German civil procedure has traditionally been based on individual rights enforcement, with court decisions only binding the parties involved (inter partes effect). The first collective redress instruments implemented in Germany were designed to address specific gaps in law rather than to introduce a general class action mechanism comparable to the US model.

From 2002 onwards, the Injunctions Act (Unterlassungsklagengesetz, or “UKlaG”) was the first law to introduce a mechanism with collective redress elements, allowing qualified consumer and business associations to seek injunctions against unlawful commercial practices or invalid general terms and conditions. In 2005, the Act on Model Proceedings in Capital Market Disputes (Kapitalanleger-Musterverfahrensgesetz, or “KapMuG”) was created in light of mass investor claims ‒ notably, following the Deutsche Telekom IPO ‒ to resolve recurring legal and factual issues in one model case while leaving individual damages to be decided in individual proceedings.

In 2018, in response to the Volkswagen emissions scandal (“Dieselgate”), the model declaratory action (Musterfeststellungsklage) was introduced in the German Code of Civil Procedure (Zivilprozessordnung, or ZPO). This procedure enables qualified entities to clarify common factual and legal issues for large groups of consumers who can participate through a publicly accessible opt-in register. The Model Declaratory Action has a limited scope of application, as consumers generally still need to file subsequent proceedings to obtain compensation or other forms of relief in case no settlement was reached in the Model Declaratory Action proceedings.

In 2023, Germany implemented the Directive (EU) 2020/1828 (the “EU Representative Actions Directive”) by means of the Consumer Rights Enforcement Act (Verbraucherrechtedurchsetzungsgesetz, or “VDuG”). The VDuG introduced the redress action (Abhilfeklage), which complements the model declaratory action and – going beyond the latter’s scope – for the first time allows qualified entities to claim compensation and other remedies (eg, contract termination or price reduction) directly on behalf of consumers and small businesses.

As of September 2025, a total number of eight redress actions have been published in the official claims register. Although this number appears modest, the mechanism is already reshaping consumer litigation in Germany. By offering a more streamlined path to collective compensation, it is expected to encourage more strategic claims by consumer associations, especially in fields such as data protection and ESG-related disputes. The first effects of this trend can already be seen in pending cases against TikTok, Meta, and X.

The underlying policy rationale of these mechanisms is to enhance consumer access to justice, ensure greater legal certainty in mass harm cases, and establish more efficient procedures that relieve courts from handling a large number of parallel individual claims. Please note that, for reasons of clarity and brevity, the following sections focus on the most prominent collective redress mechanisms under German law ‒ namely, the model declaratory action and the redress action.

The German collective redress regime is not modelled on the US class action approach. Traditional US features such as opt-out participation, pre-trial discovery, jury trial, and punitive damages are absent. German law has deliberately avoided importing these instruments, considering them inconsistent with the principles of German civil procedure.

The main external reference for Germany’s collective redress regime is EU legislation. The adoption of the EU Representative Actions Directive was decisive in shaping the most recent reform. This new mechanism goes beyond earlier German tools, as it permits claims for damages and other remedies on behalf of consumers and micro-enterprises in a single procedure.

Principal sources of law include the Injunctions Act, the Act on Model Proceedings in Capital Market Disputes, the Consumer Rights Enforcement Act, and the Code of Civil Procedure.

Germany fully implemented the EU Representative Actions Directive in October 2023 through the Consumer Rights Enforcement Act. The Consumer Rights Enforcement Act introduced the redress action, complementing existing mechanisms such as the model declaratory action. Unlike earlier procedures, the redress action allows qualified entities to directly claim damages or other remedies (eg, repair, contract termination, or reimbursement) on behalf of consumers and micro-enterprises in single-track proceedings.

Although aligned with EU standards, the German regime contains the following specific features.

• Strict opt-in requirement ‒ consumers and micro-enterprises must register individually in the official claim register (Klageregister) to participate.
• Qualified entity requirements ‒ only consumer organisations that are listed under the Injunctions Act or registered at EU level may bring claims. They must be largely independent of business funding (no more than 5% of annual resources from corporate donations).
• Scope of application ‒ Germany extended the scope of the redress action beyond the minimum required by the EU Representative Actions Directive. Although the EU Representative Actions Directive obliges EU member states to make representative actions available only in relation to breaches of certain EU consumer protection provisions (and their national transpositions), the German legislator opted for a broader approach. Under the Consumer Rights Enforcement Act, redress actions are generally available for all disputes between consumers and companies.
• Similarity of claims (Gleichartigkeit) ‒ redress actions are admissible only if the claims arise from comparable facts and raise materially similar legal issues. This threshold reflects the legislator’s intent to prevent fragmented or overly complex group proceedings.
• Inclusion of small businesses ‒ unlike the earlier model declaratory action, the redress action extends standing to small businesses with fewer than ten employees and an annual turnover or balance sheet not exceeding EUR2 million.

Germany has transposed the EU Representative Actions Directive without major deviations but with a rather conservative design. Critics argue that the opt-in requirement and strict admissibility criteria may reduce practical effectiveness compared to broader collective systems such as in the Netherlands. At the same time, early cases – ranging from energy price adjustments to large-scale disputes against digital service providers – demonstrate that the mechanism is already being used in practice.

Germany does not have a single codified class action law. Instead, several statutes form the framework for collective redress, as follows.

• The Consumer Rights Enforcement Act ‒ this entered into force in 2023 to transpose the EU Representative Actions Directive. It created the redress action, enabling qualified entities to directly pursue damages or other remedies (eg, repair, price reduction, or contract termination) on behalf of consumers and micro-enterprises.
• The model declaratory action ‒ this was introduced in 2018 in the German Code of Civil Procedure. It allows consumer organisations to establish general factual or legal issues in cases affecting large groups, but does not permit direct compensation.
• The Act on Model Proceedings in Capital Market Disputes ‒ this provides for model proceedings in investor disputes where at least ten similar claims are filed. Courts can determine common questions of law or fact with binding effect for all related cases.
• The Injunctions Act ‒ this allows consumer associations and certain business chambers to seek injunctions against unlawful commercial practices or unfair contractual terms.

These mechanisms operate within the broader framework of the German Code of Civil Procedure. The Code of Civil Procedure provides the general rules of litigation, whereas the Consumer Rights Enforcement Act and the Act on Model Proceedings in Capital Market Disputes contain special procedural provisions on admissibility, registration of claims, collective settlements, and distribution of relief (if applicable).

The scope of collective redress in Germany is broad and in principle covers all types of claims between consumers and companies, provided that the statutory requirement of similarity (Gleichartigkeit) is met. For redress actions under the Consumer Rights Enforcement Act, admissibility requires that claims arise from the same or comparable factual circumstances and raise materially similar legal questions (Section 15 of the Consumer Rights Enforcement Act). Where claims differ too much ‒ for example, owing to varying contractual bases, divergent facts, or complex individual damage calculations – the similarity threshold will not be satisfied and the court may dismiss the action as inadmissible.

Within these boundaries, collective redress has been applied to a wide range of disputes.

German law does not provide a single, overarching definition of “class action” or “representative action”. Instead, several procedural mechanisms exist that together form the framework for collective redress.

• Model declaratory action ‒ this procedure allows recognised consumer organisations to obtain a binding court ruling on factual or legal questions that are relevant for a large group of consumers. While it does not result in direct compensation, it creates the legal foundation for subsequent individual claims.
• Redress action ‒ this mechanism empowers qualified entities to pursue monetary and non-monetary remedies on behalf of consumers and micro-enterprises. Possible outcomes include damages, contract termination, repair, or reimbursement, making it the most far-reaching collective tool under German law.
• The Act on Model Proceedings in Capital Market Disputes ‒ applicable in investor disputes, this statute enables courts to decide on key factual and legal issues that arise in multiple parallel cases, such as claims based on prospectus liability. The model ruling is binding for all related proceedings.
• Injunctions under the Injunctions Act ‒ these grant consumer organisations and business chambers the ability to prevent companies from continuing unlawful practices (eg, the use of unfair terms in general conditions or the use of misleading advertising). Although not designed to award damages, it plays a central role in consumer protection.

In practice, collective redress in Germany therefore functions as a bundle of specialised mechanisms. Common features include opt-in participation, strict standing requirements for qualified entities, and a focus on compensatory relief.

As mentioned in 1.1 History and Policy Drivers of the Legislative Regime, the two main collective Redress Action mechanisms in Germany are the model declaratory action and the redress action. The following overview focuses on the individual aspects of the model declaratory action and the redress action.

Model Declaratory Action

The model declaratory action was introduced in 2018 in response to large-scale consumer claims, most prominently Dieselgate. It allows qualified consumer organisations, rather than individual consumers, to bring proceedings to establish common legal or factual questions. Consumers may participate by opting in through the official claim register, which is publicly accessible and provides information on pending proceedings.

Model declaratory actions are heard by the higher regional court (Oberlandesgericht) in the district where the defendant has its registered seat. Appeals against final judgments can be brought before the Federal Court of Justice (Bundesgerichtshof).

Redress Action

In 2023, Germany implemented the EU Representative Actions Directive by enacting the Consumer Rights Enforcement Act. This created the redress action, which directly addresses the limitations of the model declaratory action. Unlike the earlier model, the redress action allows qualified entities to pursue both monetary and non-monetary relief on behalf of consumers and micro-enterprises in a single step procedure. Available remedies include damages, repair, termination of contracts, price reductions, and reimbursement of purchase prices.

The proceedings follow a structured path. Whereas the initial steps (filing of the redress action by a qualified entity and registration of consumers and small businesses with the claim register) are the same as for the model declaratory action, the proceedings before the court are structured differently. After filing and registration by potentially affected consumers or small businesses, the court assesses the admissibility and merits of the action. If the court finds the redress action to be generally justified, the court issues a basic redress judgment (Abhilfegrundurteil), which inter alia defines eligibility criteria for compensation. Parties are then invited to propose a collective settlement. If no settlement is reached, the court issues a final redress judgment (Abhilfeendurteil), triggering implementation proceedings. Compensation is then administered by a court-appointed administrator through a dedicated fund (Umsetzungsfonds).

As with the model declaratory action, the competent court for redress actions is the higher regional court at the defendant’s seat. Appeals are handled by the Federal Court of Justice.

The model declaratory action enables qualified entities such as consumer associations to file a lawsuit to establish general factual or legal issues relevant to a large number of consumers. Individual consumers cannot file such claims themselves; their only option is to register in the official public claim register to join an existing action. Registration suspends the limitation period and ensures that claimants are bound by the judgment.

Once a model declaratory action has been filed, no other action concerning the same facts may be brought, and consumers who register are barred from pursuing parallel individual proceedings. The court’s judgment is declaratory in nature: it determines whether certain facts or legal grounds exist, but it does not itself award damages or provide enforceable relief. As a result, consumers must still bring individual follow-up proceedings to obtain compensation or other remedies. This two-stage structure has been criticised as inefficient, both for consumers (who face additional litigation costs and delays) and for consumer associations (which must commit significant resources without being able to deliver final relief).

In comparison with other collective mechanisms, such as the assignment models often used by legal tech companies (whereby individual claims are bundled and pursued by an assignee in ordinary civil proceedings), the model declaratory action is more formal and centralised. However, it is also less consumer-friendly – given that assignment models can lead directly to enforceable judgments, whereas the declaratory action requires a second round of litigation.

The redress action was designed to address the inefficiencies of the model declaratory action. Like the model declaratory action, it can only be initiated by a qualified entity, and consumers or small businesses must opt in by registering with the claim register. The key distinction lies in the relief available. Whereas the model declaratory action is limited to declaratory findings, the redress action allows courts to order actual remedies on behalf of consumers and small businesses. These remedies may include damages, contract rescission, price reductions, repair, reimbursement, or ‒ in more complex cases ‒ a collective lump sum payment to be distributed among participants. The proceedings are structured in two main phases. If the court considers the action justified, it issues a basic redress judgment that defines eligibility criteria and evidentiary requirements for the claimants. Following this, the parties are encouraged to settle; if no settlement is reached, the court issues a final redress judgment and orders implementation proceedings. Implementation is overseen by a court-appointed administrator, who creates and manages an implementation fund, verifies the claims of individual consumers, and distributes compensation accordingly.

Compared with the model declaratory action, the redress action is more efficient and consumer-friendly, as it removes the need for subsequent individual proceedings.

In Germany, standing to bring collective redress proceedings is limited to qualified entities. Individual consumers or businesses cannot initiate such actions on behalf of a group; instead, they may only participate by opting in through the official claim register once a case has been filed. This approach reflects the legislator’s intention to ensure that group litigation is handled by independent and experienced organisations rather than by private individuals.

Qualified entities are typically consumer protection organisations recognised under the Injunctions Act and registered with the Federal Office of Justice. To qualify, these organisations must meet certain criteria ‒ most notably, the requirement that no more than 5% of their financial resources come from business donations. This safeguard is designed to prevent conflicts of interest and abusive litigation.

Following the implementation of the EU Representative Actions Directive in 2023, entities from other EU member states can also bring redress actions in Germany, provided they are listed in the EU-wide register of qualified entities. This makes it possible for cross-border consumer associations to litigate in Germany on behalf of consumers or micro-enterprises harmed by practices with an impact on the German market.

Participation in these proceedings is open not only to consumers but also to micro-enterprises, defined as businesses with fewer than ten employees and an annual turnover or balance sheet not exceeding EUR2 million. This extension was a significant change compared with the earlier model declaratory action, which excluded small businesses. The reform recognises that micro-enterprises can face economic and psychological pressures similar to those of individual consumers. Under the declaratory action, small businesses were excluded from joining via the claims register ‒ a limitation criticised during the Volkswagen proceedings because it prevented commercial vehicle owners from participating.

In Germany, there is no automatic “class” as understood in common law jurisdictions. Instead, group membership is established through an opt-in system. Consumers and, in the case of redress actions, also micro-enterprises must proactively register their claims in the public claim register maintained by the Federal Office of Justice. Registration is possible until three weeks after the conclusion of the oral hearing in the relevant collective action. Only those who register within this period are bound by the judgment and eligible for relief, while those who do not register remain entirely unaffected by the outcome.

A registration is only valid if it is submitted on time and includes the following information:

• the consumer’s name and address;
• indication if the registration is made as a micro-enterprise;
• the court and case number;
• the defendant’s name;
• the subject matter and legal basis of the claim or the legal relationship; and
• a declaration confirming the accuracy and completeness of the information.

Where a monetary claim is registered, the amount must also be specified. Valid registrations are entered into the claim register without substantive review.

The admissibility both of model declaratory actions and redress actions depends on a minimum threshold of potential claimants. The initiating qualified entity must demonstrate that the action concerns at least 50 consumers or micro-enterprises. This requirement is intended to ensure that collective redress is reserved for genuinely widespread disputes rather than small-scale cases.

There is no statutory upper limit on the number of participants. In practice, some proceedings have attracted very large groups – for example, almost 450,000 consumers registered in the Volkswagen diesel emissions case under the model declaratory action, and more than 100,000 consumers joined the redress action brought against Amazon Prime Video in 2024. These examples demonstrate that the mechanism can handle very large classes, provided the claims are sufficiently similar in nature.

There is no supplementary mechanism for joining parties once the claim register is closed. German law does not provide for later opt-in options, nor for the consolidation of separate collective cases on the same subject matter, as only one Model Declaratory Action or Redress Action can be pending for the same dispute.

Under German law, courts enjoy significant case management powers in relation to collective redress procedures. However, the scope and intensity of these powers vary depending on the mechanism.

Court Powers in the Model Declaratory Action Procedure

In the model declaratory action procedure, the higher regional courts ensure that only admissible actions proceed. The court determines whether the action has been filed by a qualified entity and whether the quorum requirement under the Consumer Rights Enforcement Act is met ‒ namely, that the declaratory objectives of a model declaratory action may affect the claims or legal relationships of at least 50 consumers. Once these admissibility criteria are met, the court has the power to determine the scope of the proceedings by identifying the factual and legal issues of common relevance that are to be clarified. At the same time, the court ensures exclusivity ‒ given that no other action based on the same facts may be pursued once the model declaratory action has been admitted, and consumers who have registered are precluded from pursuing parallel individual suits.

Within the course of proceedings, the court sets the procedural framework, manages deadlines and evidence-taking, and has the authority to facilitate and approve settlements – provided they are adequate for the registered participants. The powers of the court, however, remain limited to the declaratory stage: it cannot grant damages or other substantive remedies, leaving claimants to pursue individual follow-up actions if they wish to obtain enforceable relief.

Court Powers in the Redress Action Procedure

In contrast, the redress action provides the courts with more extensive case management responsibilities, reflecting its design as a one-stop procedure for determining both liability and compensation. As in the model declaratory action, the court reviews the admissibility criteria set by the Consumer Rights Enforcement Act, but its role thereafter extends further.

If the claim is found to be justified, the court issues a basic redress judgment that not only confirms liability in principle but also sets out the eligibility conditions and evidentiary requirements for affected consumers or small businesses. This allows the court to shape the subsequent implementation phase in a binding manner.

Courts also must approve any settlement reached by the parties to ensure it adequately protects the collective interests of the participants who have opted in. Where no settlement is reached, the court issues a final redress judgment ordering implementation proceedings, appoints an administrator (Sachwalter), and oversees the creation and management of an implementation fund from which compensation is distributed. The court retains supervisory authority until the conclusion of the implementation process and issues the final cost order.

The duration of collective redress proceedings in Germany is highly dependent on the complexity of the case. In the model declaratory action, the information published in the claim register to date shows that proceedings often last several years. The high-profile model declaratory action against Volkswagen AG over the diesel emissions case was filed in November 2018 and resolved by settlement in April 2020, after approximately 18 months of proceedings.

As the redress action is still in its early stages, reliable average durations are not yet available. It is expected that overall proceedings will nevertheless be lengthy, given the two-stage structure (basic redress judgment followed by implementation proceedings). The implementation proceedings alone, including the administrator’s verification of claims and distribution of funds, is expected to take considerable time.

As regards timetabling, German courts have discretion in structuring proceedings. In both the model declaratory action and the redress action, courts set procedural deadlines, including those for the exchange of pleadings, the submission of evidence, and the scheduling of hearings. Participation by consumers and small businesses is tied to registration in the official claim register, which generally closes three weeks after the conclusion of the oral hearing in the relevant case. In the redress action, the court also determines schedules for the court-appointed administrator during the implementation phase to ensure timely processing and distribution of compensation. Despite these procedural tools, the overall duration of proceedings remains case-specific and may vary considerably depending on the scale and complexity of the dispute.

In Germany, collective redress mechanisms follow the general principles of German civil procedure, which do not provide for fast-track or summary disposal in the sense familiar in common law jurisdictions.

In Germany, the general rule on costs in civil litigation is the “loser pays” principle, which applies to collective redress mechanisms as well. In general, the unsuccessful party must bear the court fees as well as the statutory legal fees of the successful party. If the action is only partially successful, costs are apportioned accordingly. This principle applies equally to the model declaratory action and the redress action, with the qualified entity (rather than the individual consumers) formally standing as the claimant.

For model declaratory actions, participating consumers face no direct cost risk. They do not pay court fees or the opposing party’s costs, as they are not parties to the proceedings in their own right. Their only investment is the act of registration in the public claim register, which is free of charge. However, if they later bring individual follow-up proceedings to claim damages or other forms of relief, they are subject to the usual cost rules of German civil procedure. In the redress action, the court ultimately decides on costs in its final redress judgment, and implementation costs (such as the remuneration of the administrator) are usually financed from the implementation fund created to distribute compensation.

Third-party funding is generally allowed, but subject to certain safeguards. Qualified entities must disclose the source of funds used for a representative action, including any agreements with third-party funders, even if funding is secured after filing. In addition, representative actions are considered inadmissible if the funder is a competitor or dependent on the defendant, has been promised more than 10% of the awarded sum or performance, or is likely to influence the litigation in a way that harms consumers.

German civil procedure, including collective redress mechanisms such as the model declaratory action and the redress action, does not recognise broad discovery or disclosure obligations. Instead, the principle of party presentation (Beibringungsgrundsatz) applies: each party must present the facts and evidence it relies upon. Courts do not engage in active evidence-gathering on their own initiative and there is no general duty to disclose adverse documents.

That said, the Code of Civil Procedure contains some narrow disclosure-style instruments. Under Section 142 of the Code of Civil Procedure, courts may instruct one of the parties or a third party to produce records or documents, as well as any other materials that are in its possession and to which one of the parties has made reference. However, this mechanism is applied rather narrowly in practice and does not resemble common law discovery or disclosure mechanisms.

As regards privilege, German law protects attorney–client communications through professional secrecy obligations under the Federal Lawyers’ Act (Bundesrechtsanwaltsordnung, or BRAO). Attorneys may not provide information concerning matters related to their mandates unless their client has expressly released them from this duty of confidentiality. In court proceedings, attorneys have the right to refuse testimony where their testimony would concern facts to which the confidentiality obligation refers.

Whereas the model declaratory action is limited to establishing general factual and legal issues and therefore does not itself provide for enforceable remedies, the redress action introduced under the Consumer Rights Enforcement Act allows for direct relief to be obtained on behalf of consumers and small businesses. Specifically, the qualified entity may pursue claims for monetary damages, but also non-monetary remedies such as repair of defective goods, termination of contracts, price reductions, or reimbursement of the purchase price.

In Germany, both the model declaratory action and the redress action contain mechanisms that allow for settlement and alternative resolution of dispute, but the scope and effect differ.

In the model declaratory action, settlements are explicitly encouraged. Once the higher regional court has admitted the action, the parties may reach a collective settlement at any stage of the proceedings. Such a settlement must be submitted to the court for approval. The court assesses whether, in light of the facts of the case and the interests of the affected consumers, the proposed settlement represents a reasonable solution to the dispute. Otherwise, the court will reject the settlement. If approved, the settlement is binding on all registered claimants, unless they exercise their statutory right to opt out within a period of one month after the settlement terms have been published in the claims register. The settlement mechanism is important in practice because the model declaratory action itself does not provide damages or other relief, so a settlement may offer consumers more immediate compensation without the need for follow-on individual proceedings.

The redress action also embeds settlements into its procedure. After issuing a basic redress judgment, which establishes liability in principle and sets eligibility criteria, the court will invite the parties to submit a settlement proposal. As with the model declaratory action, any settlement must be approved by the court to ensure adequate consumer protection. If no settlement can be reached, the court proceeds to a final redress judgment and orders implementation proceedings under the supervision of an administrator.

In Germany, the nature, binding effect and enforceability of judgments in collective redress proceedings depend on the type of action pursued.

Enforcement of Judgments in the Model Declaratory Action Procedure

In the model declaratory action, the higher regional court delivers a declaratory judgment. This judgment establishes general legal or factual issues (such as whether a company is liable in principle) but it does not grant individual damages or specific performance. The judgment is binding on the qualified entity, the defendant, and all consumers who registered their claims in the official register before the statutory deadline. Non-registered consumers remain unaffected.

As the judgment is only declaratory, it cannot be directly enforced. Registered consumers must initiate follow-on individual proceedings to obtain specific remedies such as damages or reimbursement, relying on the declaratory findings as a binding precedent. Enforcement mechanisms are therefore not available at this stage, given that there is no operative award to enforce.

Enforcement of Judgments in Redress Actions

The redress action goes significantly further. After a court finds the action admissible and justified, it issues a basic redress judgment, which sets out liability in principle and defines eligibility criteria for consumers and small businesses. This is binding on all registered participants.

If no settlement is reached thereafter, the court issues a final redress judgment, which not only resolves the legal dispute but also orders the commencement of implementation proceedings. In this phase, a court-appointed administrator establishes an implementation fund, verifies eligibility of registered claimants, and distributes compensation. The final judgment includes a costs decision and is directly enforceable against the defendant. Enforcement does not occur through the individual consumers but, rather, through the implementation mechanism supervised by the court and carried out by the administrator.

Germany is pursuing a modernisation agenda with regard to civil procedure ‒ notably, through a Reform Commission established in 2023. The Reform Commission’s January 2025 final report presents specific recommendations for a Zivilprozess der Zukunft (future civil litigation process), including the creation of a nationwide justice portal as a single access point for court services, a uniform cloud-based communications platform for case files, and the transition from static PDF pleadings to machine-processable digital procedural documents. The report also proposes:

• strengthening specialised chambers;
• early judicial case management measures;
• more efficient evidence procedures via digital registries;
• the introduction of a digital enforcement register; and
• reforms to service of and mandatory publication of court decisions (with anonymisation).

At present, there are no concrete legislative proposals for specifically reforming collective redress proceedings in Germany. The redress action under the Consumer Rights Enforcement Act was only introduced in October 2023 to implement the EU Representative Actions Directive and remains in its early phase of application.

During the past three years, Germany has experienced a transformation in its system of collective redress, shaped by both new legislation and evolving litigation practice. The most significant development is the introduction of the redress action under the Consumer Rights Enforcement Act, which for the first time enables qualified entities to pursue direct monetary and non-monetary relief on behalf of consumers and small businesses. Although only a limited number of such actions have been initiated so far, they highlight a growing willingness of consumer associations to use this tool in high-volume disputes, particularly in industries such as energy supply, telecommunications, and digital services.