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Germany SMS & Voice Marketing Rules (UWG + BNetzA)

Germany (DE) is Orbit’s largest EEA market by regulatory documentation — BNetzA’s document rules hit almost every German number purchase, and German law (UWG §7) treats unsolicited electronic marketing as an unlawful nuisance rather than a simple opt-out regime. This page expands the DE row of the country-requirements matrix so you can close the German items deliberately instead of re-reading one JSON blob per launch. Germany is a tenant-owned burden. Orbit never mandates your posture — it keeps the country-rules reference that feeds the send-time gates, and it gives you the consent ledger, quiet-hours, and opt-out surfaces below. The legal posture is yours.
This page is documentation, not legal advice. German marketing law (Gesetz gegen den unlauteren Wettbewerb, UWG §7) is enforced against the sender, and BNetzA’s numbering requirements are set by the regulator — have counsel review your consent capture and STOP handling; Orbit supplies the surfaces.

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Accepted sender classes for Germany

Read the DE row of GET /compliance/country-rules?country=DE (see Country Compliance Requirements). Consolidated, consistent with the compliance profile seed (country_code: DE, alphaSupported: true, registrationRequired: none):
The Gesetz gegen den unlauteren Wettbewerb (UWG), Section 7, is the German unfair-competition statute that governs when a commercial communication via phone or SMS counts as “unacceptable nuisance” (general unlawful advertising). The rule (as German courts apply it):
  • Marketing SMS, marketing calls, and any directional commercial communication (email, RCS, WhatsApp) require the recipient’s prior consent to be lawful. Consent must be affirmative — German courts treat silence, pre-ticked boxes, or an inferred-from-quiet-hours assumption as insufficient.
  • Post-court practice (Bundesgerichtshof, BGH) treats an opt-out claim as valid only when it follows an ex-ante consent; i.e. “you can unsubscribe later” does not rescue an unsolicited marketing send. A minimal pre-consent “brand teaser” — a short disclosure-only message that identifies your brand and asks for consent rather than sending the full marketing payload — is the compliant fallback when prior consent cannot be demonstrated.
  • Double-opt-in (DOI) — a confirmation step that proves the recipient actually completed the opt-in — is not a German statutory requirement, but German case law treats DOI as the only reliable evidence chain courts have consistently accepted when consent is disputed. Orbit’s Double-Opt-In surface exists to supply that chain.
Tenant-owned controls that map to the UWG rule:

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BNetzA requirements for phone-number purchase (Germany)

Germany’s Federal Network Agency (Bundesnetzagentur, BNetzA) is the regulator whose numbering plan drives the DE documentation set. When you buy a German phone number (especially a local number), the Orbit purchase flow will require DE-specific compliance-profile documents. According to the Numbers Regulatory Preview page’s DE branch (preview call GET /numbers/regulatory-preview?country=DE), the platform returns the strictest combined DE requirement set — a preview that includes identity proof, address proof, and business documents (document_roles: ["id_proof", "address_proof", "business_doc"]) for a local DE number. A tenant’s compliance_profile_satisfies flag tells you whether your existing Compliance Profile already satisfies those roles; the requirements themselves are tenant-agnostic. The Documents KYC page’s Germany note also anchors Germany as one of the heavier national documentation sets (alongside France): BNetzA’s doc-age expectation — “ID or business documents must be recent on purchase” — is why a cprof_* that was valid last month may fail DE the next. Keep your documents refreshed.

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Quiet-hours defaults under German BNetzA guidance

German law leaves the per-day window mostly to case law — but BNetzA guidance and German an-sending precedent converge on a 21:00–09:00 recipient-local window as the safe zone where unsolicited marketing traffic is most likely to produce complaints or be judged a violation of UWG. Orbit’s configuration surfaces for this: Unlike the FR statutory 20:00–08:00 convention, the German 21:00–09:00 window is not surfaced as hard law in the country-rules response — it is a BNetzA guidance default Orbit inherits. If your counsel requires a different window, set it as tenant quiet hours deliberately.

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German-language STOP keyword handling

The Opt-Out Keyword Alias Table includes the entire German marketing-opt-out vocabulary: STOPP, ABBESTELLEN, ABMELDEN, ENDE, ABBRECHEN in the opt-out group, plus the opt-in (START, JA, ANMELDEN, ABONNIEREN) counterpart. German keyword matching is locale-insensitive case-folding with Unicode normalisation — so a recipient replying stopp or Stopp. matches the same opt-out rule. When a German opt-out fires, the suppression entry it writes is channel-scoped to all, not sms — the same propagation behaviour as the English STOP alias. That means a German STOPP knocks a recipient off SMS, WhatsApp, and RCS simultaneously. This is deliberate: German law treats any of the German-language aliases as a revocation of the UWG opt-in, and the most permissible posture is “stop everything.” The seeded German rules are incomplete only if you have pruned them in the dashboard. Under Messages → SMS → Opt-out Rules, add any missing German variant back — the existing seeded set behaves identically to the canonical German vocabulary per country.

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Posture-FAQ tuple for Germany

When you answer “what does Germany need?” against the Posture FAQ, the DE-specific tuple is:
  • Default quiet-hours window: platform default 21:00–09:00 (fail-open fallback only).
  • Opt-in required before marketing: yes (UWG §7, GDPR-aware).
  • Sender registration level: none (no BNetzA gate, carrier deliverability posture).
  • Opt-out keyword family: German STOPP + verb-form aliases (ABBESTELLEN, ABMELDEN, ENDE, ABBRECHEN).
  • Documentation burden for number purchase: heavy (identity proof, address proof, business document).

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DE launch checklist

Narrowed from the generic launch checklist in Country Compliance Requirements to the DE row:
1

Look up the DE row

Call GET /compliance/country-rules?country=DE and read the DE row’s sender_types, registration, content_restrictions, and stop_requirement.
2

Pick a sender type

Alphanumeric Sender ID (dynamic, no pre-registration) or a long code — both are accepted in DE.
3

Register the Sender ID if deliverability matters

Registration is none — the send-time gate does not block DE on this. Register anyway (compliance/sender-id-registration) if you need stable alphanumeric identity across carriers. BNetzA’s rules on document age (see Documents-KYC) apply only to number purchase, not sender registration.
4

Capture marketing opt-in first

Record a consent entry with sms scope before any DE marketing send; DE is opt-in under UWG §7, not opt-out. See Consent Management and the GDPR posture guide.
5

Handle the German DOI evidence chain

Accept a confirmation step on opt-in for the case-law-grade evidence German courts treat as reliable.
6

Wire the German STOPP family

Confirm the German keyword vocabulary is mapped into the alias table and writes the suppression entry. See Opt-Out Keyword Alias Table.
7

Honor the 21:00–09:00 window deliberately

The platform fallback covers it; set tenant quiet hours if you want an explicit DE marketing window.
8

Launch

With DE enabled, the sender registered, consent captured, DoI handled, STOPP wired, and quiet hours honoured, start sending.