After the train accident near Garmisch-Partenkirchen, the public prosecutor's office in Munich II initiated investigations against three people on suspicion of negligent homicide.
The accused are employees of Deutsche Bahn, said a spokeswoman for the Munich II public prosecutor on Tuesday at the request of the German Press Agency.
The regional train from Garmisch-Partenkirchen to Munich derailed shortly after departure on Friday afternoon.
Soko "Zug" leads investigations
Four women and a 14-year-old from the region died and around 40 people were injured.
One woman remains in critical condition.
Among the women killed are two mothers from Ukraine who had fled to Bavaria with their children.
The investigation into the cause of the accident is being carried out by a Soko "Zug".
The Federal Office for Railway Accident Investigation is also involved.
Deutsche Bahn announced that it is currently unable to comment due to the ongoing investigation.
"Of course we are doing everything we can to support the investigating authorities in clarifying the cause of the accident," said a railway spokesman on Tuesday.