22 Apr. IP Address Retention Must Have a Legally Sound and Practicable Framework. VATM Calls for Realistic Deadlines and Technology-Neutral Approach
Berlin, 22. April 2026. The VATM welcomes the draft legislation from the Federal Ministry of Justice on the introduction of an IP address retention requirement in principle. At the same time, VATM sees a need for clarification and adjustment in key areas to ensure that the regulations are technically feasible in practice.
“IP address retention must not create uncertainty once again,” said VATM Managing Director Dr Frederic Ufer. “If companies are required to store IP addresses and the data needed to link them, the requirements must come with realistic deadlines. Without this, the industry risks being burdened again without necessarily achieving any greater effectiveness. This particularly concerns the substantial costs associated with a retention obligation, which cannot simply be passed on to the affected providers.”
From VATM’s perspective, the extremely short implementation deadlines proposed are problematic. Before any deadlines take effect, the necessary technical and regulatory specifications must first be clearly established. The retention obligation itself must also be more clearly defined: only providers that actually assign IP addresses themselves should be required to comply.
“The industry has already borne significant efforts in the past in connection with regulations that ultimately did not endure,” Ufer continued.“This risk must not be repeated. Any new obligations must be designed from the outset to be sustainable over the long term.”
VATM therefore calls on the German government to continue engaging in dialogue with the industry.
