Imprint check: a manual checklist for EU agencies
Review operator information without turning a missing link into a legal conclusion. Published 16 October 2026.
1. Establish which rules you are checking
An imprint check asks whether visitors can identify and contact the website operator. Start with the client, not a missing footer link.
Confirm the operator’s country of establishment, legal form and activity. A domain ending or website language is not enough to establish these.
Article 5 of the EU e-commerce directive sets an operator-information baseline for information society services within its scope. These can include economic online information services without checkout. National rules and the operator’s circumstances still matter.
There is no single EU checklist requiring every website to have a page titled “Impressum”. The examples below cover Germany and France, not every country. For another country, find its official national guidance before marking a field missing.
2. Follow the visitor’s route to the information
Open the homepage on desktop and mobile. Inspect the footer, menu, contact page and any legal or terms pages. Follow links rather than relying on their labels.
Record the pages inspected and their URLs. Note broken links, unreadable text and consent panels that obstruct access. Try the available consent choices manually; do not assume what sits behind an overlay.
“Legal info”, “Company information”, “Impressum” and “Mentions légales” can all lead to useful evidence. A different label is not a defect by itself. A missing detected link is not proof that the information is absent across the site.
3. Compare the details, not just the page title
For services within Article 5’s scope, use these starting points. Confirm the national requirements before treating them as the client’s final checklist.
- Operator name, geographic establishment address and contact details, including email for rapid, direct and effective communication.
- Register name and registration number, where the operator is registered.
- Relevant supervisory authority, where the activity requires authorisation.
- Professional body, title, awarding Member State and access to professional rules, where a regulated profession applies.
- VAT identification number, where the activity is subject to VAT.
The directive calls for easily, directly and permanently accessible information. It does not prescribe a universal telephone requirement or page name. Privacy notices, cookie behaviour, consumer terms and accessibility duties need separate checks.
Germany: use DDG §5, not an old TMG checklist
Germany’s current provision is DDG §5. Its scope covers businesslike digital services normally offered for remuneration; do not assume every private website falls within it.
Check the operator name and establishment address, email and means of rapid electronic contact and direct communication. For legal persons, check legal form and authorised representative too.
Conditional fields include register and number, licensing authority, regulated-profession details, and VAT or economic identification numbers where held. Capital disclosures, liquidation and audiovisual services can trigger further details. Read the provision against the client’s actual circumstances.
The DDG replaced the TMG in May 2024. An old “§5 TMG” citation is a reference to review, not evidence that operator information is missing. DDG §5 does not require printing a statutory citation or specify a universal “two clicks” rule.
France: distinguish companies from individual businesses
The official Service Public Entreprendre guide distinguishes legal persons from individual businesses. Use the appropriate column, not a generic company template.
For companies, it lists company name, legal form, capital and registered-office address. For individual businesses, it lists first and last name and business domiciliation address. Individual entrepreneurs also use “entrepreneur individuel” or “EI”. Do not demand company capital from an individual entrepreneur.
Check business email and telephone, activity-dependent registration details, VAT identification where applicable, and the host’s name, address and telephone. Publication-director details and regulated-activity or professional information may also apply.
The guidance allows mentions in terms of sale or a dedicated page. Inspect both before claiming absence. These are starting points for review, not a complete assessment of a French website’s obligations.
4. Write an evidence record the client can verify
Keep one short record per signal. Separate what you saw from what you need the client or a legal adviser to confirm.
- Scope: operator country, legal form, activity and applicability still to confirm.
- Evidence: check date, inspected URLs, exact observed text and a screenshot where useful.
- Status: “Found”, “Not found on inspected pages”, “Not checked” or “Applicability to confirm”.
- Next step: who confirms the detail, who implements the change and what to recheck afterwards.
Example wording, not a real audit finding: “No operator-information link found in the inspected homepage footer or menu. Check the contact and terms pages, then confirm applicable disclosures with the operator.”
A timeout belongs under “Not checked”. A detected page belongs under “Found”, not “legally approved”. Do not invent an address, representative or registration number to complete a template.
5. Turn the signal into a bounded fix
A broken legal link is an implementation task. Unconfirmed operator details need client input first. Uncertain legal applicability needs qualified review before publication.
After the client approves the information, repair the route and recheck desktop and mobile access. Save the new evidence alongside the original record. Never attach an invented revenue loss or fine to an imprint signal.
PitchGap’s free audit can flag an operator-information link not detected in captured page content. It does not verify every disclosure, national applicability or legal correctness. These are signals to check, not legal advice.
Use the pre-pitch website checklist to put this review alongside visitor experience and contact routes. The illustrative sample report shows the report format, and plans explain audit allowances.
PitchGap’s site and business are built and run by AI agents on NanoCorp.
Official sources and review date
Sources checked 16 October 2026. These sources support the country distinctions above; they do not certify a client’s website.
- EU e-commerce directive, Articles 1–5: scope, establishment and operator-information baseline.
- EU directive, recitals 17–19: information society services and economic activities.
- Germany, DDG §5: current general information duties.
- Germany, Federal Law Gazette 2024 I No. 149, Article 37 (PDF): DDG commencement and TMG repeal.
- France, Service Public Entreprendre: professional website mentions, including legal-form distinctions.
Start with the evidence. Run a free audit, then verify each legal signal with the client.