Impressum & data protection for a physiotherapy practice in Germany: all mandatory details

The Impressum under § 5 DDG

Since May 2024, the Digitale-Dienste-Gesetz (DDG, Digital Services Act) has governed the Impressum obligation. The information must be “easily recognisable, directly accessible and permanently available” – in other words, an “Impressum” link in the footer of every page. For a physiotherapy practice, this means:

The details for medical practices with a medical chamber and Kassenärztliche Vereinigung are in the Impressum guide for doctors; those for psychotherapists are in the guide for psychotherapy practices and those for psychologists in the guide for psychology practices.

Professional title, licence and MPhG

Physiotherapy is a regulated profession: anyone who calls themselves “Physiotherapeutin” or “Physiotherapeut” needs a state licence under § 1 MPhG (the Masseurs and Physiotherapists Act). This gives rise to the professional details under § 5 Abs. 1 Nr. 5 DDG:

• Statutory professional title: “Physiotherapeutin” or “Physiotherapeut” (female/male physiotherapist) – exactly as it appears on your licence certificate. A bachelor’s or master’s degree does not replace the professional title.
• Awarding country: usually “Bundesrepublik Deutschland” (Federal Republic of Germany). If you trained abroad and had your qualification recognised in Germany, name the licence you were granted in Germany.
• Chamber: not applicable. There is no chamber for physiotherapists in any federal state – so don’t write “Chamber: none”, simply leave the line out.
• Professional regulations: “Masseur- und Physiotherapeutengesetz (MPhG) und Ausbildungs- und Prüfungsverordnung für Physiotherapeuten (PhysTh-APrV)” (the act and the training and examination regulations) with a link to gesetze-im-internet.de.
• Professional association (voluntary): you can name a membership of PHYSIO-DEUTSCHLAND, VPT, IFK or VDB; it is not mandatory.

Supervisory authority: Gesundheitsamt, licensing authority or none?

§ 5 Abs. 1 Nr. 3 DDG only requires the supervisory authority if your activity needs official authorisation. For physiotherapists, this is not clear-cut: the licence under the MPhG protects the professional title, and approval to treat statutory health insurance patients under § 124 SGB V is granted by the regional associations of the health insurers – that is not a supervisory authority within the meaning of the DDG. We are not aware of any court ruling specifically on physiotherapy Impressums.

• Pragmatic solution: name the Gesundheitsamt where your practice is located, which in many federal states supervises the health professions. An additional, correct detail does no harm – a missing mandatory detail does.
• Licensing authority: alternatively or additionally, you can name the state authority that granted your licence (depending on the state, e.g. a Landesamt, Regierungspräsidium or Bezirksregierung).
• Not needed: IK-Nummer, the health insurers’ approval number or the working group (Arbeitsgemeinschaft) that granted your insurance approval.

Special case: sectoral Heilpraktiker licence

Since a 2009 ruling by the Federal Administrative Court (3 C 19.08), physiotherapists can obtain a Heilpraktiker licence (non-medical practitioner licence) limited to physiotherapy and treat patients without a medical prescription. In that case, the Heilpraktikergesetz (HeilprG, Non-Medical Practitioners Act) also applies, and the licence is clearly an official authorisation. In this case, your Impressum must include:

• the professional title as stated in the licence, e.g. “Heilpraktikerin, beschränkt auf das Gebiet der Physiotherapie” (non-medical practitioner, limited to the field of physiotherapy), alongside “Physiotherapeutin”
• the authority that granted the licence, usually the Gesundheitsamt or the city or district administration, as the supervisory authority
• the Heilpraktikergesetz and the MPhG as professional regulations

Liability insurance, blog, dispute resolution: the additional details

• Professional liability insurance (§ 2 Abs. 1 Nr. 11 DL-InfoV, the Services Information Regulation): if you have professional liability insurance – and as a practice owner you practically always do –, state the name and address of the insurer and the territorial scope (e.g. “Germany” or “EU”). The website is the simplest place for this.
• Blog or advice section (§ 18 Abs. 2 MStV, the Interstate Media Treaty): if you regularly write posts, for example about back training or sports injuries, name a responsible person with name and address. A plain presentation of the practice doesn’t need this.
• Consumer dispute resolution (§ 36 VSBG): if your practice employed more than ten people on 31 December of the previous year – not unusual in physiotherapy practices with several therapists and a reception –, you must state whether you take part in arbitration proceedings. The usual sentence is: “Wir sind nicht bereit oder verpflichtet, an Streitbeilegungsverfahren vor einer Verbraucherschlichtungsstelle teilzunehmen.” (We are neither willing nor obliged to take part in dispute resolution proceedings before a consumer arbitration board.)
• ODR platform: the EU platform for online dispute resolution was shut down on 20 July 2025 (Regulation (EU) 2024/3228). You can delete the link.

Data protection: Heilmittelverordnungen, forms and online booking

Your website needs a privacy policy under Art. 13 GDPR, if only because of the server logs. It gets tricky when patients send a photo of their Heilmittelverordnung, a surgical report or a description of their pain: that is health data under Art. 9 GDPR. You may process it for treatment (Art. 9 Abs. 2 lit. h GDPR, § 22 BDSG, the Federal Data Protection Act), and as a physiotherapist you are bound by professional secrecy under § 203 StGB (Criminal Code).

Under § 38 BDSG, you generally only need a data protection officer once at least 20 people are regularly involved in the automated processing of personal data – or if a data protection impact assessment is required.

Cookies, maps and exercise videos

For cookies and comparable technologies, § 25 TDDDG (the Telecommunications Digital Services Data Protection Act) applies: access to the user’s device only with consent, unless it is strictly necessary for the service explicitly requested. On physiotherapy websites, this mainly concerns embedded exercise videos from YouTube or Vimeo, Google Maps, externally loaded fonts and analytics tools. Load videos and maps only after a click, serve fonts from your own server and use cookieless analytics – then you can often do without a banner altogether.

Accessibility under the BFSG

Since 28 June 2025, the Barrierefreiheitsstärkungsgesetz (BFSG, the German Accessibility Strengthening Act) has been in force. It covers “services in electronic commerce”, i.e. online offers aimed at concluding a consumer contract. Whether online appointment booking at a physiotherapy practice falls under this has not been conclusively settled; a purely informational website probably does not.

For most practices, § 3 Abs. 3 BFSG decides the matter anyway: micro-enterprises that offer services are exempt – that is, businesses with fewer than ten employees and an annual turnover or balance sheet total of no more than €2 million. Larger practices with online booking should have the question checked. An accessible website makes sense in any case: your patients are often older, have just had surgery or have limited mobility.

Photos and videos with patients

A video with a real patient shows not only her face, but also the fact that she is being treated by you. This means that the right to one’s own image (§ 22 KUG, the Art Copyright Act), the GDPR and your duty of confidentiality all apply at the same time. So obtain written consent that states the purpose (website, Instagram), the duration and the right to withdraw, and that explicitly releases you from your duty of confidentiality. Without consent, stick to team photos, models or shots in which nobody can be recognised. What the Heilmittelwerbegesetz (HWG, Therapeutic Products Advertising Act) allows for before-and-after pictures and success stories is covered in the guide to physiotherapy advertising.

Checklist for your physiotherapy website