According to ibi research, German shoppers made an average of 5.1 online orders per month in 2025. While they often place repeat orders with the same retailer, they also make many one-off purchases at new outlets. Having to create a customer account for a one-time order can further complicate the process.

In this article, you’ll learn whether and when German online stores must offer guest checkout, what data protection requirements apply to customer accounts and checkout flows, and how guest checkout can influence conversion rates.

Key takeaways

• The General Data Protection Regulation (GDPR) limits the processing of personally identifiable information to what is necessary for processing.
  
• The German Data Protection Conference (DSK) states that retailers in Germany generally need to offer guest checkout or an equivalent alternative that does not require a customer account.
  
• If a store has customer accounts, the scope and duration of the data processing must be covered by the respective purpose and a suitable lawful basis.
  
• In addition, the scope of data collection permitted during checkout must align with the specific payment and delivery method.
  
• Guest checkout can reduce checkout hurdles and lower the risk of cart abandonment.
  

Do German online stores have to offer guest checkout?

Guest checkout lets customers buy from an online shop without creating a permanent account. The DSK takes the position that retailers in Germany generally need to, in principle, offer guest checkout or an equivalent option. At the same time, there is no absolute legal requirement to provide that option.

Data protection regulations

From a data protection perspective, the argument for guest checkout rests mainly on the principle of data minimization under Article 5(1) of the GDPR, which requires that personally identifiable information be adequate and limited to the amount necessary. Article 6(1)(b) of the GDPR could also provide a lawful basis for data processing which is necessary for the performance of a contract. The DSK states that making a one-off transaction does not necessarily require a permanent customer account.

Legal definition

The DSK therefore believes that web retailers must generally offer guest checkout. However, case law does not fully reflect this view. The District Court Hamburg, for example, has ruled that online stores have no obligation to offer guest checkout (judgment of February 22, 2024 - 327 O 250/22). The Higher Regional Court of the Free and Hanseatic City of Hamburg affirmed this ruling in 2025.

Nonetheless, retailers still have to assess whether they need to provide guest checkout or an equivalent alternative, along with the lawful basis for requiring customers to create an account and for any related data processing.

If an online shop nevertheless decides to require customers to set up a permanent account, it must ensure that this is necessary for the purpose for which the information will be processed and that it complies with the principles of data minimization. In some cases, an online shop might require customers to create an account if setting up an account and processing account-related data is necessary to perform a specific contract. The DSK lists specialist retailers serving particular professional groups, for instance.

Guest checkout and customer accounts under data protection law

From a data protection perspective, the primary issue is distinguishing a one-off guest purchase from a customer account maintained permanently. With a guest order, the retailer collects the information necessary for that order. This could include a name, delivery address, and payment details. Processing of this data is permitted insofar as it is necessary to perform the purchase contract. Statutory retention obligations might give a controller grounds to store this data beyond the transaction.

A registered account, by contrast, can exist beyond the performance of the individual contract. Account details are stored permanently and connected to a personal login. This entails additional data processing that generally is not necessary for an individual order.

Requirements to obtain consent

Setting up and using a permanent account requires an appropriate lawful basis under Article 6(1) of the GDPR. Consent could provide this lawful basis, for example. This consent must be clear, informed, and given freely. Consequently, an online retailer cannot simply require all customers to set up an account to place an order.

It is particularly important here whether consent has been given freely under Article 7(4) of the GDPR, which requires assessing if contract performance is conditional on consent to processing data unnecessary for that contract. Asking customers to create an account, when the order can be processed without one, might be problematic from a data protection perspective.

The DSK accordingly believes that, as a general rule, shoppers must have an equivalent way to place an order without creating a permanent account. The simplest solution is a guest checkout option that allows the online store to complete the purchase contract without permanently storing the customer’s information for subsequent orders.

What data can be collected when setting up a customer account?

The principle of data minimization affects how you configure any account. Personally identifiable information must be adequate, relevant, and limited to what is necessary. This means that online stores have to determine which details are actually required to open an account.

Therefore, not all information that helps manage accounts from a technical or organizational perspective is automatically necessary under data protection law. A retailer on the web has to distinguish between data necessary to perform the contract and data stored for subsequent orders or to enable users to use additional functions.

Optional information and additional features

It is important to differentiate between mandatory and optional information. Mandatory fields have to be limited to details that are necessary for the purpose for which the data is processed. You could also collect additional information as optional, provided you have a corresponding lawful basis for the collection.

Customer account features, such as order histories or storing multiple delivery addresses, might also constitute further data processing. While they could benefit users, they are not strictly necessary for the first order.

This gives online shops a concrete benchmark for assessing their processes. When designing the checkout process, they need to establish what information is required and why. The more features an account has beyond simply processing a specific order, the more the extra processing requires detailed justification under data protection law. Guest checkout neatly separates customers with an account from those without. It allows shoppers to buy as guests instead of creating a permanent user profile to access additional features. Accordingly, the scope of personally identifiable information can be limited to what is necessary for each individual order.

What information can an online store request during checkout?

During checkout, an online store in Germany might request information necessary to process the purchase. The required details depend primarily on the chosen delivery and payment method. To illustrate, you might need a name and address to ship physical goods, but you might not need a delivery address for a digital service. Certain payment methods, such as credit card payments or SEPA Direct Debits, also collect certain details to process payment.

In addition, you could process personally identifiable information during checkout when it is necessary to perform the purchase contract. The retailer must therefore determine which details each order actually requires. If the store requests other information, it has to be clear to the customer if the field is necessary to complete the purchase or simply optional.

How do guest checkout and customer accounts influence conversion rate?

Retailers in Germany provide guest checkout for reasons beyond complying with data protection law. From a conversion perspective, a simple checkout flow that doesn’t require customers to register offers clear benefits.

Setting up an account poses an additional barrier for new customers. If they want to make a one-off transaction, they might see registering as an unnecessary hassle and abandon their cart. Along with high shipping costs, limited payment methods, and technical issues, a complicated checkout is one of the main reasons online shoppers say they don’t complete a purchase. In a Baymard Institute survey, 18% of respondents said they abandoned a purchase because they don’t want to create an account.

Advantages of a flexible checkout

Of course, a customer account does provide benefits for returning shoppers. Stored addresses, order histories, and other features can simplify future purchases. So it is not just whether an account exists; it is also how it is integrated into the checkout flow.

Therefore, it might make sense for online shops in Germany to offer both choices. Shoppers can then decide between setting up an account or checking out as a guest. Retailers can also let customers register after they complete their purchase, so registration doesn’t slow down the actual process.

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FAQs about guest checkout in online stores