People looking for a medical practice rarely look for inspiration. They look for a phone number, an opening time, an answer to whether this practice is the right one at all, and a hint about whether they can get in with a walker or a pushchair. At the same time, a practice website is the one business presence where three sets of rules speak at once: German pharmaceutical advertising law (Heilmittelwerbegesetz, HWG), the professional code of the relevant chamber, and data protection law with its special category of health data. Two mistakes follow from this, and they feed each other. Either the site says too much — promised outcomes, before-and-after photos, collected thank-you letters — or caution leaves it saying too little, so patients have to call to learn the obvious. This article sorts out what a practice page must state, what it may state, and what is better left out. It is deliberately specific to the health professions: not a general introduction to accessibility or data protection, but the exact points where medical, dental, physiotherapy, occupational therapy and alternative practitioner websites have to work differently from a tradesperson's site.
A practice page is not a shop window
Outpatient care in Germany is both large and highly fragmented. 191,875 (KBV, physician statistics 2025) doctors and psychotherapists take part in statutory outpatient care, an increase of 1.2 percent (KBV, physician statistics 2025) over the previous year. Just under 56,000 (KBV, physician statistics 2025) of them work in general practice. Around 130,000 (KBV, physician statistics 2025) are practice owners, a good 60,000 (KBV, physician statistics 2025) are employed, and more than 70,000 (KBV, physician statistics 2025) work part-time. The average age is 53.9 years (KBV, physician statistics 2025). Behind every one of those numbers sits an organisation that has to communicate hours, cover arrangements and availability — usually without a marketing department.
Patient behaviour has shifted in parallel. 64 percent (Bitkom) of people in Germany have booked a doctor's appointment online at least once; in 2024 the figure was 50 percent (Bitkom), in 2023 only 36 percent (Bitkom). Just 18 percent (Bitkom) reject digital booking outright. The survey covered 1,145 (Bitkom) people aged 16 and over. The expectation of settling organisational matters without a phone call has arrived in daily life — and it meets a website that often still consists of one photo and an address.
Am I in the right place?
Specialty, focus areas, age groups, statutory or private treatment. If that is not clear within seconds, people either call or move on — and both cost the practice time.
When can I reach someone?
Consulting hours as text, plus phone hours, holidays and cover. A time that is wrong on a public holiday produces exactly the calls it was meant to avoid.
How do I get in?
Steps, lift, door widths, parking, a doorbell at reachable height. These details belong on the page, because otherwise each one has to be asked for on the phone.
Orientation, not legal advice
What the page must state
The baseline is the same for every commercially offered website and has been set out in the Digital Services Act (Digitale-Dienste-Gesetz, DDG) since 2024. Under Section 5 DDG, name and address, details enabling rapid electronic contact including an email address, and the VAT identification number must be kept easily recognisable, directly accessible and permanently available. Health professions add two items that other sectors rarely need: Section 5 paragraph 1 number 3 DDG requires details of the competent supervisory authority where the activity requires official authorisation, and number 5 requires, for regulated professions, the chamber one belongs to, the statutory professional title and the state in which it was awarded, plus the designation of the professional rules and how they can be accessed.
- Name, practice address and, for legal entities, legal form and authorised representatives
- Phone number and email address for direct communication
- Statutory professional title and the state in which it was awarded
- Responsible chamber or the competent supervisory authority
- Designation of the professional rules with a note on where they can be found
- VAT identification number, where one exists
The wording sounds cumbersome, but it is quickly done once set up properly: professional title, awarding state, chamber, supervision, source of the professional rules. That last item is where many imprints fail, because they name a professional code without saying where the text can be found. How a complete imprint and a matching privacy notice are structured is covered in the article on imprint and privacy policy as legal requirements; the health-profession addition is the two items named above.
| Profession | Chamber and supervision | What else applies |
|---|---|---|
| Physicians | State medical chamber, supervision varies by state | Professional code based on the model code (MBO-Ä), plus duties towards the regional association of statutory health insurance physicians |
| Dentists | State dental chamber | Own professional code, largely parallel in structure to the medical rules |
| Psychotherapists | State chamber of psychotherapists | Own professional code; particularly sensitive content, so case examples call for restraint |
| Physiotherapy, occupational therapy, speech therapy | No chamber in most federal states | No chamber entry, but fully within the scope of advertising law for health services and of competition law |
| Alternative practitioners (Heilpraktiker) | Licence under the Heilpraktikergesetz, supervision by the public health office | Name the licensing authority as supervision; advertising claims face a strict test for misleading statements |
The practice sign as a template for the home page
The limits of health advertising law
The Heilmittelwerbegesetz does not cover medicinal products alone. Under Section 1 paragraph 1 number 2 it also covers other agents, procedures, treatments and objects where the advertising statement relates to detecting, removing or alleviating illnesses, ailments, physical damage or pathological complaints in humans, and expressly covers surgical cosmetic procedures altering the human body without medical necessity (Heilmittelwerbegesetz). That makes almost every sentence on a practice page describing an effect an advertising statement under this law — even when it is meant factually.
The central limit sits in Section 3 HWG: misleading advertising is prohibited. Misleading occurs in particular where procedures or treatments are attributed a therapeutic effect they do not have, or where the false impression is created that success can be expected with certainty or that no harmful effects occur with intended or prolonged use (Heilmittelwerbegesetz). The second point matters most in practice: the question is not whether a treatment works, but whether the text suggests that success is certain.
- Statements presenting a particular outcome as certain, such as "permanently pain-free" or "full restoration"
- Efficacy claims without a solid basis, especially for procedures outside the statutory catalogue
- The impression that a treatment has no adverse effects, simply because risks are not mentioned
- Untrue or deceptive statements about the training, capability or successes of the people treating
For before-and-after images there is an explicit rule, and it is narrower than many practices assume. Section 11 paragraph 1 sentence 3 HWG provides that for the surgical cosmetic procedures named in Section 1 paragraph 1 number 2 letter c, advertising may not present the effect of such treatment through a comparative depiction of the physical condition or appearance before and after the procedure; the same applies to advertising aimed exclusively or predominantly at children and adolescents (Heilmittelwerbegesetz). The prohibition therefore hits aesthetic surgery without medical necessity directly.
Before-and-after outside aesthetic surgery
A second limit is often overlooked and concerns particular conditions. Under Section 12 HWG, advertising outside professional circles may not relate to the detection, prevention, removal or alleviation of the illnesses listed in Section A of the annex; those include notifiable diseases under the Infection Protection Act, malignant neoplasms, addictive disorders other than nicotine dependence, and pathological complications of pregnancy, birth and the postnatal period (Heilmittelwerbegesetz). Factual information about a practice's range of services remains possible; promotional emphasis on those indications does not.
| Typical wording | Why it is risky | Wording that holds up |
|---|---|---|
| "We will make you permanently pain-free" | Presents an outcome as certain (Section 3 HWG) | "The aim of treatment is to reduce symptoms; progress is assessed together" |
| "The gentlest method in the region" | Comparative and promotional advertising (MBO-Ä, Section 27) | "We work with the following procedure because it offers these advantages within our range" |
| Before-and-after gallery after cosmetic procedures | Expressly prohibited (Section 11 paragraph 1 sentence 3 HWG) | A description of the process, preparation, aftercare and risks |
| A collection of thank-you letters on the home page | Third-party statements where they are made in an inappropriate way | Factual details about equipment, consulting hours and the course of treatment |
| "Leading in the treatment of addiction" | Touches Section 12 HWG and is also a top-position claim | Naming the services offered without a ranking claim, with a note on cooperations |
Professional code: factual, not promotional
Alongside advertising law sits professional law. The model professional code for physicians practising in Germany, most recently in the version adopted by the 130th German Medical Assembly on 13 May 2026 (Bundesärztekammer), states its purpose in Section 27 paragraph 1: safeguarding patient protection through appropriate and proportionate information, and avoiding a commercialisation of the medical profession that runs counter to its self-image. On that basis, paragraph 2 expressly permits factual, profession-related information. The code therefore does not forbid a practice from informing people about itself — it draws the line at the manner of presentation.
Advertising contrary to professional standards is prohibited for physicians. Contrary to professional standards is, in particular, promotional, misleading or comparative advertising.
Section 27 paragraph 4 MBO-Ä names what may be announced: titles acquired under the specialist training regulations, qualifications acquired under other public-law provisions, focus areas of work labelled as such, and organisational information (Bundesärztekammer). The order of those four categories explains two common objections. Training titles may only be used in the form permitted by the training regulations — an additional qualification does not become a specialist title. And focus areas must be labelled as such, so that they do not read like a formal qualification.
- Specialist and additional titles in the spelling used by the training regulations, ideally with a note on the awarding chamber
- Focus areas expressly marked as a focus, not presented as a title
- Organisational information such as hours, appointment handling, accessibility, languages spoken in the team
- Membership of a joint practice or a practice network
- A factual description of equipment, without comparative judgement against other practices
For practices without a chamber — physiotherapy, occupational therapy, speech therapy, alternative practitioners — this test formally falls away, but hardly does so in practice: promotional or comparative statements are caught by advertising law for health services and by competition law. How advertising claims and price statements can be phrased safely in general is covered in the article on price statements and advertising claims without legal risk.
Patient voices without a grey area
The wish for quotes on your own site is understandable, and the legal position is less clear-cut than for a tradesperson. Section 11 paragraph 1 sentence 1 number 11 HWG names statements by third parties, in particular letters of thanks, appreciation or recommendation, and references to such statements, where they are made in an abusive, off-putting or misleading way (Heilmittelwerbegesetz). The professional prohibition on promotional advertising applies as well. And general fair-trading law can treat a selected, unrepresentative collection of positive voices as misleading.
Process instead of praise
A description of what happens at the first appointment, how long it takes and what to bring builds more trust than a quote — and raises no questions under professional law.
No incentives for reviews
Paid reviews or reviews tied to a benefit must be disclosed and are additionally sensitive in a health setting. If you ask for feedback, ask without offering anything in return.
Document consent
If a patient voice is shown as an exception, consent, purpose and the right to withdraw belong in writing — and the statement must not promise a treatment outcome.
A third route is usually the practical one: leave reviews where they arise and merely point to them factually on your own page. The general rules for collecting, displaying and answering reviews are set out in the article on displaying customer reviews within the law; in the health professions the additional restraint of professional law comes on top.
Hours and cover arrangements
Consulting hours are not an add-on: they are one of the four details Section 17 paragraph 4 MBO-Ä specifies for the practice sign (Bundesärztekammer). On the website they carry the same weight — with the difference that there they have to be kept current. Section 20 paragraph 1 MBO-Ä adds that physicians in private practice should in principle be ready to cover for one another, that patients taken over must be referred back once the cover ends, and that cover should as a rule be provided by a specialist in the same field (Bundesärztekammer). For the website that means the cover arrangement is its own, continuously maintained piece of information, not a footnote.
- Consulting hours as text, separated by day, not as an image or an embedded file
- Phone hours stated separately where they differ from consulting hours
- Open surgery, appointment-only hours and acute slots clearly distinguished
- Holidays and closures with dates and a named cover arrangement
- A pointer to the out-of-hours medical service outside consulting times
- A date or a last-checked note, so readers can see when it was last reviewed
The public holiday test
Appointment requests without health data
This is the biggest difference from any other sector. A contact form usually asks about the enquiry and its details — and in a health setting that is precisely the mistake. The General Data Protection Regulation counts health data in Article 9 paragraph 1 among the special categories of personal data, whose processing is prohibited in principle unless an exception under paragraph 2 applies. As soon as a free-text field takes in symptoms, diagnoses or medication, the practice processes such data through a channel neither designed nor secured for it — often with unencrypted forwarding to a mailbox on top.
The remedy is editorial, not technical: the form asks only about organisational matters. Establishing contact is enough; the medical part belongs in the phone call or the consultation. That also reduces risk, because data that is not collected in the first place needs no protection, no deletion and no documentation. How an enquiry form should be built so that it produces answerable enquiries is described in the article on contact forms that turn visitors into enquiries.
| Form field | Why it is a problem | What works instead |
|---|---|---|
| "Your symptoms" as free text | Collects health data under Article 9 GDPR through an unsuitable channel | "Would you like an appointment or a call back?" with two options |
| "Diagnosis" or "medication" | A special category of personal data, without a solid legal basis in the form | A note that these details are recorded in conversation or at the practice |
| Insurance number or insurer data | Not needed for an appointment request, and it raises the severity of any incident | A choice of "statutory or private insurance" where the scheduling logic needs it |
| Date of birth as a mandatory field | Usually avoidable; "adult or child" is often enough | An optional field with a reason why it helps scheduling |
| File upload for medical findings | Uncontrolled inflow of sensitive documents into a web mailbox | A note to bring findings to the appointment or send them by an agreed route |
- Only a name, one contact option, a preferred time window and the type of request at an organisational level
- A free-text field with a clear label such as "Organisational notes (please do not describe symptoms)"
- Visible labels placed before the field that stay in place while typing
- A short note before submitting on how long a reply usually takes
- Clearly separated emergency information with phone numbers that no form replaces
- Encrypted transmission only, forwarded to a mailbox with restricted access
A call-back request is the most data-light option
Email is not a substitute for the form
That leaves the second data protection strand: everything that happens automatically when the page loads. In its guidance for providers of telemedia, the German Data Protection Conference states that consent must already have been given before the access to the terminal equipment that requires consent takes place; it is therefore not permissible for consent-requiring cookies to be set on the first call of a website (Datenschutzkonferenz, OH Telemedien 2021, version 1.1). For a practice page the consequence is pleasantly simple: embed as little as possible. How maps, videos and fonts can be handled without data leaking is shown in the article on embedding external content without data leaks, and the basics of consent are covered in the article on GDPR and consent on your website.
Readable for older patients
A practice serves an audience that is on average older and more often impaired than the audience of an online shop. 7.8 million (Aktion Mensch) people in Germany have a recognised severe disability; for them accessibility is the precondition for using a site at all. For around 30 percent (Aktion Mensch) of the population it is necessary — for reduced vision, motor impairments or limited reading ability — and for everyone else it is simply more comfortable. A practice page meets these groups in concentrated form, because it reaches people who are not at their best.
How far there is to go is shown by the third test report from Aktion Mensch: of 65 (Aktion Mensch) websites examined, only 20 (Aktion Mensch) met the criterion of keyboard operability, that is 30 percent (Aktion Mensch); in 2024 it was 15 of 71 (Aktion Mensch) and in 2023 17 of 78 (Aktion Mensch). Among the sites tested further, 15 of 20 (Aktion Mensch) had sufficient contrast and 19 of 20 (Aktion Mensch) could be enlarged, but only 6 of 20 (Aktion Mensch) labelled their form fields sensibly throughout. That last point hits a practice's appointment request directly.
Contrast
Body text calls for a ratio of at least 4.5:1 (W3C, WCAG 2.2, success criterion 1.4.3), large text for 3:1. Light grey on white is the first thing to fail in sunlight and with reduced vision.
Enlargement
Text must be resizable to 200 percent (W3C, WCAG 2.2, success criterion 1.4.4) without loss of content, and content should remain readable at a width of 320 CSS pixels (W3C, WCAG 2.2, success criterion 1.4.10) without sideways scrolling.
Target size
Controls should be at least 24 by 24 CSS pixels (W3C, WCAG 2.2, success criterion 2.5.8). For unsteady hands and for use in a waiting room that is the lower bound, not the target.
Readability includes language. Technical terms are unavoidable in medicine, but they need a translation in the same sentence: "sonography (ultrasound)" rather than "sonography". Short sentences, active phrasing, no chains of nouns, one piece of information per paragraph. How that works in detail is described in the articles on writing website copy customers read and on accessible, clear website copy; for a practice page there is the added fact that many readers are reading under stress.
- Name the technical term and explain it in brackets, rather than avoiding it or leaving it unexplained
- Most important information first: responsibility, hours, directions — history and mission afterwards
- Phone numbers as a dialable link, so that a single tap is enough
- No information carried by images alone: hours, addresses and prices belong on the page as text
- Enough space between lines and paragraphs; tight justified blocks make reading noticeably harder
Step-free access to the practice
Access to the building is its own piece of information, not a side note in the directions. For people with a walking aid, in a wheelchair, with a pushchair or after an operation, it decides whether an appointment is possible at all. Practices answer this question on the phone every day; a properly maintained section on the website replaces a substantial share of those calls. Precision matters: the word "accessible" on its own helps nobody, because it means something different depending on the impairment.
- Steps up to the entrance, how many and how high, plus any ramp or lifting platform
- Lift with cabin dimensions and whether the controls sit at a reachable height
- Door widths at the entrance, reception and treatment room
- Accessible toilet available or not — a clear no is better than silence
- Parking, distance to the entrance and the location of the nearest stop
- Doorbell or intercom at reachable height, or a phone number for assistance
- A note on whether a companion may come along and whether assistance dogs are admitted
Describe the route instead of embedding a map
Which pages are needed overall, and how they sensibly connect, is set out for all sectors in the article on which pages a business website really needs. In practice a lean structure has proven itself: home page with hours and scope, services overview, team, directions and access, appointment request, imprint and privacy notice. More pages mean more upkeep, and upkeep is the scarcest resource in a practice — what has to be readable on a phone is covered additionally in the article on mobile usability for business websites.
Does the German accessibility act apply to a practice?
This question comes up in every practice conversation. The German Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) covers certain services under Section 1 paragraph 3, including telecommunications services, passenger transport, consumer banking services, e-books and services in electronic commerce. The latter are defined in Section 2 number 26 as digital services provided via websites or apps, electronically and at the individual request of a consumer with a view to concluding a consumer contract. A practice website that informs and takes appointment requests generally does not fall under that. In addition, Section 3 provides an exemption for micro-enterprises providing services; under Section 2 number 17 a micro-enterprise employs fewer than ten people and reaches at most two million euros in annual turnover or balance sheet total.
Formally exempt does not mean practically irrelevant
What XICflow sets up automatically
The recurring finding from practice projects: the content is not the problem, the structure around it is. A practice can describe what it does, which hours apply and how a first appointment runs. What it cannot handle on the side is whether the required details are complete, whether the consent banner takes effect before the first access, whether form fields are labelled correctly and whether contrast meets the requirements. That is exactly the layer XICflow creates when a site is built, instead of leaving it as rework.
Legal pages and details
Imprint and privacy notice are created as their own pages with fields for professional title, chamber, supervisory authority and the source of the professional rules. The practice fills in what applies to it.
Consent and data economy
The consent banner is preconfigured, external embeds stay optional and switched off. The enquiry form starts with organisational fields rather than an open symptom box.
Accessible base structure
Heading hierarchy, labels, focus visibility, contrast and target sizes are part of the blocks, not the result of manual rework. New pages inherit that base.
The rest is editing: change hours, enter holidays, name the cover, add a service description. The route from briefing to a published page is described on the page How it works; finished examples are under demo websites, the feature set under features and Flow Blocks and the plans on the pricing overview.
What counts in the end
Sources and studies