A German statute that governs data protection for telecommunications and digital services, the law was known as the Telekommunikation-Telemedien-Datenschutz-Gesetz (TTDSG) from December 2021 until May 2024. In May 2024, it was renamed the Telekommunikation-Telemedien-Datenschutz-Gesetz (TDGG), but the old name still appears throughout compliance documentation, vendor privacy pages, and consent-tool settings. The law is best known for Section 25, which carries the EU ePrivacy cookie-consent requirement into German law.
Key Provisions
The TTDSG regulates two main areas: terminal-equipment access and telecommunications privacy. Section 25 requires informed consent for storing or reading any information on a user’s device (cookies, local storage, device fingerprinting inputs) unless strictly necessary for the service the user requested. This provision applies regardless of whether personal data is involved and is the German implementation of the EU ePrivacy rule.
Relationship with the GDPR
The TTDSG governs access to the device, while the General Data Protection Regulation (GDPR) governs any processing of the personal data collected. This means that two consent analyses may be required: one for device access under the TTDSG and another for data processing under the GDPR.
Rename to TDGG
The 2024 rename followed the EU’s Digital Services Act (DSA). Germany replaced its Telemedia Act with a new Digital Services law, and the privacy statute’s name changed with it: Telemedien became Digitale Dienste. The substance marketers care about, including the Section 25 consent rule, carried over intact.
Ongoing Relevance
Analytics and consent vendors still advertise TTDSG compliance, German regulators’ enforcement history references it, and audits of cookie banners in the German market are judged against its standard. Anyone running a Consent Management Platform (CMP) for German traffic is, in practice, configuring it to satisfy this rule, whichever of the law’s two names appears in the documentation.
