The coach, chartered by a travel company, was carrying 33 Filipino tourists and two Italian drivers to the Oktoberfest in Munich, a spokeswoman for the Upper Bavaria police prefecture told Agence France-Presse.
Near Austrian border
According to initial findings from the investigation, the vehicle left the road before overturning near Buchloe, in a region close to the Austrian border.
It had departed from the town of Mailand.
Emergency services were deployed to the scene, and the motorway was closed in both directions.
One of the victims was a 58-year-old man, but the second victim had not yet been identified, police said.