A waste fee notice from the city of Bremen that was created purely automatically is unlawful. This is the result of a decision by the Administrative Court (VG) of Bremen (Ref.: 2 K 763/23 of 14 July 2025). This is because a decision that is made without human intervention violates the European General Data Protection Regulation (Art. 22 para. 1 GDPR). The standard is intended to protect data subjects from decisions that adversely affect them and are based solely on automated processing. It was irrelevant to the court that the citizen's data had previously been recorded by employees and that the decisions had also been randomly checked by humans.

However, the Bremen citizen was unsuccessful with his complaint: In the objection procedure, a clerk had dealt with his decision. This cured the defect, as the initial and appeal proceedings formed a single unit in terms of administrative law.

„In principle, it is possible for authorities to issue automatically generated waste notices. However, they need legal authorisation and suitable data protection and security measures to do so,“ explains Rechtsanwalt Dr Dominik Lück. Bremen does not yet have such authorisation.