What actually changes when you send OTP, transactional or marketing A2P SMS into Germany — separated into German law, supplier route policy and what we recommend operationally.
A quick operational read on Germany. Anything marked route-dependent is set by the supplier and operator path your traffic uses, and is confirmed during route assessment.
SMS to mobile
Carrier or route policy
Supported
Number format
Law / regulation
+49 followed by the mobile national number without the domestic leading zero; mobile ranges begin 15, 16 or 17
Dynamic alphanumeric senderID
Carrier or route policy
Broadly supported and commonly preserved on quality routes; supplier and account policy may differ, so confirm the exact purchased path
International numeric / longcode senderID
Carrier or route policy
Supported on selected routes, but preservation and reply capability are supplier- and service-dependent
German / local numeric two-way sender
Carrier or route policy
Selected services only — not a universal feature of a generic international A2P route
Dedicated mobile shortcode
Carrier or route policy
Selected operator or aggregator programmes only
Two-way SMS
Carrier or route policy
Available through selected numeric services; provider documentation differs, so do not assume replies on a generic route
Number portability
Law / regulation
Available — current-network lookup required
Concatenation
Carrier or route policy
Generally supported, but sender-type and route-dependent; test the exact path
MMS
Carrier or route policy
Some provider paths convert MMS to an SMS containing a URL
SMS to fixed line
Carrier or route policy
Not supported on standard routes
Marketing
Law / regulation
Prior express consent is the default under UWG §7, subject to the narrow existing-customer exception in §7(3)
GDPR objection
Law / regulation
Direct-marketing processing must stop after an objection, and the right to object must be brought clearly and separately to the recipient’s attention
Last reviewed
Flowstates recommendation
1 August 2026
Route-dependent: “Route-dependent” means the behaviour is decided by the supplier and operator path your traffic takes, not by German statute. Two providers can behave differently on the same day, and a route can change its policy. Confirm before launch.
Law, route policy and recommendation
German statute, supplier route behaviour and our own operating standard are different things. Germany has unusually clear marketing law and unusually varied route behaviour, so every statement on this page is labelled for the team that has to act on it.
Law / regulation
Law and regulation
Binding obligations from German and EU law: §7 of the Act against Unfair Competition (UWG) for promotional electronic mail including SMS and MMS, the GDPR and the Federal Data Protection Act (BDSG) for processing the mobile number, and the Bundesnetzagentur’s administration of German numbering resources. These apply whichever supplier you use.
Carrier or route policy
Carrier or route policy
Rules applied by operators, aggregators or your provider on the specific A2P path your traffic takes — whether an alphanumeric sender is preserved, whether a numeric sender survives, whether replies are possible at all, concatenation behaviour, MMS handling and provider-side filtering of generic sender names. Route-dependent, supplier-specific and subject to change.
Flowstates recommendation
Flowstates operational recommendation
What we ask customers to do because it protects deliverability and keeps you comfortably inside both the law and route policy — demonstrable permission evidence, brand identification in the body, separated templates, branded link domains and recipient-local daytime scheduling.
Numbering and networks
The basics your validation layer and templates need to get right before the first send.
Law / regulationNumber format
German mobile services are reached on national numbers whose prefixes begin (0)15, (0)16 or (0)17. In E.164 the domestic leading zero is removed after +49. The exact national subscriber length varies by allocated range, so do not validate against one universal fixed total length.
Law / regulationDialling code
Country calling code +49. Mobile country code 262.
Law / regulationNumbering administration
The Bundesnetzagentur administers German numbering resources, including the number ranges used for mobile services, so numbering questions are settled against Bundesnetzagentur material rather than provider documentation.
Law / regulationFixed and geographic ranges
Geographic and other non-mobile ranges are outside standard A2P SMS reach. Validate fixed-line destinations out before sending.
Law / regulationNumber portability
Number portability is available in Germany, and subscribers can keep their number when switching provider. The original prefix is therefore not proof of the current network.
Flowstates recommendationPortability handling
Never infer the recipient’s current network from the original prefix. Use live lookup or current-network resolution so routing, reporting and per-operator quality analysis stay accurate.
Carrier or route policyNetworks
The current network operators to plan for are Deutsche Telekom, Vodafone, Telefónica/O2 and 1&1 Mobilfunk. We publish no market-share or coverage claims; per-operator route quality is assessed privately.
Carrier or route policyShortcodes
German mobile short codes are generally four to six digits, and cross-network service normally requires the relevant operator or aggregator arrangement. Availability is confirmed privately, never assumed.
Country code 49, then the mobile national number with the domestic leading zero removed. Subscriber lengths vary by allocated range, so these are masked illustrative patterns only — not real numbers and not a fixed-length rule.
SenderID options
Germany is a market where branded alphanumeric presentation is broadly available, but numeric sender preservation and reply capability are not. Current provider documentation differs: one supplier describes alphanumeric senders, international longcodes and short codes as supported and preserved with two-way messaging available; another states that alphanumeric senders are maintained on its German path without country registration; another supports alphanumeric senders but offers numeric senders only through its selected two-way service and applies its own filtering to generic sender names and selected use cases; another describes standard two-way as unavailable on its ordinary Germany path and notes that short codes may replace sender presentation. Treat sender presentation and replies as route-dependent, and validate the exact purchased service.
Carrier or route policy
This whole comparison — best for, what the recipient sees and replies — describes carrier and route behaviour on current A2P paths into Germany, not German statute. Suppliers document Germany differently, behaviour varies by route and service, and it is validated live before launch rather than guaranteed universally.
Dynamic alphanumeric senderID
Best for
One-way OTP, transactional and permissioned marketing where branded sender presentation is required
What the recipient sees
The submitted brand on supporting routes; exact presentation is confirmed before launch
Replies
No
International numeric / longcode sender
Best for
Selected transactional or service traffic where a numeric identity is needed
What the recipient sees
The submitted international number on supporting paths, or route-specific numeric presentation elsewhere
Replies
Only where the selected service explicitly supports inbound SMS
Provider-assigned German / local two-way sender
Best for
Support, service and conversational use cases
What the recipient sees
A German numeric sender assigned to the configured service
Replies
Yes — only on the expressly configured two-way service
Dedicated mobile shortcode
Best for
Selected scale programmes requiring a stable, recognisable numeric identity
What the recipient sees
The approved four- to six-digit shortcode where the operator or aggregator programme is live
Replies
Programme- and operator-dependent
SenderID options
Option
Best for
What the recipient sees
Replies
Dynamic alphanumeric senderID
One-way OTP, transactional and permissioned marketing where branded sender presentation is required
The submitted brand on supporting routes; exact presentation is confirmed before launch
No
International numeric / longcode sender
Selected transactional or service traffic where a numeric identity is needed
The submitted international number on supporting paths, or route-specific numeric presentation elsewhere
Only where the selected service explicitly supports inbound SMS
Provider-assigned German / local two-way sender
Support, service and conversational use cases
A German numeric sender assigned to the configured service
Yes — only on the expressly configured two-way service
Dedicated mobile shortcode
Selected scale programmes requiring a stable, recognisable numeric identity
The approved four- to six-digit shortcode where the operator or aggregator programme is live
Programme- and operator-dependent
Put a recognisable brand and the purpose in the message body even when an alphanumeric sender is expected to survive, because presentation can change with the route. Generic sender identifiers may be filtered on some supplier paths, so we recommend a recognisable brand — that is route policy and a Flowstates recommendation, not German law. A supplier may require sender or account verification, or a selected service arrangement, before a given sender type is usable. Never promise a reply path simply because two-way services exist in Germany.
What changes by traffic type
Germany is not one rulebook. The same destination behaves differently depending on the category you send and the route it takes.
OTP / authentication
Suitable on validated high-quality routes.
Flowstates recommendation
Keep the copy purely transactional and concise, preferably within a single segment.
Flowstates recommendation
Put the brand in the message body even when an alphanumeric sender is expected to be preserved.
Flowstates recommendation
No promotional content in OTP templates.
Flowstates recommendation
Use a branded domain for any link and avoid ambiguous link text.
Flowstates recommendation
Monitor delivery, latency, completed-verification conversion and current-network and route performance.
Flowstates recommendation
Configure carrier-grade failover so a degraded path does not become a failed login queue.
Carrier or route policy
Do not depend on replies unless a two-way numeric service is explicitly configured on the purchased route.
Transactional / service
Suitable for alerts, confirmations, appointments and account or service updates.
Flowstates recommendation
Identify the sending brand and state the purpose of the message.
Flowstates recommendation
Use a branded domain for links rather than a public or shared shortener.
Flowstates recommendation
Keep promotional copy out of transactional templates.
Flowstates recommendation
Test the final German copy and concatenation behaviour on the exact route before relying on either.
Carrier or route policy
Enable replies only on an explicitly configured two-way service.
Law / regulation
Do not relabel marketing as transactional to avoid the consent requirements in UWG §7. The category follows the content and purpose, not the template name.
Marketing / promotional
Prior express consent by default, identifiable advertising, a simple way to stop and prompt suppression.
Law / regulation
SMS counts as electronic mail for the purposes of UWG §7, so the channel-specific advertising rule applies to SMS and MMS.
Law / regulation
Prior express consent is the default under §7(2) for promotional messages sent by electronic mail.
Law / regulation
The §7(3) existing-customer exception is narrow and cumulative: the address was obtained in connection with a sale, the advertising concerns the trader’s own similar goods or services, the customer has not objected, and the customer is clearly informed at collection and at every use that they can object at any time without incurring more than the base transmission cost.
Law / regulation
A generic GDPR legitimate-interest assessment does not replace or bypass the channel permission rule in UWG §7.
Flowstates recommendation
Consent must be specific and demonstrable. We ask for timestamped, source-attributed permission records and recommend double opt-in as our evidence standard — not as a claim that the statutory text mandates double opt-in in every case.
Flowstates recommendation
Do not use bought or rented lists.
Law / regulation
Do not conceal or obscure the identity of the sender on whose behalf the message is sent.
Law / regulation
Every promotional message needs a valid, straightforward route to stop future messages without more than the base transmission cost.
Flowstates recommendation
Support natural German opt-out requests such as STOP, ABMELDEN, WIDERRUF and NEIN. No single keyword is universally mandated by statute, so recognise the intent rather than one exact word.
Flowstates recommendation
Suppress promptly and across every sending system, including any separate campaign or CRM tooling.
Flowstates recommendation
Schedule promotional traffic in Germany recipient-local daytime hours. This is our recommendation, not a German statutory SMS-hours window; a stricter route policy is applied privately where a supplier requires it.
Germany’s SMS marketing, GDPR and objection rules
Germany separates two questions that are often confused: whether you are allowed to use this channel for advertising at all, and whether you are allowed to process the personal data behind it. UWG §7 answers the first, the GDPR and BDSG answer the second, and you need both.
Law / regulation
UWG §7 is the channel-specific rule for unacceptable nuisance advertising and covers promotional electronic mail. German case law confirms that electronic mail includes email, SMS and MMS, so promotional SMS falls squarely inside it.
Law / regulation
Prior express consent is the default for promotional electronic mail under §7(2).
Law / regulation
§7(3) is a narrow existing-customer exception. All four conditions must be met together: the trader obtained the address in connection with the sale of goods or services, the advertising relates to the trader’s own similar goods or services, the customer has not objected to the use, and the customer is clearly and unambiguously informed at collection and at every use that they may object at any time without incurring costs beyond the base transmission cost.
Law / regulation
§7 also prohibits concealing or obscuring the identity of the sender on whose behalf the advertising is sent, and requires a valid address or channel through which the recipient can request that the messages stop, without more than base transmission cost.
Law / regulation
The GDPR and the BDSG separately govern the processing of the mobile number and related data. Record an Article 6 lawful basis for each processing purpose and comply with transparency, purpose limitation, data minimisation, security and retention duties.
Law / regulation
GDPR Recital 47 recognises that direct marketing may be a legitimate interest, but that does not override the more specific channel permission rule in UWG §7. Passing the GDPR test does not make an unconsented promotional SMS lawful.
Law / regulation
Under GDPR Article 21 the recipient can object at any time to processing for direct-marketing purposes, and processing for that purpose must then stop. The right to object must be brought to the recipient’s attention explicitly and separately from other information, no later than at the time of the first direct-marketing communication.
Flowstates recommendation
Keep OTP and service purposes strictly separate from marketing purposes, with separate templates, separate permission records and separate suppression handling.
Law / regulation
Germany has both federal and Land-level data-protection authorities. The BfDI supervises telecommunications providers for processing connected with providing telecommunications services, while most other private-sector businesses are generally supervised by the competent Land authority. The BfDI is not the universal regulator for every advertiser.
Flowstates recommendation
Retain the privacy notice version shown, the lawful basis, the consent or §7(3) analysis, permission evidence, objection and withdrawal records, suppression evidence, templates, campaign records and processing records for as long as you may need to demonstrate compliance.
Operational compliance checklist
The controls we expect to see in place before Germany traffic goes live, and the records we expect you to be able to produce afterwards.
Law / regulation
Record the source, Article 6 lawful basis, purpose and permitted use of every recipient record.
Law / regulation
Provide clear privacy information to recipients and retain the version that was shown.
Law / regulation
For marketing, retain the recipient, timestamp, source, exact consent wording and version, purpose and SMS-channel scope. Where you rely on the §7(3) existing-customer exception, document all four conditions.
Law / regulation
Identify the sending brand and the purpose in every message.
Law / regulation
Do not conceal or obscure the sender’s identity.
Law / regulation
Provide a working, simple stop method that costs the recipient no more than the base transmission cost.
Flowstates recommendation
Support STOP, ABMELDEN, WIDERRUF and NEIN without claiming any universal statutory keyword, and recognise plain-language stop requests.
Law / regulation
Suppress promptly across every sending system and retain the objection and withdrawal evidence.
Flowstates recommendation
Do not use bought or rented lists.
Flowstates recommendation
Schedule sending by Germany recipient-local daytime hours.
Flowstates recommendation
Keep OTP, transactional/service and marketing templates separate.
Flowstates recommendation
Use branded short domains rather than public or shared shorteners.
Carrier or route policy
Validate the exact senderID, current-network path, use case and route before launch.
Carrier or route policy
Confirm two-way capability, concatenation behaviour, shortcode availability and category acceptance privately on the selected service.
Carrier or route policy
Run a current-network lookup, because portability is active and the prefix does not identify the current operator.
Flowstates recommendation
Keep template, privacy, lawful-basis, consent and exception, opt-out, campaign, suppression and route-approval records.
Encoding and delivery
Segment maths and German-language pitfalls, plus what to test on the live route before launch.
German text does not automatically require UCS-2, but smart quotation marks, long dashes, emoji, uncommon symbols and pasted formatting can silently change the encoding. Inspect the actual encoded template rather than the draft in a document.
Flowstates recommendation
Test the final German copy end to end across the purchased Deutsche Telekom, Vodafone, Telefónica/O2 and 1&1 paths.
Flowstates recommendation
Keep OTP messages within a single segment wherever practical.
Law / regulation
Remove the domestic leading zero after +49, and remember that subscriber lengths vary by allocated range, so a single fixed-length check will reject valid numbers.
Flowstates recommendation
Validate mobile versus fixed destinations and resolve the current network before sending.
Law / regulation
Portability means the original prefix is not proof of the current operator.
Carrier or route policy
Some provider paths convert MMS into an SMS containing a URL. That is route policy, not a German legal requirement.
A country guide is only useful when the route follows it.
Country rules only help if the route your traffic actually takes respects them. That is the part we operate.
Per-country and per-category routing
Multi-vendor routing decided per country and per traffic category, so OTP, service and marketing traffic do not share one compromise route into Germany.
SenderID management
We manage sender presentation per route and per category, and validate what the recipient actually sees before launch rather than after the first complaint.
Carrier-grade failover
Automatic failover between vendors so a degraded German path does not become a queue of failed logins.
Per-route visibility
Delivery, latency and OTP-conversion visibility per route, so a quality change on one operator path is visible while it is still small.
24/7 vendor escalation
We chase the vendor. Escalation runs around the clock rather than waiting for a support queue in another time zone.
BYOV / BYOG
Bring your own vendors or gateway and keep your commercial relationships while we operate the routing, sender policy and monitoring.
Branded short links
Branded short domains instead of public shorteners, so German recipients see a link that matches the sender they trust.
A quick operational read on Germany. Anything marked route-dependent is set by the supplier and operator path your traffic uses, and is confirmed during route assessment. SMS to mobile: Supported. Number format: +49 followed by the mobile national number without the domestic leading zero; mobile ranges begin 15, 16 or 17. Dynamic alphanumeric senderID: Broadly supported and commonly preserved on quality routes; supplier and account policy may differ, so confirm the exact purchased path. International numeric / longcode senderID: Supported on selected routes, but preservation and reply capability are supplier- and service-dependent.
Which sender ID options work for SMS in Germany?
Germany is a market where branded alphanumeric presentation is broadly available, but numeric sender preservation and reply capability are not. Dynamic alphanumeric senderID — Best for: One-way OTP, transactional and permissioned marketing where branded sender presentation is required. International numeric / longcode sender — Best for: Selected transactional or service traffic where a numeric identity is needed. Provider-assigned German / local two-way sender — Best for: Support, service and conversational use cases. Dedicated mobile shortcode — Best for: Selected scale programmes requiring a stable, recognisable numeric identity.
What are the consent and opt-out requirements for SMS in Germany?
Germany separates two questions that are often confused: whether you are allowed to use this channel for advertising at all, and whether you are allowed to process the personal data behind it. UWG §7 is the channel-specific rule for unacceptable nuisance advertising and covers promotional electronic mail. German case law confirms that electronic mail includes email, SMS and MMS, so promotional SMS falls squarely inside it. Prior express consent is the default for promotional electronic mail under §7(2). §7(3) is a narrow existing-customer exception. All four conditions must be met together: the trader obtained the address in connection with the sale of goods or services, the advertising relates to the trader’s own similar goods or services, the customer has not objected to the use, and the customer is clearly and unambiguously informed at collection and at every use that they may object at any time without incurring costs beyond the base transmission cost.
How many characters fit in an SMS to Germany?
Segment maths and German-language pitfalls, plus what to test on the live route before launch. GSM-7 single segment: Normally 160 characters. GSM-7 concatenated: Normally 153 characters per segment. Unicode / UCS-2 single segment: Normally 70 characters. Unicode / UCS-2 concatenated: Normally 67 characters per segment.
Sources and change control
Official German and EU sources control the law, numbering, operators, portability and authority wording. Provider sources describe only their own current route or service. Where providers differ, we expose the uncertainty instead of picking a favourite.
Describes alphanumeric, longcode and shortcode sender support with preservation, two-way availability, concatenation with sender-type caveats, MMS converted to SMS with a URL, and no landline SMS. Its own route only.
Entry point for German number ranges and their administration. Mobile short codes are generally four to six digits and cross-network service normally requires the relevant operator or aggregator arrangement.
Explains that the BfDI supervises telecommunications providers for telecom-service processing, while most other private businesses fall to the competent Land authority.
Describes alphanumeric sender support with numeric senders only through its selected two-way service, plus provider-specific filtering of generic sender names and selected use cases.
Describes alphanumeric and numeric sender support with standard two-way unavailable on that path, notes that short codes may replace sender presentation, and marks concatenation supported.
Advertises one-way alphanumeric coverage into Germany and applies supplier-specific verification and route controls.
Change log
1 August 2026 — Initial draft; separated German marketing and GDPR obligations from sender presentation, two-way service availability and other route-dependent behaviour.
Last reviewed 1 August 2026
Disclaimer
This page is operational guidance, not legal advice. Requirements vary by operator, route, senderID, traffic category, purpose, sector and customer setup, and they change. Flowstates confirms the live path with you during onboarding, and you should take your own legal advice on German marketing and data-protection obligations.
