16 Juni Conference of Interior Ministers on IP Address Retention: VATM Warns Against New Obligations Without Clear Rules, Realistic Timelines and Fair Cost Reimbursement
Berlin, 16 June 2026. VATM is calling on Germany’s federal state interior ministers to focus on clear rules and realistic implementation timelines for the planned statutory IP address retention regime at the Interior Ministers’ Conference, which begins tomorrow. “Effective law enforcement in the digital environment is important,” said VATM Managing Director Dr Frederic Ufer. “However, it must not be based on requirements that are impossible to implement within the proposed timelines, legally uncertain or economically unsustainable for businesses. Anyone seeking greater security must also ensure legal certainty.”
According to VATM, the draft legislation on IP address retention still requires substantial revision. The federal states should not allow companies to be required to make investments before it is even clear what the final technical requirements will be. Otherwise, there is a risk of creating yet another law that generates significant costs but proves unworkable in practice.
VATM considers the proposed six-month implementation period to be particularly unrealistic. New data retention obligations require far-reaching changes to network infrastructure, IT systems and internal business processes. Meaningful implementation can only begin once all legal and technical requirements have been definitively established.
The association is also critical of the proposal that certain obligations should take effect immediately upon the law’s entry into force. This applies in particular to preservation orders. Companies that are not already subject to the European e-Evidence Regulation should be granted specific transitional periods to allow for implementation.
VATM further argues that the legislation should apply only to providers that actually assign dynamic IP addresses themselves and for whom data retention is necessary to support subsequent investigations. “Providers that do not assign IP addresses themselves, or that primarily use fixed IP addresses in the business customer segment, should not be forced into a process that is unnecessary and disproportionate for their operations,” said Ufer. “Security policy must reflect the technical realities of modern communications networks.”
The association is also calling for fair reimbursement of costs. Compensation rates should not be reduced. The administrative and technical effort involved in storing, reviewing, documenting and securely providing retained data remains substantial, even where a measure is extended.
VATM also cautions against considering IP address retention in isolation. When combined with preservation orders and European regulatory frameworks, new datasets may be created that could potentially be accessed by authorities in other EU Member States. The federal states should also take these security-related and geopolitical implications into account.
“The telecommunications sector is ready to play its part,” Ufer emphasised. “However, Germany does not need another law that creates significant costs only to fail later due to legal or practical shortcomings. Any new obligations must be legally robust, technically feasible and fairly funded. Only then can they provide sustainable support for law enforcement authorities.”
