Photovoltaics
without
craftsmen’s register?
Photovoltaics
without
craftsmen’s register?
from
Is a business license sufficient to offer photovoltaic systems, or is more required? Why doesn’t it help to outsource the actual work to registered subcontractors? And what does all of this have to do with customer reviews on your own website?
What was it about?
On its website, a company advertised photovoltaic systems as a turnkey service, ranging from planning and installation to commissioning and maintenance—specifically noting that it used its own team and did not use subcontractors. However, the company was not registered in the craftsmen’s register, neither for roofing nor for electrical work. A temporary registration for electrical work existed only from mid-January to the end of March 2025 and was subsequently revoked ex officio.
A self-regulatory body of the German business community, registered as a qualified trade association, issued a cease and desist letter to the company, demanding that it cease its activities and reimburse the costs of the cease and desist letter due to violations of competition law. Since the company did not issue a declaration of cessation, the case went to trial. The Mainz Regional Court upheld the complaint, and the Koblenz Higher Regional Court has now completely dismissed the company’s appeal.
Why is photovoltaic installation a trade that requires a license?
The core of the Judgment of June 2, 2026 – Case No. 9 U 1015/25 The issue before the Higher Regional Court of Koblenz is whether the activities performed fall within the protected scope of the roofing and electrical trades. Both trades are listed in Appendix A of the Crafts and Trades Code as crafts requiring a license. Anyone who independently performs essential activities of such a craft as a regular business must be registered in the Trade Register.
The court clarifies that the planning, installation, commissioning, and maintenance of photovoltaic systems—particularly those installed on roofs—fall within the core scope of both crafts. The decisive factor is what defines the nature of a craft. To determine this core area, the court refers to the relevant training and master craftsman regulations. In both the training program for roofers and the training program for electronics technicians or electrical engineers, the assembly, installation, and commissioning of energy-generating systems are explicitly established as core components of the profession. These are therefore not secondary or peripheral activities, but rather essential activities within the meaning of the Crafts and Trades Code.
It is worth noting that the distinction between above-roof and in-roof systems is irrelevant. This is because even when installing an above-roof system, holes are drilled into the roof battens and the system is bolted in place, thereby altering the roof structure. Therefore, the classification guidelines from the industry and crafts organizations discussed by the parties were not decisive.
The planning, installation, commissioning, and maintenance of photovoltaic systems—particularly those installed on roofs—are to be classified as essential activities of the roofing and electrical trades, respectively, within the meaning of the Crafts and Trades Code.
Is it safe to outsource work to registered subcontractors?
This is one of the most important practical conclusions. For the court, it was not decisive whether the subcontractors were themselves registered in the craftsmens’ register or what qualifications their employees held. The ruling cites two reasons for this:
First, the company had advertised that it worked exclusively with its own permanent team and without subcontractors. From the perspective of the average consumer, this gave the impression that the work was performed in-house. The company must be judged based on this specific advertising claim.
Second, the registration requirement generally depends solely on the registration itself, not on whether the professional qualifications have been met. Registration has the effect of establishing legal rights. Therefore, even the reference to an allegedly qualified employee was of no help. What is protected is the reliance on the fact that the necessary qualifications were verified and confirmed through a state-administered procedure. However, this verification was lacking.
What role did customer reviews play?
In addition to the issue with the trade registry, the court raised a second concern. The company had published customer reviews on its website without explaining whether and how it ensures that these reviews come from real customers. Under the law, this information is considered essential when a company makes consumer reviews available. Reviews have a significant influence on purchasing decisions, which is why their reliability is of particular importance to consumers.
The fact that the company modified its website during the proceedings—for example, by adding Google as a source of the reviews—did not eliminate the risk of recurrence. Without a cease-and-desist declaration subject to a penalty, the legal presumption remains that an infringement that has occurred once may recur. A mere modification of the website or a verbal commitment is not sufficient for this purpose.
Conclusion
Anyone who plans, installs, or maintains photovoltaic systems should check before taking on any job whether registration in the craftsmen’s register as a roofer or electrician is required. Providing a complete service from a single source typically triggers this requirement.
Advertising with your own team and without subcontractors creates a commitment to your own company. Anyone who advertises in this way must be allowed to provide the service independently and cannot subsequently rely on registered third parties.
Anyone who displays customer reviews on their website should clearly and unambiguously state whether and how the authenticity of the reviews is verified.
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