Advertising as a bookkeeper in Germany: which words are allowed and which cost you a cease-and-desist letter

Three rules from § 8 StBerG

In § 8 StBerG, the Steuerberatungsgesetz (StBerG, Tax Advisory Act) contains its own advertising provision, which applies to everyone who provides assistance in tax matters, including bookkeepers under § 6 Abs. 1 Nr. 1 StBerG. It can be boiled down to three rules:

That last sentence is the key. Almost all disputes are not about the Tax Advisory Act itself but about the UWG's ban on misleading statements: an offer must not create an impression that goes beyond what you are actually allowed to do.

What the courts have decided

The OLG Karlsruhe based this on an earlier BGH decision on the term “Buchführungsbüro” (bookkeeping office) (GRUR 2008, 815): anyone who advertises with “Buchführung” must at the same time make it unmistakably clear that only a limited scope is meant. In short: the courts ask what an average small business owner understands. That person does not know § 6 StBerG, but does know the word “Buchhaltung”, and thinks of everything up to the balance sheet.

Terms that work, and terms that cause trouble

In 2001, the BGH also objected to “Lohnabrechnung” (payroll) without an addition. Use the wording of the law, “laufende Lohnabrechnung” (ongoing payroll). It is precise and shows that you know your limits, which tends to build trust with cautious business owners rather than cost it.

How to word the restriction properly

The clarification must appear where the impression is created. If “Buchhaltungsbüro” is in your logo, it needs an asterisk and an easily readable footnote on the same page. If “Buchhaltung” is a menu item, the first sentences of the service page describe what is included and what is not. An example of an introductory text:

A text like this meets the requirements of the case law and is good marketing at the same time: it describes the benefit, presents the cooperation with tax advisers as a strength and avoids jargon nobody understands. What the matching imprint looks like is explained in the article on the imprint for bookkeepers.

Using titles and qualifications correctly

• You may use “Buchhalter:in” under § 8 Abs. 4 StBerG if you meet the requirements of § 6 Abs. 1 Nr. 1. You are not obliged to.
• “Geprüfte:r Bilanzbuchhalter:in” only with the IHK (Chamber of Industry and Commerce) qualification. Do not drop the “Geprüft” (certified), and ideally name the IHK where you took the examination.
• “Bachelor Professional in Bilanzbuchhaltung” is the equivalent title for the same qualification. Do not shorten it to “Bachelor”, because that would suggest an academic degree.
• “Steuerfachwirt:in” is also permitted as an advertising title, but does not authorise tax advice.
• “Steuerberater:in” (tax adviser), “Steuerbevollmächtigte:r” and variations are protected under criminal law (§ 132a StGB). “Steuerbüro” (tax office) or “Steuerservice” (tax service) in the name is also generally misleading for bookkeepers, because it suggests a power they do not have.

Reviews, references and client names

Reviews are an important signal for bookkeeping offices, because prospective clients can hardly judge the quality of the work in advance. Since 2022, the UWG has set out more precisely what applies. If you show reviews on your website, you must state whether and how you ensure that they come from real customers (§ 5b Abs. 3 UWG). Fake or bought reviews, and the unsupported claim that all reviews are genuine, are always prohibited under the annex to the UWG (Nos. 23b and 23c).

Bookkeepers do not have a statutory duty of confidentiality like tax advisers. Even so: only publish names, logos or quotes of clients with express consent, if only because of contractual confidentiality and data protection. You may actively ask for Google reviews, but without offering anything in return and without selecting only satisfied clients. A QR code for Google reviews on the invoice or at the closing meeting makes it easy. More on this in the article on the Google Business Profile.

Outreach: letter, phone, email and Google Ads

Because § 8 Abs. 2 StBerG does not prohibit soliciting individual engagements for bookkeeping activities, you have more options than tax advisers. The limits are set by § 7 UWG:

Courts interpret a business's presumed consent to marketing calls narrowly; a general need for bookkeeping is usually not enough. A traditional letter to businesses in your region is therefore often the safer route. For Google Ads: the ad copy is advertising within the meaning of § 8 StBerG. “Buchhaltung Leipzig: laufende Buchungen und Lohnabrechnung” (bookkeeping Leipzig: ongoing entries and payroll) is unproblematic, “Steuererklärung günstig” (cheap tax return) is not, even if the landing page then restricts it correctly. For visibility without an ad budget, the article on local SEO helps.

Prices and comparisons

The Steuerberatervergütungsverordnung (tax advisers' fee regulation) does not apply to bookkeepers; your prices are freely negotiable and may be advertised. Towards consumers, state final prices including VAT; with business clients, net prices with a note are common. Be careful with comparisons such as “cheaper than a tax adviser”: such a statement suggests the service is the same. It is not, so the comparison quickly becomes misleading.