If you sell to customers in Germany online, the Impressum contact requirements are short but strict: details that allow fast electronic contact and direct communication, including an email address. Can a form or live chat replace a phone number? Email is always required, and the second fast channel must work in practice, not just appear on the page.
This guide is a practical explanation, not legal advice. It covers the statute, the EU court ruling and how to set up chat or callbacks your team can staff. For the layout of the whole page, see our guide to the contact page.
What Section 5 DDG requires
Since 14 May 2024, the German Impressum duty has been set out in Section 5 of the Digitale-Dienste-Gesetz (DDG), which replaced the former Section 5 TMG. It applies to providers of commercial digital services that are usually offered for payment. The details must be easy to recognise, directly reachable and always available. Alongside the name, registered address and authorised representative, point 2 requires information that enables fast electronic contact and direct communication, including an email address.
The text of Section 5 DDG on gesetze-im-internet.de names email as a mandatory element. It names no other channel: phone, form and chat are not mentioned.
The word "including" matters: email is the minimum, not the whole requirement. So the question is not whether chat can replace email, but what to add to email so contact is fast. Austria has its own basis: Section 5(1)(3) of the E-Commerce-Gesetz (ECG) requires details that let users get in touch quickly and directly, including an email address. If you target Austria, check the current ECG text in the RIS database.
What the CJEU said about contact forms
The key ruling is the CJEU judgment of 16 October 2008 in case C-298/07. An online-only insurer listed a postal address and email and took questions through a form answered by email; only contract holders got a phone number, and the Federation of German Consumer Organisations (Bundesverband der Verbraucherzentralen) demanded one for everyone. The Court held that, in addition to email, a provider must offer another route for rapid, direct and effective contact, but that route does not have to be a phone.
A form answered by email can therefore be the second channel. The exception: if a customer loses network access after the first electronic contact, for example while travelling, and asks for a non-electronic channel, the provider must offer one. The Court also noted that the form enquiries in that case were answered within 30 to 60 minutes.
Judgment C-298/07 on EUR-Lex confirms that a form can be the second channel next to email and that a phone number is not strictly required. It sets no statutory reply time: 30 to 60 minutes was a fact of that case, not a rule.
Form, chat, callback and phone: what role each plays
The table sorts channels by role. It is not a compliant/non-compliant list: that depends on how each channel works in practice.
Scroll the table sideways to see all columns.
| Channel | Role in the Impressum | Watch out for |
|---|---|---|
| Mandatory in every case | The inbox must be read, not just receive messages | |
| Contact form | Can be the second channel next to email | Reply time counts, not the submit button |
| Website chat | Can supplement email during staffed hours | Outside the schedule it is not fast contact |
| Callback request | A supplement that also offers non-electronic contact | Time slots must come from a real schedule |
| Phone | The simplest second route and the answer to an offline request | A number nobody answers hurts as much as having none |
That is why you should list chat or a form in the Impressum as an addition to email, never instead of it. German chambers of commerce, such as IHK Nuremberg, list both a phone number and an email address in their Impressum guidance. That is the cautious route, though the CJEU does not strictly require a phone. Form fields and copy are covered in our guide to contact forms.
What "fast" means in practice
Neither Section 5 DDG nor the CJEU ruling gives a number of minutes to meet. A form that replies after three days is hard to call fast. The safer assumption is that during staffed hours the second channel replies at the pace of a conversation, not of correspondence.
- The second channel shows its staffed hours in the Impressum or right next to the channel.
- A named person covers every hour in the schedule, including holiday periods.
- Outside those hours the channel says honestly when a reply will come and still accepts a message.
- Once a month you check the actual reply time, not just the promise.
Set the reply promise like any support target, as described in our guide to a customer support SLA. Ready-made copy for evenings and weekends is in the guide to after-hours enquiries.
How to turn chat or callbacks into a working second channel
A fictional example: a joinery workshop in Poznan sells made-to-measure furniture to Germany. Its Impressum lists an address, an email and a note about chat on weekdays from 9 to 4. But the chat is always on, and one person replies when free. A customer in Munich writes at 3:30 pm and hears back the next day. The channel exists but breaks the Impressum promise.
- Set the channel schedule.Enter the hours when someone really answers chat and assign specific people to them.
- Tie status to the schedule.Outside the schedule, chat should switch to offline mode instead of pretending someone is there.
- Add a non-electronic route.A phone line or a callback request covers the customer who asks for contact outside the network.
- Describe channels in the Impressum.List email, the second channel and the staffed hours in the same form as on your contact page.
- Measure reply time.Compare the actual first reply time with the hours you promise in the Impressum.
In the Meetlead widget, an agent counts as available only with the panel open and within their schedule for that website. When nobody is available, the widget switches to offline mode and visitors can leave a message through the offline form. With the Phone / Callback app active, callback requests offer slots calculated from the team schedule, and accepting them out of hours is a separate setting. The inbox shows how long the first unanswered message has been waiting, and the first-response report takes working hours into account. Meetlead does not write your Impressum or assess its legal compliance; callback design is covered in our guide to website callbacks.
Contact: email [address] · phone [number], Mon–Fri 9 am–4 pm Central European Time · chat on this website, Mon–Fri 9 am–4 pm. Outside these hours we reply on the next working day. Repeat the same details in German on your German pages.
Selling to Germany: the Impressum is not the only duty
Businesses outside Germany often run one site with a German version. The Impressum, usually linked in every footer, should list the same contact details as the contact page and the widget. Different hours in three places suggest that no channel works.
Pre-contract information for distance contracts with consumers is a separate matter. Article 246a Section 1 EGBGB lists the trader's phone number and email address among it, along with other means of communication provided that let the customer keep the correspondence. This consumer duty is separate from the Impressum, and chat does not replace it.
Article 246a Section 1 EGBGB on gesetze-im-internet.de lists phone, email and other means of communication among the consumer information for distance contracts. It says nothing about the Impressum or reply speed.
Questions about Impressum contact details
Is chat alone enough instead of email? No. Section 5 DDG explicitly requires an email address, and chat can at most be the second channel next to it. Even then, it must reply fast during the stated hours. This text is not legal advice; for a disputed case, consult a lawyer familiar with German law.
Do I have to list a phone number in the Impressum? According to the 2008 CJEU ruling, a phone number is not strictly required if another channel provides fast and effective contact. But a customer who loses network access after electronic contact and asks for another route must get a non-electronic one. If you list a number, keep its answering hours.
