemicals
- Automotive
- Financial services
Standards you may already hold — ISO 27001, ISO 9001 and the rest of the Onwyn standards catalog — are not repeated here; evidence you already collected is reused rather than recollected. The full breakdown of every domain, the three clocks and how an engagement runs is on the cross-border DE→UK service page.
Tell us the shape of your expansion
Branch or subsidiary. Staff or none. Goods or services. Personal data or none. Four answers is enough for us to send back the domain map for a company of that shape, and what an early engagement would look like — and which expansions people are actually planning is how we decide which registers to build next.
- The obligation domains that open for a company of that shape, in writing — not a sales call.
- A named person to talk to when your expansion moves from planning to a date.
- The dated deadline briefing above, kept current, if you want it by email.
- No obligation, no charge, and nothing is filed or committed on your behalf.
We would rather say this here than in the second meeting: Onwyn is not a law firm. Where your expansion needs a lawyer or a Steuerberater, we route it to the partner firm named on your engagement and you contract them directly.
Expression of interest
Germany → UK expansion. Two required fields; the rest sharpens the answer you get back.
Germany to UK, asked and answered
General information about how the two regimes work, not advice about your company. Which of it applies to you is a question of fact about your structure, and that is what scoping establishes.
Does a German company need a UK entity to sell into the United Kingdom after Brexit?
Not necessarily. Selling into Great Britain from Germany can be done with no UK registration at all, and many companies do exactly that. What creates registration and filing duties is presence and activity — a place of business that must be registered at Companies House, or people concluding contracts in the UK on your behalf, which is a different test again. Which of those is true of your company is a question of fact about your structure, and it is the first thing scoping establishes.
What is the difference between a UK establishment and a permanent establishment?
They are two different tests applied by two different regimes that do not reference each other. The Companies House “UK establishment” test turns on registrable physical presence. The tax “permanent establishment” test turns on what is actually happening — whether people negotiate or conclude contracts in the UK for you. A company can trigger one and not the other, which is why a register prints them as two rows and never lets one answer populate the other.
Do we still need CE marking for Great Britain, or UKCA?
Great Britain operates a recognition regime rather than a fully parallel one, so for most product categories the marking burden itself is far smaller than a fully parallel regime would have imposed. What did not go away: economic-operator duties, labelling and language requirements, the technical file and declaration of conformity, and long retention periods. Northern Ireland is a separate answer again under the Windsor Framework, and machinery has a changeover in January 2027 that is worth planning for now.
Does a German company need a UK GDPR representative?
A representative requirement can attach on either side of the border depending on where you are established and whose personal data you process. It is a one-time appointment with an ongoing consequence, and it sits alongside ICO registration and the transfer mechanism between two regimes that have been diverging since the UK Data (Use and Access) Act. Onwyn carries these as the cross-border delta only — the full GDPR programme is a separate Onwyn service, and we do not sell you the same thing twice.
Do we need an EORI number, and do we need two?
Moving goods across the border needs customs identity on the side you are declaring on, and companies moving goods both ways generally end up holding identity on both. The harder question underneath it is not the number but the representation: who declares, in whose name, and who carries the liability if the declaration is wrong. Under the Union Customs Code, a party that fails to declare its representation type is treated as acting in its own name — which makes it the declarant and the customs debtor. Onwyn does not file anything; that is your broker’s work, and we route it.
How long does a Germany to UK expansion take?
Months rather than weeks, and the critical path is rarely the incorporation. Some registration deadlines run very short — a UK establishment registration falls due within one month — but the real constraint is sequencing: several obligations can only be discharged in a particular order, and some fire on events rather than dates. A programme run to a named go-live date handles that. A checklist does not.
What does it cost?
Fixed fees, scoped after the questions, never a day rate — and the ranges are published on the cross-border service page rather than hidden behind a call. Third-party costs are yours and are never marked up by us: the partner law firm, the tax firm, a customs broker and any immigration adviser contract with you directly, and are named on your engagement letter before you sign it.
Is Onwyn a law firm?
No, and this matters enough that we put it on the page rather than in the second meeting. Onwyn does not give legal or tax advice. We maintain the register, run the schedule, assemble the evidence and prepare the documents. Anything that turns on your specific facts — the structure decision itself, a contract, a tax position — goes to the German partner law firm or Steuerberatungsgesellschaft named on your engagement, whom you contract directly. Roughly half of a cross-border expansion is routing the right question to the right regulated professional, early, with the facts already assembled. Being clear about which half is which is most of what makes the register worth having.
Expansion nach Großbritannien — kurz zusammengefasst
Wer als deutsches Unternehmen eine Zweigniederlassung anmeldet oder eine Limited in Großbritannien gründet, unterliegt ab dem ersten Tag einem zweiten Regelwerk: Gesellschaftsrecht, Steuern, Lohnabrechnung und Renten, Datenschutz, Produktkonformität und Zoll. Das meiste davon ist im Voraus bekannt. An einer Stelle zusammengeschrieben ist es fast nie.
Zweigniederlassung oder Limited gründen — was Onwyn macht
Wir führen das Pflichtenregister: eine gepflegte, datierte Übersicht der Pflichten, die ein Unternehmen Ihrer Struktur tatsächlich trifft — je Pflicht mit verantwortlicher Person, Frist und der Angabe, ob sie einmalig, wiederkehrend oder ereignisgesteuert ist. Die dritte Kategorie ist die teure: Sie wird durch eine Einstellung, eine Entsendung oder eine Geschäftsführerbestellung ausgelöst, und kein Kalender weiß, dass das passiert ist.
Was Onwyn nicht macht
- Keine Rechtsberatung. Onwyn ist keine Kanzlei. Alles, was eine rechtliche Bewertung Ihres Einzelfalls erfordert — die Strukturentscheidung selbst, Verträge, alles Fallbezogene — geht an die Partnerkanzlei, die Sie direkt mandatieren.
- Keine Steuerberatung. Steuerliche Pflichten werden aufgeführt und mit Fristen versehen. Beraten wird dazu von Ihrer Steuerberatungsgesellschaft, nicht von uns.
- Wir reichen nichts ein. Anmeldungen und Zollanmeldungen erfolgen durch Sie oder Ihren beauftragten Vertreter, unter eigenen Zugangsdaten.
Warum jetzt
Vier der oben genannten Fristen liegen innerhalb der nächsten Monate, und mehrere davon begründen eine persönliche Verantwortlichkeit der Geschäftsführung. Das Argument ist ausdrücklich nicht „kaufen Sie das, sonst drohen 500.000 Euro“. Es lautet: ein datiertes Register kostet weniger als ein Tag, an dem die Exposition der Geschäftsführung undokumentiert ist.
Honestly, this line is early — and that is why we are asking first
The research behind this page is done: six main reports, thirteen sub-stream briefs and an independent verification pass that re-checked fourteen load-bearing claims against primary sources only, and found and corrected real errors in our own earlier drafts. The register content is in build, domain by domain, registrations first.
What is not finished: the partner Kanzlei arrangement and the professional-indemnity cover for UK-law work are being finalised, and until both are closed we are not taking this line to market at volume. That is the reason this page asks for your interest rather than selling you something.
What it means for you in practice — we are working with a small number of early companies, scoping is a conversation rather than a checkout, you are quoted a fixed fee before anything starts, and we will tell you plainly if your expansion needs something we cannot yet stand behind.
The one thing worth doing today, even if you never talk to us
Take the deadline table above and check the four dates that fall in the next six months against your own calendar. If your company has people, goods or data crossing the border, at least one of them is probably yours — and finding that out costs nothing.