The DSA in Germany: Bundesnetzagentur, JMStV and what applies to adult sites
In Germany, the Federal Network Agency (Bundesnetzagentur) is the Digital Services Coordinator for the EU Digital Services Act. It supervises providers established in Germany and takes complaints. For adult sites, the DSA comes on top of the JMStV, the German law on minors. This page shows how the two fit together and what to put on your site.
Summary of the official sources · checked 14 October 2026 · Not legal advice. · Sources at the end
Applies from17 February 2024 (DSA)
WhoHosting and platform services established in Germany
RuleDSA · Bundesnetzagentur as coordinator
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In short
- The Bundesnetzagentur (BNetzA) is Germany’s Digital Services Coordinator: it supervises providers established in Germany, handles complaints and can impose fines.
- The DSA and the JMStV run side by side. The DSA covers reporting, contacts and terms; the JMStV covers the closed user group for porn, supervised by the KJM.
- Even a small German upload site needs a report form (Art. 16), statements of reasons (Art. 17) and contact points (Art. 11 and 12).
- The DSA's rules mainly concern services that host content from others; the JMStV covers content offered online in Germany, including a site's own content.
Does this apply to your site?
Two laws, two questions: does the DSA reach you, and does the JMStV? Usually both do.
- ✓
Your company is registered in Germany and users upload contentYou are supervised by the Bundesnetzagentur for DSA duties.
- ✓
You offer porn to people in GermanyThe JMStV closed-user-group rule applies, whether or not the DSA does.
- ?
You are based in another EU countryDSA supervision then sits with that country’s coordinator; the German JMStV can still reach your content.
- ?
You publish only studio content you producedProbably not an intermediary under the DSA. The JMStV applies independently of the DSA.
What regulators expect
- Do the JMStV gate first. For porn in Germany, the closed user group is the bigger job: identify once, authenticate each visit. Our German age-check page explains it.
- Put the DSA contacts in your Impressum area. German sites already have an Impressum. Add a DSA block next to it: an authority email with languages (for example German and English) and a user contact answered by a person.
- Add a German report form. Ask for the URL, the reason, name and email and a good-faith statement. Offer it in German, since your users and the authority will use it.
- Write statements of reasons in German. Tell uploaders what you removed, why, and how to complain.
- Update your AGB. Add a section on content rules, moderation and complaints, in plain German.
The Bundesnetzagentur only supervises providers established in Germany. If you are based elsewhere in the EU, your own coordinator does; the duties themselves are the same EU-wide.
What good DSA pages look like in Germany
Impressum · DSA contactdsa@yoursite.de · German, English
Impressum with a DSA block
Your existing legal page, extended with the authority and user contacts.
URL des InhaltsBegründung
Report form in German
“Rechtswidrigen Inhalt melden” with URL, reason and the good-faith checkbox.
18+ · AVS · Report content
Gate and report link together
The report link stays visible on the closed-user-group gate.
How No451 checks your site
We read your Impressum, AGB and contact pages from a German connection and look for the DSA contact points, the content-rules topics and a report form with the Art. 16 elements. We check the JMStV gate separately with our age-check checks.
Should fixMedia listed in a public index (from a related check) Example resultNo stored real DSA result yet, so here is a real one from our age-check checks: a sitemap and media list named 125 media files. We checked 16, and all 16 opened for an anonymous visitor.
The fix: take media out of public listings and protect the files. Every finding shows its evidence like this.
Contact for authoritiesArt. 11: email and languages
Contact for usersArt. 12: reachable by a person
EU representativeArt. 13: if you’re outside the EU
Terms on content rulesArt. 14: moderation and complaints
Notice and actionArt. 16: report form elements
ComplaintsArt. 20: how to object to a decision
Common mistakes
- Thinking the Impressum covers the DSA. The Impressum is German law; Art. 11 and 12 want named DSA contacts with languages.
- Solving the DSA but not the JMStV. A perfect report form doesn’t replace the closed user group for porn.
- English-only report form on a German site. Users and the authority will expect German. Offer both.
- Report link only inside the members’ area. Under the DSA, people outside the closed user group must be able to report too.
Enforcement
The Bundesnetzagentur supervises DSA duties for providers established in Germany, handles complaints and can impose fines. The JMStV duties are supervised separately by the KJM through the state media authorities.
Questions operators ask
Who supervises the DSA in Germany?
The Bundesnetzagentur, as Germany’s Digital Services Coordinator, for providers established in Germany. Very large platforms are supervised by the European Commission.
Does the KJM enforce the DSA?
No. The KJM supervises the JMStV, including the closed user group for porn. DSA duties sit with the Bundesnetzagentur.
My site is in Austria but has German users. Who supervises me?
For the DSA, the coordinator of the country where you are established. German JMStV rules on minors can still apply to content offered in Germany.
Can I combine the Impressum and the DSA page?
Yes. Many sites add a clearly titled DSA section to the Impressum page, with the authority and user contacts and the languages.
Sources
Not legal advice. This page summarises and links to primary sources; it does not tell you what the law requires of your specific site. Related: DSA in the EU · Age checks in Germany · Germany overview
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