OnwynA UK presence is not a filing. It is a second regulatory regime.
The day a German company opens a UK branch or subsidiary, a second body of obligations attaches to it — company law, direct and indirect tax, employment, 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. What follows is the map we maintain, the deadlines it carries, and how an engagement actually runs.
Newer to this? The Germany → UK after Brexit overview covers what a UK presence actually changes, the dated 2026–27 deadlines, and a German-language summary.
Two tests, and most advisers assess one
Whether you have a UK presence is decided twice, by two different regimes, using two different tests that do not reference each other. A company can pass one and fail the other, and the failure is usually the expensive one, because it is the one nobody asked about.
The Companies House “UK establishment”
Turns on what is registered — whether the company has 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 are negotiating or concluding 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.
Why we print both rows even when both are negative
The two tests are asked as two separate questions in scoping, and neither answer is allowed to populate the other. Your register shows both results side by side — including when the answer to both is “no obligation arises.” The absence is the reassurance, and it only means something if the questions were genuinely asked apart. A register that quietly inferred one from the other would look identical and be worth nothing.
The deadlines that catch people are the ones nothing prompts
Small and mid-sized 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. Every obligation in your register is classified into one of three clocks, and the third is the one this line exists for.
One-time
Fires once, on establishment, and is usually short-fused.
- OS IN01 — UK establishment registration, within 1 month
- ECCTA identity verification — per director and per PSC
- Berufsgenossenschaft Unternehmeranzeige — within one week
- Art. 27 representative — appointment on each side as applicable
- DPO appointment — plus the separate notification to the LfDI
- UK REACH Only Representative, LUCID, producer registrations
Recurring
Fires on a fixed cycle, and each cycle has its own window.
- CS01 confirmation statement — annual, 14-day window
- OS AA01 — accounts for the establishment
- Register of Overseas Entities — annual update even with no changes
- VAT returns — both sides, on their own cycles
- FPS every payday · P11D by 6 July
- Auto-enrolment re-declaration — every three years
Event-driven
Fires when something happens. Nothing reminds you. This is where the money is lost.
- New director → identity verification before appointment
- Employee starts → s.1 written statement on day one
- Any cross-border assignment → A1 certificate before departure
- Posting over 14 days → £5m employers’ liability cover — with no UK entity at all
- 20+ redundancies in 90 days → HR1 before consultation opens
- Dismissal → §623 BGB written notice, wet signature
No general-purpose calendar tool models this
A date can be put in a calendar. An event trigger cannot, because the calendar does not know you hired someone. Handling the third column is the work that a maintained register does and a spreadsheet does not — and it is the reason this is delivered as a programme with a named owner per obligation rather than as a document you download once.
The five register domains, and the regimes inside them
The register is organised into five domains. Which of them open for you — and how much of each — falls out of your structure during scoping, not out of a plan 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
XB-Establish · the largest domainStanding up a presence and moving people, on both sides. Includes the direct tax that follows from presence — corporation tax registration, permanent-establishment attribution, Gewerbesteuer, transfer pricing, withholding — because it is triggered by the same scoping answers as the presence itself, and separating them is what makes the two-tests problem invisible.
- 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
XB-Trade · collapses to ~25% if you move no goodsMoving goods and money: customs identity and the right to declare, preferential origin under the TCA and the supplier’s-declaration burden sitting behind it, special procedures and guarantees, VAT on both sides including Making Tax Digital and mandatory B2B e-invoicing, and the border systems.
- 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
XB-Goods · GB · EU · Northern IrelandWhether a physical product may lawfully be placed on the GB, German or Northern Ireland market, and what paperwork must exist and be retained: marking route, technical file and declaration-of-conformity duplication, conformity-assessment bodies, German-language duties, and the producer-responsibility registrations that are a condition of selling rather than a property of the product.
- UKCA / CE marking routes
- Technical file & DoC duplication
- Approved & notified bodies
- Machinery changeover (20 Jan 2027)
- 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
XB-Digital · deliberately not a duplicateOnwyn already ships full programmes for GDPR, NIS2, DORA, the EU CRA and the EU AI Act. This domain carries only what exists because you are in two places at once: the representative on each side, UK/EU divergence after the DUAA, the registrations and notifications no security standard covers, and the multi-clock incident-reporting problem when two regulators want the same breach on different deadlines.
- 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
XB-Sector · applies to few, changes the answer for thoseAn overlay rather than a domain of its own. It applies to almost nobody — and where it does apply, it changes the answer the other four domains already gave. That is why it cannot be built or sold first, and why sector clients are scoped before anything is quoted.
- Medical devices
- Chemicals
- Automotive
- Financial services (bridging to DORA)
Standards and frameworks you may already hold — ISO 27001, ISO 9001, and the rest of the 33-standard catalog — are not repeated here. Evidence you have already collected for them is reused through the same crosswalk that runs everywhere else in Onwyn, rather than recollected for the expansion.
How an engagement actually runs
Five stages, in order. Most companies stop after stage two the first time, deliberately — it is the cheapest way to find out whether the picture we produce is worth what we charge for it before committing to the programme.
Exposure check
Twelve closed questions. The answer you get back is the number of obligation families your structure triggers and the next three dated deadlines — not the register itself. Enough to know whether this is a two-filing problem or a programme.
Free · minutesScoping and the register
The full intake, then the register itself: every obligation that attaches to your structure, each with a named owner on your side, a date, the clock it runs on, and the artifact that closes it. Named, dated and versioned — “generated 14 Sep 2026 from pack XB-Establish v3.2” — because a register nobody can date is a register nobody can rely on. Ships with the generated forms, appointment letters and notification drafts.
Weeks · fixed feeExpansion readiness — the project
Where the months go. Evidence and document assembly, the filings sequenced against each other in the order the deadlines actually permit, chasing on your behalf, and a structured handoff at every boundary where the work stops being ours — to your lawyer, your Steuerberater, your customs broker. Run to a named go-live date by a delivery team and one contracted cross-border specialist.
Months · fixed fee, never hourlyGo-live
The register closes out: every one-time obligation evidenced, every recurring one scheduled with its owner, every event trigger armed against the events that would fire it.
The date the programme was run toKept true, afterwards
A register that was right in March and silent since is worse than no register, because it is trusted. When a threshold, a fee or a filing deadline moves, your register is re-issued with a dated note of exactly what changed — and the event triggers keep firing as your company changes shape. This is the only part of the engagement that is a subscription, and it exists because the register has to stay true after the project ends.
Ongoing · monthly, separately invoicedFixed fees, scoped after the questions — never hourly
Every figure below is a range because the scope genuinely varies, and the range narrows to a single fixed number once scoping is done. What it never becomes is a day rate.
Expansion readiness — the programme to go-live
€12,000 – €24,000
Scoping, the register, evidence and document assembly, the sequenced plan, the chasing, and a structured handoff at each labelled boundary. One fixed fee for the project, agreed before it starts.
Exposure check
Twelve questions, a count of the obligation families you trigger, and your next three dated deadlines.
Register — single stream
One domain, fully scoped and evidenced. Usually company registration or data protection, and usually where a first engagement starts.
Register — full expansion
Every domain your structure opens, with the generated forms, appointment letters, notification drafts and handoff packs.
Keeping it true — after the programme
The maintained register: the multi-clock calendar, the event triggers, and re-issue with dated change notes when a rule moves. Follows a completed register; it is not a way to buy one. Separate engine, separate invoice, and you can end it without touching your compliance programme.
Third-party costs are yours and are never marked up by us: the partner Kanzlei and Steuerberatungsgesellschaft contract with you directly, as do a customs broker and any immigration adviser your expansion needs. We name them on your engagement letter before you sign it.
What we do, and what goes to a lawyer
Onwyn is not a law firm and does not give legal advice. We maintain the register, run the schedule, assemble the evidence and prepare the documents. We do not tell you what the law requires of you, and no part of this page should be read that way.
Where a question needs a lawyer — the structure decision itself, a contract, anything that turns on your specific facts — it goes to the German partner firm we work with, named on your engagement, and you contract them directly. The same boundary applies on tax: obligations are listed and dated in your register, and advising on them is your Steuerberater’s work, not ours.
We would rather say this on the website than in the second meeting
Roughly half of what a cross-border expansion needs is routing rather than doing — getting the right question to the right regulated professional, early, with the facts already assembled. Being clear about which half is which is not a limitation we are disclosing reluctantly. It is most of what makes the register worth having.
Where this line stands, honestly
The research is done — six main reports, thirteen sub-stream briefs and a verification pass that found and corrected real errors in our own earlier drafts. The register content is in build, domain by domain, registrations first. 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 to market at volume.
What that means for you: we are working with a small number of early clients, scoping is a conversation rather than a checkout, and we will tell you plainly if your expansion needs something we cannot yet stand behind.
If you are planning this
Tell us the shape — branch or subsidiary, staff or none, goods or services, personal data or none — and we will come back with which domains open for you and what an early engagement would look like. Which expansions people are actually planning is also how we decide which registers to build next.