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German Freedom of Information Act: redaction and reasons

Oct 18, 2026 · 4 min read

Under the German Freedom of Information Act, the federal Informationsfreiheitsgesetz (IFG), an authority that releases documents in part redacts them, and it must give reasons for the partial refusal. Good practice goes one step further and shows the ground for each redaction where it sits. This guide is for officers of German federal bodies: what the IFG protects, where the duty to give reasons comes from, and how to record the ground on each cover and in the file. The basics for every kind of redaction reason are in how to justify redactions. The IFG is quoted as in force on October 18, 2026; the statutes are German, so the links go to the German text.

What the IFG protects: sections 3 to 6

Everyone has a right of access to official information held by federal authorities (§ 1 IFG). The exceptions are in four sections:

  • § 3, special public interests, such as international relations, internal and external security, ongoing court proceedings, the deliberations of authorities, and duties of secrecy or confidentiality (§ 3).
  • § 4, the authority’s decision-making process: drafts and work that directly prepare a decision, as long as early disclosure would defeat it (§ 4).
  • § 5, third parties’ personal data (§ 5, more below).
  • § 6, intellectual property and trade or business secrets; access to the latter only with the consent of the person concerned (§ 6).

When a ground covers only part of a document, § 7(2) IFG applies: access is granted to the extent it is possible without disclosing the information that must stay protected. That is what redaction does.

German Freedom of Information Act redaction: partial refusals need reasons

Every redaction refuses part of the request. § 9 IFG sets the procedure for that decision: notice within the time limit, a statement of whether and when access may be possible later, and objection and court action as remedies.

The duty to give reasons comes from § 39(1) of the Administrative Procedure Act (VwVfG): a written or electronic administrative act must state its reasons, giving the essential factual and legal grounds for the decision. For discretionary decisions, it should also show the points the authority considered.

Show the exemption ground on each redaction

The law asks for reasons in the decision. Writing the ground on each redaction is practice, not an express statutory duty. The IFG guide of the Federal Ministry for Economic Cooperation and Development (BMZ), an internal guide for that ministry, puts it this way: for each redacted passage or each withheld document, the relevant IFG section must be given and the reasons stated for the circumstances of the case. For paper copies, it says each redacted passage gets a note naming the IFG provision the redaction rests on.

That way, the requester sees which section carries which gap.

Third parties’ personal data (§ 5 IFG)

Under § 5(1) IFG, access to personal data may be granted only where the requester’s interest in the information outweighs the third party’s interest worth protecting, or where the third party has consented. Special categories of data under Article 9 GDPR need express consent.

Two points keep you from redacting too much:

  • Officials handling the matter. Their name, title, academic degree, job title and function, office address and office phone number are not excluded, as long as they reflect official activity and no exception applies (§ 5(4) IFG).
  • The requester’s consent. If the requester agrees to have third parties’ data made unrecognizable, access is granted to the rest (§ 7(2), second sentence, IFG). The BMZ guide asks for this consent to avoid a third-party consultation.

Länder and municipalities: their own laws

The IFG binds federal bodies only. The Federal Commissioner for Data Protection and Freedom of Information (BfDI) says so plainly: under the IFG, only federal bodies doing public administration must give information; the Länder have their own laws for access to information held by state and municipal authorities. One example is the North Rhine-Westphalia Freedom of Information Act (IFG NRW) of 2001. For state and municipal bodies, the exceptions of the relevant state law apply.

Reasons on the cover, a log for the file

In Dress Docs, each cover can carry its reason, printed on the cover itself: your own wording, or an entry from an exemption set for information-access requests. Check every ground against the statute; whether it holds in the case is your decision. The reason is part of the same flat image as the cover, and nothing under it stays readable.

The redaction log records what you removed, where and why: covers, reasons, pages and date, with no content from the document. You save it to your own files, for the case file. That fits the BMZ guide’s point that the IFG file must show which information the requester had access to. More in the redaction log. How UK law handles the same question: FOI redaction exemption codes.

Reasons and the log are in Pro, Team and Organization (see pricing). For your data protection and IT review: read the compliance pack.

This article is not legal advice. Whether an exception applies in a given case is your authority’s decision.

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