Key Changes Regarding Data Protection, Legal Notice and Accessibility

1. New Legal Frameworks for legal notice (DDG) and data protection (TDDDG)

The former German Telemedia Act (TMG) and the Telecommunications-Telemedia Data Protection Act (TTDSG) have been replaced by new regulations:

• Legal notice: The TMG has been replaced by the Digital Services Act (Digitale-Dienste-Gesetz – DDG). The legal notice requirements are now governed by Art. 5 DDG.
• Privacy notices / cookie banners: The Telecommunications-Telemedia Data Protection Act (TTDSG) has been renamed the Telecommunications-Digital Services Data Protection Act (TDDDG). The cookie rules continue to be set out in Art. 25 TDDDG.

What does this mean for you?

All legal documents on your website that directly refer to the TMG or TTDSG must be updated to refer to the DDG and TDDDG.

2. Discontinuation of the EU Online Dispute Resolution Platform (ODR Platform)

The European Commission discontinued its online dispute resolution service (ODR platform) on February 15, 2024.

What does this mean for you?

All references and links to the ODR platform in your legal notice and/or general terms and conditions (GTCs) are now obsolete and may expose you to warnings (cease-and-desist letters). These sections must therefore be removed without delay.

3. New Accessibility Strengthening Act (BFSG)

Since June 28, 2025, the Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz – BFSG) also applies to the private sector. This law requires that digital products and services (such as online shops, websites, apps, etc.) must be accessible and usable for people with disabilities.

What does this mean for you?

You should assess whether your digital offerings fall within the scope of the regulation. If they do, extensive technical adjustments to your website will be required.

Recommended actions: What companies should do now

Not only data protection authorities, but also competitors and consumer protection associations, are entitled to issue warnings (cease-and-desist letters). A warning due to an incorrect privacy policy can have significant legal and financial consequences for companies in Germany, including contractual penalties, fines, or legal proceedings.

We therefore strongly recommend that you review and implement the above-mentioned changes and any necessary adjustments to your website in order to ensure compliance.

If you have any questions or require assistance, we will be happy to support you.