# BAG: Data subject not entitled to copies of compliance reports under Art. 15 GDPR

- Type: Case Law
- Source: German Federal Labour Court
- Date: 2026-04-16
- Original: https://gdprhub.eu/index.php?title=BAG_-_8_AZR_169/25
- Canonical: https://overview.legal/posts/262249
- Topics: Right of Access, Personal Data, Right of Access Procedures, Right to Restriction, Accuracy, Right to be Forgotten, Controllers, Human Resources, Supervisory Authorities, Processing

## Summary

Facts — A company (the controller) commissioned a law firm to conduct a compliance investigation into alleged misconduct of a manager (the data subject) in August 2023. The investigation resulted in two compliance reports containing the allegations against the data subject, the names of whistleblowers and witnesses, and a summary of the findings of the investigation. The data subject claimed that she had the right to receive copies of the final compliance reports pursuant to Articles 15(1) and 15(3) GDPR. She requested access to these documents in order to verify what statements had been made about her, whether those statements were accurate, and how they had been determined. The controller refused to grant the data subject access to copies of the entire documents – it considered that its interest in maintaining the confidentiality of the compliance reports as trade secrets outweighed the plaintiff’s interest in obtaining information. The court of first instance ordered the controller to provide the data subject a copy of the earlier version of the compliance report. The appellate court dismissed the data subject’s claims. Following this, the data subject appealed before the Federal Labour Court and also requested access to an interim report related to the same investigation for the first time. Holding — The court dismissed the data subject’s appeal and held that she did not have the right to receive a copy of the final compliance reports under Articles 15(1) and 15(3) GDPR. The court held that requesting access to an interim report constituted an impermissible expansion of the claim in the appeal proceedings. Furthermore, the court held that the final compliance reports did not exclusively contain personal data within the meaning of Article 4(1) GDPR. For instance, the documents also contained legal analysis, which merely constitutes information about how the controller assesses the legal situation. Consequently, the court argued that the data subject did not need copies of the reports in their entirety in order to verify the accuracy of the personal data and the lawfulness of the processing.

## Full text

Federal Labor Court 8 AZR 169/25 April 16, 2026 Disclosure of a Copy of a Compliance Report rewis logo REWIS: LEGAL TECHNOLOGY Case Law Database Information provided without guarantee. URL: https://rewis.io/s/u/G6IO/ © REWIS UG (limited liability) Federal Labor Court 8th Senate 2 8 AZR 169/25 dated April 16, 2026 | rewis.io 8 AZR 169/25 dated April 16, 2026 Judgment | Federal Labor Court | 8th Senate Headnote The plaintiff’s appeal against the judgement of the Munich Regional Labor Court dated June 12, 2025—2 SLa 70/25—is dismissed. The plaintiff shall bear the costs of the appeal. Facts 1 The parties are in dispute over the question of whether the defendant must provide copies of compliance reports concerning the plaintiff’s conduct as a manager . 2 The plaintiff holds a managerial position with the defendant. In early April 2023, the defendant’s ombudswoman informed the compliance department that there were complaints regarding the plaintiff. Three whistleblowers had described the plaintiff’s management style as intimidating, demeaning, disrespectful, and dishonest . Through various behaviors, she had unsettled, demotivated, and literally made employees sick. At least two employees had already resigned as a result. Between August 25, 2023, and January 11, 2024, the defendant subsequently commissioned a compliance investigation into the plaintiff’s alleged managerial misconduct, to be conducted by a law firm. There are two versions of the final report on this compliance investigation: one dated January 31, 2024, and one dated February 6, 2024. Both versions contain identical content, including a structured summary of the investigation’s findings. The allegations against the plaintiff are listed, and whistleblowers and witnesses are named. The content of the conversations is reproduced in part as verbatim quotes and in part as summaries of the substance. It includes assessments and evaluations by the retained law firm, among other things regarding the credibility of witness statements. The version dated January 31, 2024—which, incidentally, is identical in content to the one dated February 6, 2024—also contains additional legal commentary and client advisories. 3 3 8 AZR 169/25 dated April 16, 2026 | rewis.io The plaintiff has been on parental leave since July 21, 2023. In a letter dated February 20, 2024, the defendant applied to the competent Labor Inspectorate to have the extraordinary, or alternatively ordinary, termination of the employment relationship with the plaintiff during her parental leave declared permissible. It based its argument on the findings of the compliance investigation. The Labor Inspectorate did not approve the intended termination. 4 The plaintiff argued that, pursuant to Art. 15(1) in conjunction with (3) of the GDPR, she has a right to receive copies of the compliance final reports. She wished to verify which statements had been made about her and stored, whether these statements are accurate, and how they were determined. The rights of the defendant or third parties do not preclude disclosure. 5 The defendant contested the claim. The term “copy” in Article 15 (3) of the GDPR does not refer to a document as such, but rather to the personal data it contains. The requirements for an exceptional right to copies of the entire documents are not met. The plaintiff’s arguments do not justify the assumption that she requires such copies in the interest of effective data protection. The defendant has an interest in maintaining the confidentiality of the compliance final reports as trade secrets that outweigh the plaintiff’s interest in obtaining information. The reports allow inferences to be drawn about the defendant’s litigation strategy and also contain data worthy of protection regarding the whistleblowers and witnesses to whom the defendant had promised confidentiality. 6 The Labor Court ordered the defendant to provide the plaintiff with a copy of the final compliance report dated January 31, 2024. The defendant filed an appeal against this decision and substantiated it in a brief dated April 22, 2025, served on the plaintiff on April 23, 2025. On appeal, the defendant clarified that, in addition to the version dated January 31, 2024, a further version of the final report dated February 6, 2024, existed. The plaintiff thereupon, in a brief dated June 10, 2025, requested for the first time that a copy of the version dated February 6, 2024, be provided. 7 Upon the defendant’s appeal, the Regional Labor Court amended the judgement of the Labor Court and dismissed the motions to provide copies of the reports in the versions dated January 31, 2024, and February 6, 2024 . However, the Regional Labor Court ordered the defendant, in accordance with the alternative motion filed in the appellate proceedings, to grant the plaintiff access to the compliance final report in the version dated February 6, 2024. 8 With the appeal authorized by the Regional Labor Court regarding the provision of copies, the plaintiff continues to pursue the corresponding motions. She also seeks, for the first time and as a matter of priority in the appeal proceedings, the provision of the final compliance reports, including an interim report dated October 19, 2023, which is statically referenced therein 4 8 AZR 169/25 dated April 16, 2026 | rewis.io an interim report dated October 19, 2023. She states that, in the meantime, based on the appellate judgment, she reviewed the final report in the version dated February 6, 2024, and found that it contained only an sub-report and that essential content was contained exclusively in an interim report dated October 19, 2023, to which reference was made. 9 She therefore requests, in summary, in the appeal proceedings, that the defendant be ordered to provide her with a copy of the compliance final report dated January 31, 2024, including the first interim report referenced the interim report dated October 19, 2023, or, in the alternative, in the event that the motion under 1, to order the defendant to provide a copy of the compliance final report dated January 31, 2024, in the 2nd version dated February 6, 2024, including the interim report dated October 19, 2023, to which it statically refers, be made available, alternatively, in the event that the claims under 1. and 2. are denied, to order the defendant 3. to provide a copy of the final compliance report dated January 31, 2024, to be made available, alternatively, in the event that the claims 1 through 3 are unsuccessful, order Defendant No. 5 8 AZR 169/25 dated April 16, 2026 | rewis.io to provide a copy of the final compliance report dated January 31, 2024, as amended on February 6, 2024. 10 The defendant seeks dismissal of the appeal. Reasons for the Decision 11 I. The plaintiff’s appeal is unsuccessful. The Regional Labor Court correctly made the decision that the plaintiff has no right to receive a copy of the final compliance reports. 12 1. Insofar as the plaintiff, in the appeal proceedings, now primarily seeks, through claims 1 and 2, now primarily seeks, in the appeal proceedings, to be provided with a copy of the final compliance report in the version dated January 31, 2024, or, in the alternative, in the version dated February 6, 2024, including the interim report dated October 19, 2023, to which it statically refers, this constitutes an impermissible expansion of the claim in the appellate proceedings. 13 a) By including the interim report dated October 19, 2023, in the substantive claims raised in the appeal proceedings, the plaintiff introduces a further subject matter of the dispute. The introduction of a further subject matter of the dispute constitutes an amendment to the lawsuit or is at least equivalent to one (BAG March 20, 2024 – 5 AZR 161/23 – para. 23 with further references). 14 aa) Based on the two-part concept of the subject matter of the dispute, the subject matter of the proceedings is determined by the claim asserted (statement of claim) and the underlying factual circumstances (grounds of the claim) (BAG June 26, 2025 - 8 AZR 276/24 – para. 17, with further references). The factual circumstances encompass the entire set of actual events underlying the claim, which, when viewed from the natural perspective of the parties, form part of or would have formed part of the set of facts presented by the plaintiff for the court’s decision (see BAG March 20, 2024 – 5 AZR 161/23 – para. 24, with further references). 15 bb) The inclusion of the interim report dated October 19, 2023, alters the lawsuits and the underlying facts of the case. Conversely, the plaintiff cannot successfully argue that, prior to reviewing the report, that the information was fully contained in the final reports and that she merely specified the claims in the appeal proceedings, because the interim report of October 19, 2023, was already part of the reports already at issue in the appellate proceedings. This is contradicted by the fact that the plaintiff had already distinguished in the lawsuit between the compliance 6 8 AZR 169/25 of April 16, 2026 | rewis.io Final Report dated January 31, 2024, and the Interim Report dated October 19, 2023. The motion in the lawsuit, however, refers exclusively to the Final Report dated January 31, 2024, without including the to include the interim report of October 19, 2023, which was known to the plaintiff in the lawsuit. Had the plaintiff intended to include the interim report of October 19, 2023, along with the request for a copy of the final report, it would have been expected that she would have included the interim report in the request. This is particularly true given that, on appeal, the plaintiff further distinguished between the requests and explicitly differentiated between the final reports in the version dated January 31, 2024, and the version dated February 6, 2024 . However, she still did not include the interim report dated October 19, 2023, in her request. 16 b) The amendment to the complaint is inadmissible in the appeal for review. 17 aa) Pursuant to § 559(1), first sentence, of the German Code of Civil Procedure (ZPO), an amendment to the complaint in the appeal for review is generally inadmissible. The conclusion of the oral hearing in the second instance forms the basis for the decision of the court of appeal not only with regard to the factual arguments but also with regard to the parties’ claims. However, the petition may be amended in the appeal for review by the appellant if the amended factual claim can be based on facts established in the appellate court or unanimously presented by the parties, the legal scope of review does not change significantly, and the procedural rights of the other party are not curtailed by a decision on the merits (BAG September 19, 2024 — 8 AZR 368/22 — para. 18 with further references). 18 bb) These requirements for an admissible amendment to the complaint in the appeal on points of law are not met. With regard to the interim report dated October 19, 2023, the facts have neither been established by the Regional Labor Court nor are they undisputed between the parties. While it may be assumed that it is undisputed between the parties that such an interim report exists, it is not undisputed what its essential content is or how it differs in detail from the respective final report . Furthermore, the defendant’s procedural rights could be violated if it were now confronted in the appellate proceedings with an amendment to the complaint regarding the interim report. It cannot be ruled out that the defendant could have presented further facts regarding the interim report that would argue against the disclosure of a copy, had the amendment to the lawsuit had been made in the lower courts. 19 2. The admissible appeal is unfounded to the extent that the plaintiff, in its most recent motion under No. 3, seeks, in the alternative, to order the defendant to provide a copy of the compliance final report in the version dated January 31, 2024, to be made available. 7 8 AZR 169/25 of April 16, 2026 | rewis.io 20 a) The Regional Labor Court correctly held that the plaintiff has no right to be provided with a copy pursuant to Art. 15(1) in conjunction with (3) of the GDPR with respect to the entire final compliance report in the version dated January 31, 2024—i.e., including the legal analysis and client notes. 21 aa) Under Article 15(1), first sentence, of the GDPR, the data subject generally has the right to request from their employer, as the controller (Article 4(7) of the GDPR), a confirmation as to whether personal data concerning them is being processed. If this is the case, the data subject has, pursuant to Article 15(1), second clause, of the GDPR, the data subject is entitled to information regarding this personal data and the information specified in Article 15(1)(a) through (h) of the GDPR. Article 15(3), first sentence, of the GDPR also grants the data subject the right to receive a copy of the personal data. Article 15(1) and (3) of the GDPR are among the provisions intended to guarantee the right of access as well as transparency regarding the Art and manner of the processing of personal data vis-à-vis the data subject (CJEU October 26, 2023 – C-307/22 – [FT] para. 49). The right of access provided for in Article 15 of the GDPR must, according to the case law of the Court of Justice of the European Union, enable the data subject to verify whether the data concerning them is accurate and whether it is being processed lawfully . This right of access is necessary to enable the data subject to exercise, where appropriate, their right to rectification, their right to erasure (“right to be forgotten”) and their right to Restriction of processing, to which they are entitled under Articles 16, 17, and 18 of the GDPR, respectively, as well as their right under Article 21 of the GDPR to object to the processing of their personal data or their rights under Articles 79 and 82 of the GDPR) to seek judicial remedy or compensation for damages (CJEU February 27, 2025—C-203/22—[Dun & Bradstreet Austria], para. 53 et seq.). 22 bb) Article 15(3), first sentence, of the GDPR does not constitute a right other than that provided for in Article 15 (1) of the GDPR and does not confer an independent claim against the controller for the provision of the document as such, but rather for the personal data it contains, which must be complete (CJEU October 26, 2023—C-307/22—[FT], para. 72; May 4, 2023—C-487/21— [Austrian Data Protection Authority] para. 32, 39). Thus, Article 15(3) of the GDPR governs a procedure for exercising the right and is inextricably linked to Article 15(1) of the GDPR. The copy must contain all personal data that is the subject of the processing (CJEU, October 26, 2023 – C-307/22 – [FT], loc. cit.; May 4, 2023—C-487/21—[Austrian Data Protection Authority], loc. cit.). This means that the data subject must be provided with a faithful and comprehensible reproduction of all such data. This right presupposes the right to obtain a copy of excerpts from documents, or even of entire documents, or of 8 8 AZR 169/25 dated April 16, 2026 | rewis.io excerpts from databases containing, among other things, this data, if the provision of such a copy is essential to enable the data subject to effectively exercise the rights granted to them by this Regulation , whilst taking into account the rights and freedoms of others in this regard (CJEU October 26, 2023 - C-307/22 - [FT] para. 75; May 4, 2023 - C-487/21 - [Austrian Data Protection Authority] para. 45). In this regard, the Court of Justice of the European Union has held, with respect to Art. 12(1) of the GDPR in conjunction with Recital 58 of the GDPR, that the reproduction of excerpts from documents or even entire documents may prove particularly ensure that the information provided is easily understandable, if contextualizing the data during processing is necessary to ensure its comprehensibility (CJEU October 26, 2023 - C-307/22 - [FT] para. 74; May 4, 2023 - C-487/21 - [Austrian Data Protection Authority] para. 41; see also Federal Court of Justice (BGH) March 5, 2024 – VI ZR 330/21 – para. 18). 23 cc) Based on this, the Regional Labor Court correctly concluded that the final compliance report, as of January 31, 2024, does not contain exclusively personal data. The Regional Labor Court also correctly held that the plaintiff could not demand a copy of the entire report on the grounds that contextualization of the personal data would be necessary to ensure its comprehensibility. 24 (1) The final compliance report in the version dated January 31, 2024, does indeed contain personal data. According to the legal definition contained in Art. 4(1) of the GDPR, personal data means any information relating to an identified or identifiable natural person—the data subject— . The concept of personal data must be interpreted broadly in light of the phrasing “any information” (see CJEU, June 22, 2023— C-579/21—[Pankki S], para. 42; May 4, 2023—C-487/21—[Austrian Data Protection Authority], para. 23). It is not limited to sensitive or private information but potentially encompasses all types of information, both objective and subjective in nature, in the form of statements or assessments, provided that the information relates “to” the individual in question (CJEU June 22, 2023 - C-579/21 - [Pankki S], loc. cit.; May 4, May 2023—C-487/21—[Austrian Data Protection Authority], loc. cit.; December 20, 2017—C-434/16—[Nowak], para. 34). The final compliance report in the version dated January 31, 2024, addresses the plaintiff’s conduct as a manager and therefore necessarily contains information “about” the plaintiff as a person. 25 (2) However, the final compliance report in the version dated January 31, 2024, does not exclusively contain personal data within the meaning of Art. 4(1) of the GDPR. The legal arguments contained solely in the version dated January 31, 2024, do not constitute personal data insofar as they contain a legal analysis. 9 8 AZR 169/25 dated April 16, 2026 | rewis.io legal analysis. A legal analysis is not information about the data subject, but at most—insofar as it is not limited to a purely abstract interpretation of the law—information regarding how the controller assesses the legal situation (see CJEU July 17, 2014—C-141/12 et al.—[YS et al.] para. 40). The legal situation in this regard has been sufficiently clarified by the Court of Justice of the European Union, regardless of the fact that the decision regarding the concept of personal data was issued in relation to Article 2(a) of Directive 95/46/EC (contrary view: Tegel/Lembke, NZA-RR 2026, 121, 125). This predecessor provision is comparable to Art. 4(1) of the GDPR (see Federal Court of Justice [BGH], June 15, 2021 – VI ZR 576/19 – para. 29). 26 (3) There are no indications that the plaintiff requires a copy of the final report in the version dated January 31, 2024, including the legal analysis and client notices, in order to ensure the comprehensibility of the contained in the final report, are not apparent. These are, in essence, distinct components of the report, even if they are contextually related (contrary view: Zöll/Kielkowski, jurisPR- Compl 1/2026, note 3). Nor does the plaintiff require knowledge of the legal analyses and client notices in order to exercise the rights conferred upon her by the General Data Protection Regulation—namely, the rights to rectification, erasure, and restriction of processing under Articles 16, 17, and 18 of the GDPR, respectively, with respect to her personal data. To the extent that she wishes to challenge a legal opinion of the defendant or its advisors that she considers incorrect, she may, if necessary, make use of her procedural options—e.g., in the context of an unfair dismissal lawsuit. Therefore, the requirement to provide complete information regarding personal data does not give rise to a claim by the plaintiff that—as she has demanded— the final report be provided in its entirety, even if partially redacted, as a copy (see BGH April 16, 2024—VI ZR 223/21—para. 18; see para. 32 below regarding redaction ). 27 b) A claim for the provision of a copy of the compliance final report in the version dated January 31, 2024, does not arise from either para 26(2) SprAuG or para 83(1) BetrVG. It can therefore be left open whether the plaintiff— in accordance with the parties’ view—is or was a senior executive within the meaning of § 5(3) BetrVG. 28 aa) Under § 26(2) SprAuG and § 83(1) BetrVG, which are identical in both wording and substance (see BAG, Nov. 16, November 2010 – 9 AZR 573/09 – para. 21, BAGE 136, 156) the right to inspect the personnel files maintained about them . According to the substantive definition, personnel files are a collection of documents and records concerning the personal and professional circumstances of the employee and intrinsically related to the employment relationship. An external classification is not relevant in this context (BAG October 17, 2024 - 8 AZR 42/24 - para. 28 with further references).10 8 AZR 169/25 of April 16, 2026 | rewis.io 29 bb) The right of access includes the right to make copies from the personnel file at one’s own expense (ErfK/Kania, 26th ed., BetrVG § 83, para. 4, with further references). This right is, however, limited to a reasonable scope. This scope is no longer maintained if the employee wishes to copy the personnel records in their entirety (GK-BetrVG/Franzen, 13th ed., BetrVG § 83, para. 24 et seq.; Richardi, BetrVG/ Thüsing, 18th ed., BetrVG § 83, para. 17; HaKo-BetrVG/Boemke, 7th ed., BetrVG § 83, para. 19). Based on this, neither § 26(2) SprAuG nor § 83(1) BetrVG establishes any right for the plaintiff to receive a in its entirety. Irrespective of this, it appears doubtful whether the legal analyses and client advisories contained in the version dated January 31, 2024, can be regarded as part of the substantive personnel file. 30 3. The appeal is also unfounded with respect to the alternative claim under 4., by which the plaintiff seeks to be provided with a copy of the compliance final report in the version dated February 6, 2024. The plaintiff asserted this claim by way of an inadmissible cross-appeal. 31 a) The plaintiff first raised this claim in the appellate proceedings in a brief dated June 10, 2025, “to order the defendant, in addition, to … provide a copy of the final compliance report dated February 6, 2024.” With this wording of the request, the plaintiff makes it clear that, in addition to or in any event, in the alternative to a copy of the report in the version dated January 31, 2024, a copy of the report in the version dated February 6, 2024. This constitutes an expansion of the issues in dispute. The reports in the versions dated January 31, 2024, and February 6, 2024, differ in content. They are therefore different documents. Accordingly, the plaintiff clarified during the oral hearing before the State Labor Court, as evidenced by the minutes of the hearing, clarified that it understood the motion seeking a copy of the version of the report dated February 6, 2024 as an amendment to the complaint in the appeal proceedings. The defendant expressly stated that it consented to the amendment to the complaint. The State Labor Court based its reasons for the judgment on the fact that this constitutes an amendment to the complaint in this respect. The plaintiff did not contest this in the appeal proceedings. 32 b) The plaintiff cannot successfully argue that the request for the production of a copy of the compliance final report in the version dated January 31, January 2024 had already previously been interpreted as a “lesser” claim seeking the production of a copy of the report dated January 31, 2024, with partial redaction . An interpretation of the original request for disclosure of the report dated January 31, 2024, to the effect that legal analyses and client advisories may be redacted is ruled out (see, regarding the interpretation of requests for information under Art. 15(1) in conjunction with (3) of the GDPR: BGH March 5, 2024 – VI ZR 330/21 – para. 19). The existence of a version with and a version without legal11 8 AZR 169/25 dated April 16, 2026 | rewis.io explanations and client notices became known to the plaintiff on appeal . She took this as an opportunity to amend her lawsuit. Such a move would have been unnecessary had there been a proper understanding of the original lawsuit. It can therefore remain undecided whether the plaintiff’s interpretation of the lawsuit would have led to a sufficiently specific lawsuit . 33 c) The amendment to the lawsuit in the appellate proceedings was possible for the plaintiff, as the respondent on appeal, only by way of a cross-appeal. Thus, the amendment to the lawsuit must be interpreted as a cross-appeal, even if it is not designated as such (see BAG, October 1, 2025—4 AZR 285/24—para. 92 et seq.; August 21, 2019— 7 AZR 563/17 - para. 66; December 10, 2014 - 7 AZR 1009/12 - para. 54). However, the cross-appeal was not filed within the prescribed time limit. 34 aa) Pursuant to § 524(2), second sentence, of the German Code of Civil Procedure (ZPO), a cross-appeal is admissible until the expiration of the time limit set for the respondent to file a response to the appeal. In labor court proceedings, however—unlike under § 521(2), para 1, of the ZPO— the Court does not “set” a time limit for the respondent to file a response to the appeal; rather, rather, the statutory time limit specified in § 66(1), para 3, of the Labor Court Act (ArbGG) applies to the response to the appeal. Nevertheless, § 524(2), para 2, of the Code of Civil Procedure (ZPO) is applicable by analogy pursuant to § 64(6), para 1, of the Labor Court Act (ArbGG). A cross-appeal that is not filed within one month after service of the statement of grounds for appeal—in the event of an extension of the time limit for filing a response to the appeal pursuant to § 66(1), para 5, ArbGG within the period then applicable—is to be dismissed as inadmissible pursuant to § 522(1) of the ZPO if the appellate court, upon service of the statement of grounds for appeal, provided the notice required under § 66(1), para 4 of the ArbGG regarding the deadline for filing a response to the appeal pursuant to § 66(1), sentence 4, ArbGG (BAG March 25, 2021—8 AZR 120/20— para. 52; August 21, 2019 - 7 AZR 563/17 - para. 68). The requirement to file a cross-appeal within the time limit for filing a response to the appeal and to substantiate it is intended to facilitate the resolution of the appeal proceedings. An exception to this time limit for reasons of procedural economy is not permissible in light of its meaning and purpose, nor in light of the constitutional requirement of equality of arms in civil procedure (see BGH August 31, 2022 - VIII ZR 233/21 - para. 72 et seq.). 35 bb) These requirements for an admissible cross-appeal are not met. The appellate court must examine this ex officio (BAG May 24, 2012 – 2 AZR 124/11—para. 10; Federal Court of Justice (BGH) October 24, 2007—IV ZR 12/07—para. 7). The defendant filed the grounds for the appeal in a brief dated April 22, 2025, which was served on the plaintiff on April 23, 2025. The Regional Labor Court advised the plaintiff pursuant to § 66(1), fourth para, of the ArbGG, that the appeal must be answered within a period of one month following service of the statement of grounds for the appeal. The plaintiff answered the appeal within the prescribed time limit by a brief dated May 23, 2025, on the last day of the time limit. However, the lawsuit seeking the production of a copy of the compliance final report in the version dated February 6, 2024, was not filed until 12 8 AZR 169/25 dated April 16, 2026 | rewis.io Cross-appeal, however, the plaintiff did not file her response until June 10, 2025, and thus after the deadline for responding to the appeal had expired. 36 II. The decision on costs is based on § 97(1) ZPO. Krumbieg Roloff Pulz el Volz Wittke

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