Regulations for CPA Premium Germany
Government regulations
The German telecommunications market is regulated by government and the Telekommunikationsgesetz (TKG).
The RegTP is instructed by the German government to regulate the telecoms market. The industry itself has also established an independent organization called Verein zur
Freiwilligen Selbstkontrolle Telefonmehrwertdienste e.V. (FST-EV), which is responsible for regulating PSMS and value-added mobile services. All PSMS service providers are required to commit to the FST-EV code of conduct.
Content restrictions
There are a number of restrictions on services, in particular with regard to adult services and the protection of minors. German law provides for this under the Jugendschutzgesetz or Youth Act. To obtain Adult content approval, an age verification system needs to be in place. Without this, operators will only allow 16+ content.
Furthermore, content must not contain any unlawful or inappropriate materials such as extremist propaganda or ideology that supports terrorism.
Operator-specific restrictions
T-Mobile
Subscription Services: Services require a so-called “handshake”. This means that after the end-user has sent the MO to the short code, an MT has to be sent giving further details on the service and how to cancel the subscription. By replying to this MT message, end-users confirm that they want to receive the service and the subscription starts. Only then can the content be delivered. The handshake is only required when end-users start the subscription service. If providers deliver content for a second or third time, they don’t need to send a further MT.
Acceptance Testing: T-Mobile is very strict about service approval and a detailed service description needs to be completed. Only services that have been approved by
T-Mobile according to the service description are allowed and changes without approval represent a breach of the contract.
WEB Billing: T-Mobile services, where the user requests the service on the internet rather than via an MO SMS, are subject to restrictions and only one-time billing transactions are allowed. To establish a recurring or subscription service, users must opt-in via an MO SMS, otherwise a web request must be made for each instance of the service.
Vodafone
Subscription services: Double opt-in by the end-user (handshake) is required. This is handled by Vodafone’s mPay platform. If confirmed by the end-user, mPay sends back a positive acknowledgement. An SMS receipt needs to be sent to the end-user with further service details, including instructions for canceling the subscription.
Latest changes: Vodafone no longer allows daily subscription services. The minimum duration between two billing events in a subscription service is now 2 days. Furthermore, for all subscription service with a frequency below one week, services must be preapproved by Vodafone. In addition, a minimum period for a subscription service of e.g. three months is not allowed.
E-Plus
Subscription services: Same as T-Mobile.
Billing System: E-Plus is the only operator in Germany without an online billing platform. All E-Plus short codes are single tariff and the end-user is charged for every message that is send via the premium link. Therefore, all zero-rated SMS messages (i.e. service confirmations and requests) must be sent via a different, zero-rated short code. The use of premium short codes for this purpose is not possible. Providers are also required to offer a service request short code to which an end-user sends an MO. All zero-rated MT messages are sent via a delivery short code, which is used to deliver the content to the end-user. The shared short code offer contains one service request short code, which is cross carrier, and five delivery short codes, which are priced at € 0.99, € 1.99, € 2.49, € 3.99, € 4.99.
Special regulations: E-Plus only permits the sale of content that can be consumed with or on the mobile phone.
O2
Subscription services: Very similar to Vodafone. The newly introduced platform MyP@y handles the handshake with the end-user on behalf of the service provider.
Please note, MOB does not require a handshake at all. For one time downloads MOB is the more attractive product.
Special regulations: O2 does not allow chat services on MT Billing. This does not occur for MOB short codes.
Debitel
Debitel is the only virtual operator offering MTB in Germany. Only post-paid Debitel customers are configured on the Debitel SMSC. Pre-paid customers have the real
operator’s SMSC configured, thus, they appear as the real operator’s customers.
Subscription services: The latest Debitel contract now requires a double opt-in for subscription services. This has to be implemented by the service provider.
Common restrictions
Keywords: Special keywords need to be supported for subscription services. The table below contains further details:
|
Operator
|
Key Words for
subscription services |
Action associated
|
|
T-Mobile
|
START <Keyword>
STOP <Keyword>
STATUS
STOP ALLE |
Starts the service
Stops the service
Returns an overview of all
subscription services on the
short code
Stops all services |
|
VF D2
|
START <Keyword>
STOP <Keyword>
STATUS
STOP ALLE
LISTE
|
Starts the service
Stops the service
Returns an overview of all
subscription services on the short code
Stops all services
Provides a list of all keyword on the short code |
|
E+
|
Stopalle
Statusabo
|
Stops the service
Returns an overview of all
subscription services on the short code |
|
O2 |
START <Keyword>
STOP <Keyword> |
Starts the service
Stops the service |
|
Debitel |
START <Keyword>
STOP <Keyword> |
Starts the service
Stops the service |
Bill warnings: Some operators require the service provider to send free of charge messages to the end-user indicating that a certain amount of money has been spent
on that particular service.
Marketing regulations
The contracts from T-Mobile, Vodafone and E-Plus contain requirements concerning advertisement of the services in different media. These requirements are concerned
with ensuring clear pricing indication, e.g. the price for a subscription service must be displayed throughout the duration of a TV advert and must meet minimum font size regulations.
End-user support
Clients are responsible for end-user support. Clients must set up a toll free number or a shared cost number in Germany as a hotline. This must be available during normal business hours. End-users should also be able to access support via email.
For any questions, please send an e-mail to: smssupport@vianett.no