Summary

  • Five documents reviewed on 13 November 2026 — DENIC's statute page, its 2024 statute PDF, the German cooperative act, IANA's .de record and DENIC's imprint — contain no statute, permit, designation or ministerial decision conferring the .de registry function on DENIC eG.
  • The power to change DENIC's statute comes from § 16 of the cooperative act: the Generalversammlung alone may resolve it, the baseline is three quarters of votes cast, and the amendment has no legal effect until it is entered in the cooperative register.

DENIC's legal page publishes its statute in full — twenty-four sections, with a link to the PDF — on the statute page inspected for this piece. Section 2 is headed „Zweck und Gegenstand“, purpose and object, and it opens with a sentence the page displays verbatim: Die Genossenschaft verwaltet und betreibt als Registrierungsstelle Internet-Domains. The cooperative administers and operates internet domains as a registry.

Everything else in that section is the job description that follows from the first sentence. Technical and member-support functions. Information for registrants. Representation of the German internet community. No profit-making purpose. The 2024 statute PDF adds where the money goes: cost coverage, and securing the cooperative's existence. And a door for anything new — additional functions require the Generalversammlung's approval.

One word deserves attention because it keeps getting translated away. The statute's name for the members' assembly is Generalversammlung, not Mitgliederversammlung. The same term runs through German cooperative law. Anyone writing about "the members' meeting" is paraphrasing; the document does not say that.

Three organs, one of which decides who gets in

Section 12 lists the organs: Vorstand, Aufsichtsrat, Generalversammlung. The board manages, the supervisory board supervises, and section 18 puts the exercise of members' rights in the assembly.

Membership is not open. Section 3 restricts ordinary membership to persons or entities that manage .de domains, are not economically connected with more than two other members, and are financially stable. Joining takes a written declaration and an admission decision by the Vorstand, with an appeal route to the Aufsichtsrat; members of those two bodies are separately eligible.

So the electorate that governs .de's rulebook is a filtered set of domain managers, admitted by the executive and appealable to the supervisors. That is not a criticism; it is the structure, and it explains the rest.

The majority is not where you would look for it

Section 19(5) gives the assembly a general rule: simple majority of the votes cast, unless the law or the statute requires a larger one. Read alone, that looks like a low bar for everything.

It is not the amendment rule. Neither the statute page nor the extracted PDF contains a separately worded clause headed amendment of the statute, and a text search of the PDF for Satzungsänder returns nothing. The sections retrieved for this piece state no DENIC-specific amendment threshold at all.

The threshold comes from outside the cooperative's own text. Section 16(1) of the cooperative act is quoted verbatim in the reviewed record: Eine Änderung der Satzung oder die Fortsetzung einer auf bestimmte Zeit beschränkten Genossenschaft kann nur durch die Generalversammlung beschlossen werden. Only the Generalversammlung may resolve an amendment. Section 16(2) sets at least three quarters of the votes cast for the amendments it names; section 16(3) requires nine tenths to introduce or expand certain member obligations, and at least three quarters for ongoing contribution duties; section 16(4) sets three quarters for other amendments — unless the statute establishes other requirements.

That final proviso is the honest complication, and the reviewed documents do not resolve it. A general simple-majority rule in section 19(5) and a statutory default of three quarters that yields to statute-specific rules sit in the same file without a sentence saying which governs an amendment. The baseline is three quarters. Whether DENIC's own text moves that baseline is a question these documents leave open, and this piece leaves it open too.

Then the gate. Section 16(6): no legal effect before entry in the cooperative register.

The pen ends at a register in Frankfurt

DENIC's imprint states where that register is, verbatim: Eingetragen unter Nr. 770 im Genossenschaftsregister, Amtsgericht Frankfurt am Main. Number 770, local court Frankfurt. That is the cooperative's own publication; the register extract itself was not obtained, so the number is DENIC's statement about itself and is reported as such.

Assemble the sequence. Members vote. Three quarters of those cast at minimum for an ordinary amendment, higher for the obligations section 16(3) names. The full amended text goes to the register. Until the entry, the change has no legal effect.

Nothing in that sequence requires a ministry, an agency or a permit. Nothing in it hands an outside supervisor a power to vary a term — because, in these five documents, there is no term to vary. The Danish, Kenyan and French files at this desk each turned up an instrument outside the operator that fixed or governed its role. Nothing of that shape appears here.

What the root zone states, and what it does not

IANA's .de record is the one document reviewed here that names DENIC's role to the outside world. It displays status Active, lists DENIC eG as Manager, lists DENIC eG again as the technical organisation, gives „Vorstand DENIC eG“ as administrative contact, sets Technical Status Delegated, and displays a last update of 4 August 2026.

Read the fields for what they are: a manager, a technical organisation, a technical status, an administrative contact. No term of years. No service level. No financial term. No statutory authority. The record says who is delegated to. It does not say on what terms, for how long, or under whose supervision.

The absence, and the size of it

Across the five documents reviewed on 13 November 2026, there is no statute, statutory ordinance, permit, designation or ministerial decision conferring the .de registry function on DENIC eG.

That sentence has a boundary, and the boundary is the point. It describes these five documents. It does not say that no German instrument exists, and it should not be read that way. What it does say is narrower and still consequential: in the record that defines DENIC's own powers, answerability runs to members and to a register, and the only outside document naming the operator names a role, not a relationship.

The same five documents contain no member count, no registration volume, no fee, no price, no revenue figure and no service-level percentage. So there is no ratio, no share and no per-domain arithmetic anywhere in this piece.

One further limit, stated plainly: only sections 2, 3, 12, 13, 15, 18 and 19 of the statute were reported retrieved, and the statute displays no adoption or publication date — the 2024 marker is the filename.

Why the mechanism outranks the label

"Cooperative" has been on this desk's record since July. The mechanism is the newer finding. If an amendment needs three quarters of a filtered membership plus a court register entry, the practical question for a registrar or a registrant is not who supervises DENIC. It is who can assemble that majority — and what happens to the rulebook when nobody can.

That is a different shape of accountability from a term fixed by an instrument. It is slower, it is internal, and it does not expire on a date somebody in an office can move. The rulebook of .de is held by the people who manage .de domains, counted in a room, and made real by a clerk's entry. Nothing in the reviewed record gives anyone else the pen.