Case file DE-1995/2026June 2026 evidence report · Germany

A public opportunity should not depend on denying a belief.

The record shows declarations used in public contracts, grants, employment-related settings and other administrative contexts that require people or organisations to distance themselves from a named belief community. It shows how the condition is worded, where it travels, and how courts have recognised the legal significance of belief and association.

Key findings

Three findings from the record.

The number, the time span, and the court recognition belong together: they show reach, development, and legal boundary.

01
3,959Notices in the documented minimum

The June series records 3,959 TED notices containing the search term. It is a documented minimum, not a census of every clause.

Open TED search ↗
02
2014–2026A longer documented series

The report-backed series reaches back to 2014. The public TED search itself shows only the latest ten years.

03
2022A court set a boundary

In BVerwG 8 C 9.21, Munich could not make an environmental subsidy depend on a declaration distancing the applicant from Scientology.

Open decision ↗
Source pathFour routes into the findings.Each source carries a different part of the finding.
Source statesHow to read the source states
Judicial recordJudgment, order, docket, or court passage.International sourceTreaty, OHCHR communication, or international instrument.Party submissionA dossier or submission presented to an international body.Administrative recordTED notice, form, circular, or public authority material.
Evidence Atlas · source index

Follow the record
node by node.

The record brings together the clauses, notices, judgments and international materials that establish the finding.

Report dossier2 Jun 2026

Faith Breakers · June 2026 report

Quantitative TED series, historical frame, clause variants and institutional recommendations.

Party submission3 Oct 2021

ICCPR submission

International argument, court quotations, forms, media, BKA extracts and attachment archive.

Judicial record15 Dec 2005

BVerwG 7 C 20.04

Official court record; the submission also reproduces passages from the decision.

Administrative record2014–2026

TED Scientology search

Live public window and longer report-backed historical series; documented minimum, not census.

Connected evidenceTyped relationships

quotes · interprets · implements · affects · follows

Key findings

Three findings from the record.

The number, the time span, and the court recognition belong together: they show reach, development, and legal boundary.

01
3,959Notices in the documented minimum

The June series records 3,959 TED notices containing the search term. It is a documented minimum, not a census of every clause.

Open TED search ↗
02
2014–2026A longer documented series

The report-backed series reaches back to 2014. The public TED search itself shows only the latest ten years.

03
2022A court set a boundary

In BVerwG 8 C 9.21, Munich could not make an environmental subsidy depend on a declaration distancing the applicant from Scientology.

Open decision ↗
Source pathFour routes into the findings.Each source carries a different part of the finding.
The signal

The record shows the condition, its reach, and its legal stakes.

Documented record3,959Open TED search ↗

The public TED search exposes the latest ten years; the author’s report-backed series reaches back to 2014. This is a documented minimum, not a census.

2024 documented peak621

The report records 621 notices in 2024, after the cited 2022 ruling; sequence does not establish causation.

Legal lens08

Constitutional, procurement, equality, privacy, ECHR and ICCPR frameworks.

Coverage note: the live TED query exposes only the latest ten years; the author’s report-backed series reaches back to 2014. Below-threshold contracts, annex-only wording and linked-platform records may still fall outside the documented minimum. Run the Scientology TED search ↗ Open report methodology ↗

Chapter 01 · Plain-language explainer

See the clause
before the argument.

A faith-breaker clause is a contractual or grant condition that demands a negative declaration about Scientology and the use of “L. Ron Hubbard technology” from a tenderer, grantee, employee or subcontractor.

Exhibit AClause excerpt · procurement template
“I declare that I do not apply, teach or disseminate the technology of L. Ron Hubbard; that I do not attend courses or seminars based on this technology; and that this applies to employees and subcontractors.”
✓
A neutral safeguarding rule

Regulates conduct.

Legality, labour compliance, confidentiality, safeguarding, anti-corruption and professional capacity can be required of everyone equally.

×
A faith-breaker clause

Tests identity.

It asks for negative declarations about one named community, including teaching, course attendance, dissemination or association.

Chapter 02 · Data record

The documented signal grew after 2022.

The annual record shows the scale and timing of the documented notices. The live TED window and the longer report-backed series are shown together as distinct coverage layers.

Run the Scientology TED search ↗
Fig. 03

TED notices mentioning Scientology

Germany · annual record
2022: cited court ruling 2024: reported peak* 2026 partial period
Chapter 03 · Primary evidence

The forms show
the clause’s reach.

Each exhibit keeps the source language visible, then provides a concise reading of who the declaration reaches and why that matters.

A
01
Procurement template

The clause, as filed

“I declare that I do not apply, teach or disseminate the technology of L. Ron Hubbard; that I do not attend courses or seminars based on this technology; and that this applies to employees and subcontractors.”

Filed as a routine contract condition; examined here as a belief-based declaration.

B
02
Bavaria / Munich template

A declaration reaching employees

“I am not a member of the Scientology Organization; I do not use the technology of L. Ron Hubbard; I do not attend courses or seminars; none of my employees do.”

The recorded wording extends the declaration from the contractor to employees.

C
03
Hamburg / Berlin template

A supply-chain belief test

“I do not apply, teach or disseminate contents or methods of L. Ron Hubbard; I do not attend courses; this applies to all employees and subcontractors involved.”

The relevant form language reaches into staff and subcontractor arrangements.

Chapter 04 · Legal analysis

The clause engages
eight legal lenses.

Eight legal lenses bring the clause into view. Open any row to read the governing rule and move directly to the legal text.

01Basic Law · Arts. 3 & 4 GGEquality and freedom of belief⌄
The rule in view

Public authorities must treat persons equally and may not disadvantage them because of faith, religious opinion or belief.

Read the legal source ↗
02Directive 2014/24/EUEqual treatment in procurement⌄
The rule in view

EU procurement requires equal treatment, transparency and proportionality; religious affiliation is not a listed exclusion ground.

Read the legal source ↗
03EU Charter · Arts. 7, 10 & 21Privacy, belief and non-discrimination⌄
The rule in view

The Charter protects private life, religion or belief, and equality when Member States apply EU procurement law.

Read the legal source ↗
04ECHR · Arts. 9 & 14Freedom of religion and equality⌄
The rule in view

The report identifies state assessment of religious affiliation as an economic condition as engaging Convention protections.

Read the legal source ↗
05GDPR · Arts. 5 & 9Religious data is special-category data⌄
The rule in view

A declaration can collect or infer belief-related data when access to public opportunity depends on disclosure.

Read the legal source ↗
06ICCPR · Arts. 17 & 18Privacy and freedom of religion⌄
The rule in view

The report frames belief screening as arbitrary interference lacking an individualised justification and evidence-based necessity test.

Read the legal source ↗
07Directive 2000/78/ECEmployment equality⌄
The rule in view

Supply-chain and workforce clauses can pressure employees to conceal or renounce belief as a condition of employment.

Read the legal source ↗
08Directive 2007/66/ECEffective remedies and transparency⌄
The rule in view

Annex-only visibility can make a discriminatory condition harder to identify and challenge effectively.

Read the legal source ↗
Chapter 05 · International record

Rights in the record.

Privacy, religion and equality stand beside the German court record. The 2021 ICCPR submission is identified by evidence state, while every cited instrument and decision remains open for inspection.

Art. 17

Privacy

The ICCPR submission frames forced belief disclosure as an interference with private life. This is a party claim, not a Committee finding.

Read instrument ↗
Art. 18

Freedom of religion

The submission places belief, conscience and non-coercion at the centre of its argument and connects that claim to the German court record.

Read instrument ↗
Art. 26

Equal protection

The submission argues that access to work, grants and public opportunity cannot depend on a negative declaration about one named community.

Read instrument ↗
Evidence stateParty submission

Evidence state: party submission. This is not a Committee decision; the linked instrument is the direct legal source.

Open OHCHR index ↗
Chapter 07 · Judicial record, 1988–2012

Courts recognised
belief in context.

Each card pairs the court, docket, legal significance and—where indexed—a short positive passage. The source label shows whether the passage is read from the decision itself or reproduced in the ICCPR case packet. The 2022 BVerwG decision appears below as the procurement anchor.

Open the historical case packet ↗
1988Court recordSuperior Court Hamburg71 T 79/85 · NJW 1988, 2617
Judicial record

The court record recognises the Church as a religious organisation under Article 140 Basic Law / Article 127 WRV.

Primary decision copy reached through the dejure full-text listing; hosted on Wikimedia Commons.
1990Court recordAdministrative Court FrankfurtIV 2 E 2234/86 · NVwZ 1991, 195
Judicial record

An information-stand dispute is quoted as recognising constitutional protection of religious or philosophical community status.

“The Church of Scientology ... constitutes a Religious respectively Philosophical Community in the meaning of Art. 4 sect. 1 and Art. 140 of the Basic Law in connection with Art. 137 sect. 2, sect. 7 WRV.”VG Frankfurt IV 2 E 2234/86 · ICCPR submission pp. 10–11Verified quotationVerified quotation in supplied PDF; public decision listing availableInstitutional sourceJudicial recordOpen PDF at quoted pages · PDF pages 10–11 ↗
1994Court recordHamburg State Administrative Court of AppealBs III 326/93 · NVwZ 1995, 498
Judicial record

The quoted injunction decision treats Article 4 Basic Law as a wider protection than Article 2.

“It has to be considered that it is also entitled to claim the protection from Art. 4 Basic Law, which—as a lex specialis when compared to Art. 2 sect. 1 Basic Law—grants a wider reaching—even if not unlimited—protection.”OVG Hamburg Bs III 326/93 · ICCPR submission p. 11Verified quotationVerified quotation in supplied PDF; public decision listing availableInstitutional sourceJudicial recordOpen PDF at quoted pages · PDF pages 11 ↗
1997Federal courtBVerwG1 C 18/95 · 6 Nov 1997
Judicial record

The principle distinguishes member services inseparable from membership from ordinary commercial activity.

“An idealistic association does not conduct a commercial activity, to the extent that it offers services to its members that cannot be rendered by other service providers independent of the membership relationship.”BVerwG 1 C 18/95 · ICCPR submission pp. 14–15Verified quotationVerified quotation in supplied PDFInstitutional sourceJudicial recordOpen PDF at quoted pages · PDF pages 14–15 ↗
2002Labour courtFederal Labour Court5 AZB 19/01 · NJW 2003, 161
Party submission

The later Berlin case analyses courses and seminars through the parties’ religious conviction.

Quotation verified in the supplied PDF; an independent judgment PDF remains a preferred direct route.
2004State courtHamburg Krüger case1 Bf 198/00 · 17 Jun 2004
Party submission

The court recognises Article 4 protection for the plaintiff’s belief and philosophy.

Quotation verified in the supplied PDF; an independent judgment PDF remains a preferred direct route.
2005Federal courtBVerwG · Krüger7 C 20.04 · 15 Dec 2005
Judicial record

The court’s analysis links the declaration to belief and to exposure and exclusion from business relations.

“The religious or philosophical contents of Scientology cannot be separated from the technology, even if the declaration refers explicitly only to the latter.”BVerwG 7 C 20.04 · ICCPR submission pp. 22–23Verified quotationVerified quotation in supplied PDFInstitutional sourceJudicial recordOpen PDF at quoted pages · PDF pages 22–23 ↗
2008Bavarian courtAdministrative Court AnsbachAN 16 K 06.03463 · 13 Nov 2008
Party submission

The quoted reasoning treats member services as inseparable from religious conviction and not customary in the market.

“A commercial enterprise of the plaintiff ... does not exist as the services offered by the plaintiff to its members are not customary in the market, but are inseparably connected with the convictions of its members and lose their value when the connection vanishes.”VG Ansbach AN 16 K 06.03463 · ICCPR submission pp. 16–17Verified quotationVerified quotation in supplied PDF; independent judgment route preferredInstitutional sourceParty submissionOpen PDF at quoted pages · PDF pages 16–17 ↗
2009Court recordBerlin courtsVG 27 L 41.09 · OVG 5 S 5.09
Party submission

The court record shows removal of an information pillar and confirmation on appeal under Article 4 protection.

“The posters put up on an info pillar in front of the center of the applicant unjustly interfere with the basic right of the applicant in the free exercise of its philosophy per Art. 4 sect. 1 of the Basic Law.”VG Berlin VG 27 L 41.09 · ICCPR submission p. 12; confirmed OVG 5 S 5.09Verified quotationVerified quotation in supplied PDF; independent judgment route preferredInstitutional sourceParty submissionOpen PDF at quoted pages · PDF pages 12 ↗
2010–12Court recordHamburg street-mission cases21 K 621/07 · 4 Bf 269/10
Party submission

The quoted decisions reject a merely commercial reading of religious street activity and refer to Articles 4 and 5 Basic Law.

“This estimation does not sufficiently consider the pertinent constitutional rights deriving from Art. 4 and Art. 5 of the Basic Law, which the plaintiff can also rely on.”VG Hamburg 21 K 621/07 · ICCPR submission pp. 12–13; confirmed OVG 4 Bf 269/10Verified quotationVerified quotation in supplied PDF; independent judgment route preferredInstitutional sourceParty submissionOpen PDF at quoted pages · PDF pages 12–13 ↗
Case model · BVerwG 8 C 9.21

What the court decided.
Why this matters.

A court recognition is strongest when its holding, legal reach and significance remain visible together.

What the court decided.

The Federal Administrative Court confirmed that Munich could not refuse a Pedelec subsidy because the applicant would not sign a declaration distancing herself from Scientology. It held that the demand exceeded the municipality’s competence, interfered with freedom of religion or belief under Article 4(1) and (2) GG, and violated equal treatment under Article 3(1) GG.

What this establishes

For this case, the judgment establishes a concrete legal boundary: an environmental subsidy may not be made conditional on a belief-related declaration unrelated to the subsidy’s purpose.

Why this matters.

This decision gives the atlas a concrete judicial anchor: a public authority could not make an environmental opportunity depend on a belief-related declaration unrelated to the opportunity’s purpose.

Judicial recordBVerwG 8 C 9.21 · 6 April 2022Open official decision ↗
Chapter 08 · Citation wall

Read the words
in the record.

These passages remain in their source chain: court decision, OHCHR communication, or wording reproduced through the ICCPR submission. The label identifies the evidence state.

01
“The religious or philosophical contents of Scientology cannot be separated from the technology, even if the declaration refers explicitly only to the latter.”
BVerwG 7 C 20.04 · quoted at ICCPR submission pp. 22–23Verified quotationOpen PDF at quoted pages · PDF pages 22–23 ↗
02
“Its purpose is to prepare the breaking off of the business relation with Scientologists, which gets exposed by means of the protective declaration.”
BVerwG 7 C 20.04 · quoted at ICCPR submission p. 22Verified quotationOpen PDF at quoted pages · PDF pages 22 ↗
03
“An idealistic association does not conduct a commercial activity, to the extent that it offers services to its members that cannot be rendered by other service providers independent of the membership relationship.”
BVerwG 1 C 18/95 · quoted at ICCPR submission pp. 14–15Verified quotationOpen PDF at quoted pages · PDF pages 14–15 ↗
04
“Individuals identifying as Scientologists should not have to endure undue scrutiny nor disclose their beliefs unless a legitimate, substantiated reason can be provided.”
OHCHR Special Procedures communication AL DEU 2/2019 · quoted at ICCPR submission pp. 1–2International sourceOpen PDF at quoted pages · PDF pages 1–2 ↗
Chapter 09 · Evidence map

Follow the evidence
through the archive.

The archive brings together court packets, translated judgments, protective-declaration samples, and media or government references. Each group is a route into the record.

ATT. 01

Krüger / BVerwG

Hamburg and Federal Administrative Court passages on belief and protective declarations.

ATT. 02–08

German court packet

Hamburg, Frankfurt, Berlin and street-activity decisions from 1988–2012.

ATT. 09–13

Association and labour cases

BVerwG 1 C 18/95, Baden-Württemberg, Bavaria, Ansbach and the 2002 labour decision.

AT. SF

Sect-filter attachments

German originals and translations of forms used across federal, state and public programmes.

AT. REPORTS

Media and government material

Press reports, public information material and documents that complete the historical record.

Chapter 10 · Security and proportionality

Security is not a
blank cheque.

Security is measured against four visible standards: inner belief, necessity, least intrusive means, and a clear boundary between a cited record and a claim still awaiting primary verification.

Forum internum

Protected inner belief is distinct from state assessment; the applicable OSCE/ODIHR standard keeps that boundary visible.

Necessity

Belief disclosure requires a legitimate, substantiated reason before it can be demanded.

Least intrusive means

Any filter must be proportionate to a concrete security risk and no broader than necessary.

Evidence boundary

OPC surveillance and constitutional-risk references remain marked for primary-record verification.

Source chain

Party submission → OSCE/ODIHR guidance → primary German security records still needed.

Read source note ↗
Chapter 06 · Reach

Where the clause travels.

The condition travels across authority levels and service categories. This map records documented contexts; it is not a complete census.

01

Federal

Ministries, federal agencies and the Federal Administrative Court appear in the post-2022 examples.

02

Länder

Bavaria, Hamburg, Baden-Württemberg and North Rhine-Westphalia are named across procurement and grant contexts.

03

Municipal

Munich, Berlin, Hamburg and hundreds of municipalities sit below the TED threshold more often, increasing the undercount.

04

Central purchasing

Dataport AöR and Kasse.Hamburg can transmit one template across several authorities at once.

Sectors named across the source material
IT infrastructureFacility managementConsultingTrainingCleaningSecurityTransportHealthcareSocial services
Grants

The second dossier describes a Bavarian subsidy dispute and frames public funding as a gatekeeping context.

Employment

The Munich House of Art case is presented as a 2018–2019 employment and institutional-pressure example.

Security clearance

The submission connects intelligence-service practice to questions about belief in security-sensitive roles.

Citizenship

The submission claims belief-related screening can reach naturalisation procedures; this remains a submission-level claim requiring primary verification.

Private supply chains

The June report describes a cascading effect when public contracts induce private employers and suppliers to reproduce the same wording.

Methodology and source trailOpen or close methodology⌄
Methodology and source trail

Methodology and
source trail.

This closing section explains the research frame: the TED search window, the report-backed series reaching to 2014, the documents included, and the limits created by publication thresholds and annex-only wording. It is here for readers who want to reproduce the research—not a qualification on the findings above.