In the case of amendments to the association's basic act (Article 20 ZDru-1), the association must also attach to the request a copy of the amendments to the basic act or a copy of the consolidated text of the basic act.
If at the end of the procedure the administrative unit (UE) does not agree with the amendment of only one provision of the basic act (and accepts all amendments to the other provisions as correct), it will reject the entire basic act, which also means the amendments that the UE considers to be correct and in compliance with the applicable legislation.
In this case, the association is prevented from continuing its work in accordance with the amendments that were not problematic. It would be more correct to approve these amendments and reject the amendments that the Administrative Unit decides are not in accordance with the law. This would allow the association to continue its operations in the light of the accepted amendments, which are correct and lawful, and to continue with the appeal procedures in respect of the others.
The above-mentioned practice, which has been established at the UE, thus forces associations, in the event of amendments not being adopted in accordance with the law, to repeat the procedure for their adoption (convening of the assembly of members, drafting of the material, drafting of the minutes, drafting of the application) and to resubmit the request for amendment of the same provisions of the basic act. This means that the UE has to work with the same amendments that it has already found to be correct but has rejected because it has rejected the entire basic act of the association because it disagrees with the amendment of one provision.
It is certainly possible that, even under the current legislation, the Administrative Units could have issued a decision approving some amendments to the Basic Act and rejecting others. Such a solution would be more correct and also in line with the principles of economy, efficiency and the protection of the rights of the parties. The amendment of each individual provision of the basic act could be considered by the UE as an individual request - which also follows from the logical interpretation of the institute of partial decision (Article 219 of the ZUP), which could be used by administrative units in similar cases several times. Unfortunately, civil servants in administrative units and ministries (as appeal bodies) are not able to apply the provisions of ZDru-1 and ZUP in accordance with general principles and systemic and teleological interpretation, but only read a specific provision of the law and draw incorrect conclusions based on the practice of other "merely" similar cases (e.g. first registration of the association and approval of the first basic act).
In order to simplify matters and make them quicker, it would be sensible to write the text of the ZDru-1 (especially Article 20) in such a way that it would be perfectly clear even to the most untrained civil servants that they can only issue a decision rejecting amendments to provisions which they consider to be inconsistent with the law and approving amendments to provisions which they consider to be in conformity with the applicable law. This would save work and time for the associations and the UE, as the current practice duplicates work that has already been done and is judged by the UE to be correct.
I attach a practical example where the UE LJ rejected all other changes to the basic act because it considered the name change inappropriate. Unfortunately, this way of working was also accepted by the Ministry of the Interior.