After Next AI Act Phase: Transparency Gaps at Germany’s Largest Companies
How do German companies disclose their rules for the use of artificial intelligence? In our latest study, we analyzed 48 companies from three groups—DAX-40, online retailers, and credit reporting agencies—using a 10-point criteria list for publicly documented AI governance. The assessment did not evaluate how well companies actually use AI, but rather focused exclusively on how transparently they publicly communicate their AI governance policies. The result: 11 of the 48 companies examined do not publicly disclose their AI governance policies at all. On average, the companies examined scored 4.2 out of a possible 10 points.
Online retailers communicate most openly, credit bureaus the least
With an average score of 4.6 points, the online retailers surveyed perform best in the group comparison, closely followed by the DAX-40 companies with 4.4 points. Credit bureaus bring up the rear with an average of 1.3 points: of the three credit bureaus examined, Schufa Holding AG and Creditreform Boniversum GmbH show no publicly findable AI governance documentation whatsoever; only CRIF Bürgel GmbH achieves a solid mid-range value with 4 points. Among online retailers, Amazon leads with 9 points, followed by eBay with 8 and Otto with 6 points. About You and MediaMarktSaturn, on the other hand, score 0 points.
Tech and telecom sectors lead, logistics scores zero transparency points
On average, Technology & Software (8.7) and Telecommunications (8) perform best, though for telecommunications only one company (Deutsche Telekom) is included in the ranking. These are followed by Healthcare (5.7 points, 3 companies), Finance & Insurance (5.3 points, 6 companies), and Industry & Mechanical Engineering (4.8 points, 5 companies). At the lower end are Consumer Goods & Retail (0.3 points, 4 companies) and Logistics & Transport, where the only company examined (Deutsche Post DHL) scores zero transparency points. At the company level, Infineon and SAP share the top spot with 10 out of 10 possible points each. They are followed by Allianz, Bayer, Commerzbank, GEA Group, and Amazon, each with 9 points. In total, 11 of the 48 companies surveyed – including Adidas, Beiersdorf, Brenntag, Deutsche Post DHL, Hochtief, Symrise, as well as Zalando, About You, MediaMarktSaturn, Schufa Holding AG, and Creditreform Boniversum GmbH – score 0 points.
Human oversight often emphasised, right to appeal rarely so
Looking at the individual criteria: more than half of the companies (30 of 48) publicly state that a human retains final control over AI decisions. 26 companies have publicly accessible AI guidelines and explicitly address discrimination. Concrete processes are described far less often: only 18 companies detail their AI governance structure in depth, and only eleven publicly differentiate between different AI risk levels. The biggest gap is in the complaint and review process: only three of the 48 companies publicly explain how affected individuals can appeal or have automated decisions reviewed.
“What stands out is how differently the topic of AI governance is communicated among German companies: from a dedicated AI principles page to a complete absence of any public information,” comments Dr. Farshad Badie, Dean of the Faculty of Computer Science and Data Processing at the BSBI School of Business and Innovation. “It’s hardly surprising that the tech industry, on average, communicates most transparently. What’s more striking is the gap in the complaint and review process, which runs through almost all sectors. While many companies emphasize that humans retain control, it usually remains unclear to customers and employees how they can actually challenge an automated decision. Given the phased implementation of the EU AI Act, this is exactly where companies should sharpen their approach.”
– Dr. Farshad Badie, Dean of the Faculty of Computer Science and Data Processing at the BSBI School of Business and Innovation
About the study
The study examined 48 companies from three groups: 40 DAX-40 companies, five online shops (Amazon, eBay, Otto, About You, MediaMarktSaturn), and three credit agencies (Schufa Holding AG, CRIF Bürgel GmbH, Creditreform Boniversum GmbH). The basis was exclusively publicly accessible communication on official company websites (including blogs, news, and trade articles), with no external sources or third-party press releases. Based on ten criteria (1 point for “yes,” 0 points for “no”), an overall score of 0 to 10 was calculated for each company. For the industry comparison within the DAX-40, an average score per industry was calculated; since the number of companies per industry ranges from one (telecommunications, logistics & transport) to six (finance & insurance, chemicals & pharmaceuticals), the values for smaller industries should be interpreted with corresponding caution. General explanatory or use-case content (e.g., descriptions of where AI is used within the company) was only counted if it specifically related to the company’s own governance or implementation; mere statements of intent or general references to the EU AI Act without reference to the company’s own compliance did not count. Only public documentation was assessed, not the actual internal implementation of AI within the company. Survey period: August