At the same time, Federal Finance Minister Lars Klingbeil announced at the end of April 2026 that he would abolish the impunity-exempt self-disclosure pursuant to § 371 AO in the case of larger amounts of evasion – the “golden bridge to tax compliance” should only have a mitigating effect, not an impunity-exempt effect, above threshold values still to be defined. For entrepreneurs with unexplained tax burdens, this constellation means that the window for effective self-disclosure is closing. In this article, we explain the concrete consequences of ZeFin NRW, the penal framework that threatens according to the case law of the Federal Court of Justice (BGH), what the planned self-disclosure reform means for practice and why an effective self-disclosure can still be an important step in 2026.

1. Introduction: Increased pressure of persecution in NRW

In addition, there is a federal policy development that is of considerable importance for consulting practice: Federal Finance Minister Lars Klingbeil presented an action plan against tax crime at the end of April 2026. The core of the plan is the restriction of the possibility enshrined in § 371 AO to achieve impunity by a complete and timely self-disclosure. Above the thresholds still to be defined, the self-declaration should in future only have a mitigating effect, not a dissuasive effect.

For entrepreneurs with unexplained tax liabilities – for example from incompletely declared foreign accounts, VAT errors, mistreated crypto profits or liquidity withdrawals from the GmbH – this results in a very concrete recommendation for action: Anyone considering self-disclosure should do so in 2026. Because the preparation of an effective self-disclosure takes several months, according to experience.

2.1. Tasks and responsibility

The Central Office shall independently prosecute single cases of economic and financial crime. These include in particular: