Module 95 goes digital: KBA-compliant XML export

Report without undue delay – there's no fixed deadline

Every recognized training center reports its participants' continuing education to the Federal Motor Transport Authority (KBA) in an automated procedure and without undue delay (Section 19 BKrFQG), i.e. without culpable delay. The law doesn't say how many days that is. It's more specific about fines: anyone who doesn't transmit data, or transmits it incorrectly, incompletely or late, commits an administrative offense – up to 5,000 euros (Section 28 BKrFQG).

Section 14 no. 4 BKrFQG lists what goes into the report:

• Training center: name and address, competent recognition and supervisory authority, file number of the recognition notice
• Participants: birth and family name, first names, date and place of birth, academic degree, sex
• Instruction: period and type of instruction, actual attendance time per type of instruction
• Content: knowledge sub-areas covered according to Annex 1 of the BKrFQV
• Proof: serial number of the current driver qualification card (FQN), if one has already been issued

The driver's address is not part of it.

Since August 2026, the type of instruction counts

Since February 6, 2026, instruction can take place digitally, synchronously (live) or asynchronously, but only in the form named in the recognition notice (Section 9 (3) BKrFQG). According to the explanatory memorandum, at most 12 of the 35 lessons may be digital.

To make this verifiable, since August 2, 2026 the training center reports the attendance time by type of instruction (Section 14 no. 4 (c) in conjunction with Section 30 (10) BKrFQG). The instruction itself can cost more than a reporting error: without the matching recognition, for example digital in an unapproved form, it can cost up to 20,000 euros (Section 28 BKrFQG).

No API to the KBA, just its web app

Reports go into the KBA's web app free of charge (via kba-online.de, section “Ausbildungsstätten”, i.e. training centers), with the ELSTER organization certificate and individually by form or as an XML file. Per the KBA's FAQ, there's no web service for transmitting directly from your own software.

The XML file must be valid against the KBA's XSD schema, which is only available in the web app. Otherwise the web app returns error code 001806 (“XML nicht schemavalide”, i.e. XML not schema-valid). You'd rather hear that from your own machine first, say with xmllint --schema against the downloaded schema.

The KBA processes the file with a delay; a result file then names faulty records, which are corrected and resubmitted. If the training center doesn't correct incorrect data within the set deadline, the competent state authority cancels it (Section 18 (3) BKrFQG).

In BKF Manager, the file comes from confirmed attendance

We build the file in BKF Manager from data that's generated anyway, with no retyping. On the day, the driver shows a QR code in the app, scanned by webcam or app camera; anyone without a smartphone is confirmed in the participant list. After the last day, anyone neither checked in nor confirmed counts as absent, no matter how full the classroom was.

Only confirmed days go into the report, along with the authority data and the location's file number. The knowledge areas follow from the license classes in the profile: goods transport for C, CE, C1 and C1E, passenger transport for D, D1, DE and D1E.

What we take away

The last step stays manual. Without a web service, all automation ends at the download. So “without undue delay” also means someone has to remember it.

Form and content are two separate checks. Schema-valid only means the form is right. If a license class or another mandatory field is missing, BKF Manager says so in plain language before the export. How the app reads the FQN by camera is covered in the FQN scanner guide.