Signature Circular Translation for Germany

Beneficial ownership and the KYC context

When an account is opened or a business relationship formed in Germany, the other side wants to establish not only the authorised signatory but also the company’s beneficial owner (wirtschaftlich Berechtigter), under know-your-customer (KYC) principles; that information rests largely on the transparency register (Transparenzregister). Within this picture the signature circular is read as the document showing authority to represent, and in translation the signatory’s name and title are carried across clearly enough for a bank or notary to run that check.

It matters in this context that the details in the circular do not contradict the company’s other corporate documents; beneficial ownership is usually read from the articles of association and the shareholding structure, and is assessed alongside the names of the authorised persons in the circular. The translation carries the trade name across as it stands and shows plainly whether authority is sole or joint; generalising a limit on that authority can mean the document is asked for again during the KYC review.

The document set: the circular never travels alone

A signature circular usually goes abroad not on its own but together with the company’s other corporate documents; the German recipient reads the structure of representation alongside the articles of association (Gesellschaftsvertrag/Satzung) and the activity and registry records. The trade name, the capital figure and the names of the authorised persons are expected to agree across all of them. A trade name written differently in one document weakens the impression that the whole file belongs to the same company, which is why the set is translated as a whole, with one consistent set of terms.

In the German company forms (GmbH, AG) authority to represent follows the structure of the company’s organs; the authority of a managing director (Geschäftsführer) or a board member may be sole or joint according to what is entered in the register. Since the title and authority shown in a Turkish circular will be read as the counterpart of that structure, the title is carried across as it stands and the form of authority, sole or joint, is shown plainly. The document is not characterised as a German organ resolution; it is conveyed under its own identity and explained where necessary.

The most easily overlooked aspect of a circular is how current it is; once a company’s management or its form of representation changes, the old circular ceases to be valid and a new one is drawn up. If an out-of-date circular is put before the German side, the recipient may ask for a current document, so it is best to work with a circular dated close to the transaction. The date of issue, the notary’s details and the notarial register number are kept exactly as they are in the translation, because these are what show which state of the representation structure the circular reflects.

Handelsregisterauszug and Vertretungsberechtigung

The German side usually reads who is authorised to represent a company from the commercial register extract (Handelsregisterauszug) and from the statement of authority to represent (Vertretungsberechtigung) set out in it. The translation of a Turkish signature circular sits within that logic: the signatory’s name, title and form of representation have to answer what the German recipient will be looking for as Vertretungsberechtigung. The translation does not characterise the Turkish document as a Handelsregisterauszug; the document is conveyed under its own identity and explained in brackets where necessary.

Prokura and the form of representation

In German company law Prokura is a particular form of authority to represent, entered in the commercial register, and it may be sole or joint. The words “münferiden” and “müştereken” in a Turkish circular mark the distinction the German side will read as Einzel- or Gesamtvertretung, and it must not be lost in translation. A simplification such as “is authorised” can make a limited authority look unlimited. A trade name is an identity; it is carried across as it stands and is not translated.

The layer of approval and currency

Because a signature circular is a notarial document, its apostille is obtained not from the governor’s office but from the relevant judicial justice commission. A translation submitted to an official body in Germany must bear the stamp of a sworn translator (beeidigter Übersetzer). When the management or the authorised persons change, the old circular ceases to be valid; use a document dated close to the transaction.

• Do not leave the sole/joint distinction unclear.
• Do not translate the trade name and so damage the identity of the document.
• Obtain the apostille for a notarial document from the judicial justice commission.

Germany is a party to the Hague Apostille Convention; confirm the current position from the official HCCH list. You can run your file through our single office in Ankara Kızılay, see the cost on our pricing page, and upload your document to request a quotation. This page is for general information and is not a substitute for legal advice; consult your accountant or lawyer on questions of authority to represent.