Who Audits Public Companies – Germany

Posted by Jessica McKeon - Aug 31, 2020

This analysis was originally posted by Audit Analytics.

Note: This post has been updated to reflect auditor changes not previously included in this analysis, specifically relating to the DAX 30.

There are 12 accounting firms that audit Germany’s top 160 companies. Perhaps coming as no surprise, the Big Four account for 91% of the top company market, with KPMG leading as the auditor of 51 companies, followed by PwC with 46, then EY and Deloitte with 31 and 17, respectively. BDO, with six, and Ebner Stolz, with three, capture the next 6% of the market. Six other firms audit one company each.

Similar to our coverage of SEC market share, we’ll take a look at the 2019 auditor market concentration across Europe, starting with Germany. For this analysis, we looked at the top three indexes trading on XETRA in Germany – DAX 30, MDAX 60, and SDAX 70, totaling 160 companies. 

  • DAX 30, with a combined market cap of €13 billion, is composed of the 30 largest companies on the Frankfurt Stock Exchange traded on XETRA;
  • MDAX 60 is the mid-cap index that includes 60 weighted stocks – excluding technology – with a market cap of €28 billion; and
  • SDAX 70 contains the next 70 largest companies and has a market cap of €12 billion.
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DAX 30

The DAX 30 is audited exclusively by the Big Four with KPMG leading in 2019 at 50% and Deloitte at the bottom with 3%. Audit Analytics has recorded a number of upcoming auditor changes for the 2020 and 2021 fiscal years for DAX 30 companies. As a result of the changes, KPMG will lose four clients, EY will gain 3, and PwC will gain one. Deloitte will continue to audit just one of the top blue-chip companies.


The Big Four rank in the same way in the MDAX as in the DAX, but the spread among the Big Four is wider, most notably with PwC and EY having larger slices relative to KPMG. Deloitte audited just seven companies on the mid-cap index in 2019. There is also the significant addition of BDO, who audits one MDAX company, Software AG. According to our auditor changes database, PwC will lose four clients in 2020, which will be picked up by other Big 4 firms.


PwC managed to top KPMG in market share among the next 70 companies on the index, grabbing 20 companies, or 29%. They are closely followed by KPMG, with 17 companies, and EY and Deloitte with ten and nine companies, respectively. BDO audited five, Ebner Stolz audited three, and the remaining six companies were audited by six different firms each with one a-piece.

By 2023, we expect over 40 of these companies to need to tender or change auditor. We will be watching to see whether the top indexes in Germany experience anything like the audit market in the UK, where BDO is the first mid-tier firm to penetrate another top-heavy audit market.

Germany implemented EU Audit Reform for Public Interest Entites (PIEs) following Directive 2014/56/EU and Regulation (EU) 537/2014 of the European Parliament which applied from June 2016. While member states were allowed to interpret certain articles in their own way, Germany adopted the reform almost in whole as it was written.

These changes included mandatory audit firm rotation after 10 years maximum with an option to extend an additional 10 years if a tender takes place, and 14 years if a joint audit is used. One additional provision Germany added is that credit institutions and insurance companies have no option to extend auditor tenure after 10 years.

Like many other member states, Germany added their own rules surrounding provision of non-audit services, such that ALL tax and valuation services are permissible – adding legislation that ensures “aggressive tax planning services” will not be allowed.

Germany implemented all other EU regulations, including the Expanded Audit Report that includes Key Audit Matters and evaluation of management’s use of the going concern basis of accounting.

For more information about Audit Analytics or this analysis, please contact us.

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