Legal compliance · HWG · Web design

HWG & Practitioner Websites:
What's allowed — and what a
legal warning costs.

sandhan-design.com

Most practitioner websites breach the German healthcare advertising law — without knowing it. The risk: legal warnings (Abmahnungen) of between €1,500 and €5,000, issued by specialised law firms that deliberately search for violations. This article shows you what is prohibited, what correct wording looks like, and what happens if it comes to the worst.

What is the German healthcare advertising law (HWG)?

The Heilmittelwerbegesetz — HWG for short — is a German federal law from 1965, last updated in 2022. It governs which advertising claims are permitted for medicines, medical devices and health-related services .

Crucial for practitioners: § 1 (1) no. 2 HWG explicitly brings "other procedures as well as treatments and objects" within its scope — that is, everything you write about your work on your website. Naturopathy, TCM, homeopathy, energy work, systemic counselling — the HWG applies to all health-related professions that provide services to people.

Important to understand

The HWG applies not only to your website — but to all advertising media: flyers, social-media posts, newsletters, Google ads, and even client testimonials on your website if they describe healing successes.

Why is this so delicate for practitioner websites?

The core problem: as a practitioner you naturally want to describe what your method is good for. You want to explain what you do and whom you reach with it. That is exactly where an HWG violation can quickly arise — because between a helpful description and a prohibited promise of a cure there is often just a single word.

On top of that: the HWG was written to protect patients from exaggerated promises of a cure. The aim is legitimate. But the wording rules are complex — and even well-meant text regularly breaches § 3 HWG (misleading advertising) or § 11 HWG (absolute statements, guarantees of success, before-and-after comparisons).

What is prohibited? The most common violations

1. Promises of a cure (§ 3 HWG)

Any statement suggesting that a method heals, cures or eliminates an illness is prohibited. That sounds clear-cut — but in practice it isn't:

Prohibited wording — examples

"I heal chronic back pain."

"Acupuncture for migraines." (without qualification)

"TCM helps with sleep disorders, burnout and depression."

"After the treatment, clients are pain-free."

"Naturopathy works for allergies."

2. Absolute statements (§ 11 no. 2 HWG)

Statements such as "always", "certain", "guaranteed", "demonstrably effective" or "without side effects" are absolutely prohibited — because they suggest a certainty that cannot be medically proven.

Also prohibited

"100% natural and risk-free."

"Proven and scientifically established."

"Guaranteed results after 3 sessions."

3. Before-and-after comparisons (§ 11 no. 5 HWG)

Photos or text comparing a state of health before and after a treatment are generally prohibited — even if the client themselves gives permission.

4. Client testimonials with healing successes

An area many underestimate: if a client writes on your website "Thanks to the treatment I've been pain-free for two years", that is an HWG violation — even though you did not write the text yourself. As the website operator you are responsible for all content on your site.

What happens in the event of a violation?

This is where it gets expensive. Germany has an active culture of legal warnings, and practitioner websites are regularly and systematically checked by specialised law firms and competition associations.

1.500 – 5.000 € typical legal-warning costs
250 – 1.500 € Lawyer's fees for your defence
up to 250.000 € Contractual penalty for repetition

A legal warning typically goes like this: you receive a letter with a deadline (often 48–72 hours) requiring you to sign a cease-and-desist declaration with a penalty clause and to reimburse the costs of the party issuing the warning.

If you sign without legal review, you commit to paying a contractual penalty for every future violation — even for similar wording. If you don't sign, you risk an interim injunction, which becomes even more expensive.

The good news

Since the reform of the Act Against Unfair Competition (UWG reform 2021), so-called "mass warnings" have become harder. Warnings by direct competitors remain possible at any time — and those are the most common ones for practitioners.

How do you phrase it correctly?

HWG-compliant writing can be learned. The trick: instead of promising an effect, you describe application and field of use. Instead of guaranteeing a cure, you describe the framework of your work.

❌ Not like this ✓ This is correct
"Acupuncture heals migraines." "Acupuncture is traditionally used for migraines."
"I treat burnout." "My work accompanies people through phases of exhaustion and overwhelm."
"Naturopathy helps with allergies." "In naturopathy there are various approaches that are applied to allergies."
"After 3 sessions, clients are pain-free." "Many clients report that they feel better after several sessions." (without promising success)
"My method is demonstrably effective." "This method has been used in my practice for years."
"TCM eliminates sleep disorders." "TCM is traditionally used in the area of sleep and inner restlessness."

Sounds stiff? At first, yes. But well-written HWG-compliant text reads professionally and seriously — and often creates more trust than grand promises of a cure, which clients meet with scepticism anyway.

Need more examples to look up? In my collection 40 HWG-compliant phrasings for practitioners you'll find vetted before-and-after wording for treatments, methods, about-me and testimonials — ready to copy (also as a PDF).

Special case: health data and GDPR

HWG and GDPR overlap on practitioner websites in one important way: every contact form through which clients describe their complaints processes health data under Article 9 GDPR — the most sensitive data category in European law. Stricter requirements apply to it:

Anyone who does not implement both — HWG and GDPR — cleanly has two points of attack at once. Both should be considered from the start , not added afterwards.

My recommendation

You don't have to become a legal expert. But you should know that the topic exists — and that a single sentence on your website can become expensive.

My recommendation for practitioners who want to plan or have a website redesigned:

Checklist — HWG-safe website

✓ No direct promises of a cure in text, headlines or meta tags

✓ Effect statements always with "is used", "can support", "traditionally applied"

✓ No absolute statements: no "always", "certain", "guaranteed"

✓ Client testimonials without healing successes — or leave them out entirely

✓ No before-and-after photos

✓ Privacy policy with an Article 9 GDPR module

✓ Legal notice complete under § 5 DDG with professional title

Frequently asked questions about the HWG

Yes. The HWG applies to all advertising media — so also to social-media posts, stories, reels and ads. The same wording rules as on the website apply there too.

Not on your website. Even if a client explicitly agrees, you as the website operator are responsible for all published content. Testimonials are possible but must not describe healing successes — only the collaboration and the general experience.

That depends on how you describe your services. As soon as you use terms like "burnout", "depression", "trauma" or other conditions, the HWG can apply — regardless of whether you hold a practitioner title. When in doubt: phrase cautiously.

If you're not sure whether your text is HWG-compliant — yes. A review by a lawyer for medical law costs €200–400 and is considerably cheaper than a legal warning. Alternatively: when building or relaunching a website, the text can be worded correctly from the start.

Sandhan Jürgen Westphal
Sandhan Jürgen Westphal

Web designer for holistic practitioners, coaches and therapists across the German-speaking region (DACH). 40+ years personally rooted in the healing community. All websites are created with HWG-compliant copy and complete GDPR documentation — as standard, at no extra charge.

Your website should be secure — from the start.

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