Market study · Weight-management telehealth
An outside-in benchmark of eight operators prescribing GLP-1 weight-management treatment to patients in Germany, examined on identical terms. Consultation covers the online form and what moves patients through it. Policies covers eligibility, exclusions, transfer-in, switching and the rest of the clinical rule set. Advertising covers how operators market a service the law largely forbids them to market, and how they avoid enforcement. Built from funnel and advertising crawls of 14 and 15 August 2026 and their follow-up of 19 and 20 August, published legal and regulatory research, and operator-supplied internal material where marked.
Eight operators, no solved form. The German field splits into two incomplete strategies. Four operators run a light questionnaire and carry the legal risk of a questionnaire-only prescribing decision. One pushes the clinical depth into a mandatory video call and carries the operational cost instead. Only one attempts both, at around twenty-four screens, and it is the longest form in the market by a wide margin.
On one design choice the field has converged. Three of the eight tell the patient early whether they qualify: GoLighter returns a verdict on the screen immediately after height and weight, DoktorABC calculates a body mass index live in the page and states that it qualifies the patient, and Fit fürs Leben declares eligibility after two clinical questions. Two more give the verdict at the end. The operators that do not return anything are taking the patient's two most personal numbers and giving nothing back at the point where forms usually lose people.
Wellis's own German service sits outside this eight-operator crawl and is assessed here on its public marketing and legal pages rather than a completed walkthrough: its intake questionnaire, a one-question-per-screen format in the same family as MedExpress's and Voy's, could not be progressed past the first screen this round, so its funnel-level behaviour on eligibility feedback, consent structure and transfer-in evidence is not established either way. What the public pages do state: a homepage body mass index calculator ahead of the funnel, in the same family as GoLighter's and DoktorABC's, though without a stated qualifying threshold or verdict on the page itself; a three-step process description - short online form, then a free phone consultation, then doctor review - that promises contact with a clinician earlier and more explicitly than any of the eight; a named clinical team carrying Dutch BIG registration numbers; and prescribing and dispensing run through Netherlands-registered doctors and Wellis Pharmacy B.V. rather than a German entity, which is the same cross-border structure the pending Court of Justice reference concerns. Section 03 sets that out in more detail, and section 11 records the evidence gap plainly.
The follow-up crawl closed the largest gap in the earlier report. GoLighter's clinical questionnaire, previously recorded as unreachable, was captured in full: ten questions on a separate prescribing domain, with an outcome-graded prior-use question and an exclusion set wider than its question count suggests. It is the clearest evidence in the file that a short form and a thin clinical screen are not the same thing.
Eight operators were walked end to end on identical terms with synthetic intake data: MedExpress, Zava, GoLighter (commercial brand of Wellster Medical), Fit fürs Leben, DoktorABC, Dokteronline, Voy and Juniper. TeleClinic was checked manually and set aside as a different service category - a general reimbursed consultation rather than a GLP-1 prescribing funnel. Every crawl stopped at the first gate that could not be passed honestly: payment, account creation where terms forbid it, identity verification and photograph upload. No real or synthetic identity document or photograph of a person was ever generated or uploaded.
Wellis - not to be confused with GoLighter's parent Wellster Medical, a different company - is not one of the eight and was not walked end to end. Its public marketing pages, category page and terms were read on 31 August 2026, and an attempt to walk its intake questionnaire with the same synthetic data stalled on the first screen for reasons that could not be resolved this session, so it is treated the way this report treats Dokteronline and Juniper where their funnels went unreached: recorded as unknown rather than absent, and never averaged against the eight.
Three claims carry different weight and are marked accordingly. Findings sourced to page text captured during a crawl are stated plainly. Findings drawn from an operator's own internal planning material, supplied for this study, carry an INTERNAL marker - they are not publicly observable and could not be checked against a rival on equal terms. Legal holdings rest substantially on court press releases and professional commentary rather than full published judgments, and are flagged where the underlying text was not read.
The reader most likely to misuse this document is one who reads a design difference as a preference. In several places it is not: German law removes options from every operator in this market, and a report that praised one operator for restraint or criticised another for caution would be wrong in both directions. Section 03 separates the two before any comparison is made.
Three design choices in this market look like competitive positioning and are not.
Two further constraints shape every funnel here. Weight-management GLP-1 medicines are excluded from statutory reimbursement as lifestyle medicines under §34 SGB V, following the Gemeinsamer Bundesausschuss decision of 21 March 2024 in force from 15 June 2024, so every journey is private self-pay and the form is a commerce funnel as much as a clinical one. And the Heilmittelwerbegesetz restricts claims of certain success (§3), advertising of remote treatment (§9) and advertising of prescription-only medicines to the public (§10), which is why several operators' approach to social proof is a risk rather than a tactic. That is the subject of the Advertising view.
Health data adds a third layer that shows up directly in form design. Explicit, separable consent is required, so an itemised consent step is the expected construction and a single bundled tick is both a compliance question and a conversion advantage the operator taking it is enjoying at the others' expense.
Each row is something an operator does at a named step to move more patients through. Nature records where the row comes from: an internal decision means the operator could have done otherwise; a regulatory requirement means German law pushes every operator to it regardless of preference.
| Mechanism | Who does it | Wellis (public pages only) | Nature |
|---|---|---|---|
| Early eligibility feedback | Three of eight. GoLighter returns a verdict on the screen after height and weight - "on your body mass index you are suitable for GLP-1 medicines" - and runs a calculator on its homepage before the funnel starts. DoktorABC returns a live body mass index and a qualifying message in-page. Fit fürs Leben declares "you are eligible" after two clinical questions. Voy and Juniper give the verdict only at the end. MedExpress sits at the other end of the field: two numbers are taken and nothing is returned. | CATEGORY ONLY A homepage calculator sorts height and weight into a weight band (underweight to obesity); no qualifying verdict. In-form behaviour not observed - the questionnaire stalled at screen one | Internal decision |
| Progress signalling | Fit fürs Leben, numeric percentage. DoktorABC, named four-stage bar. Zava, named six-stage bar. Juniper, "three simple steps". Four of eight show nothing at all. MedExpress runs the weakest form observed: a bar with no number and no step count, across all fourteen screens. | ORDINAL ONLY A small boxed number counts the screen reached; no total or percentage seen before the questionnaire stalled | Internal decision |
| Named clinician inside the form | Voy alone. A named medical lead carries the explainers, the rejection screen and the eligibility-success screen. Juniper names a medical director on the homepage, Zava three doctors as content-review bylines, Dokteronline a pharmacist with a Dutch register number, and GoLighter a nutrition coach rather than a doctor. MedExpress names three doctors with registration numbers, but only on trust pages outside the questionnaire itself. | OFF-FORM Four staff named with Dutch BIG registration numbers on the medical-team page; not confirmed inside the questionnaire, which was not reached | Internal decision |
| Micro-copy against under-reporting | DoktorABC instructs patients to answer yes on the eating-disorder question even if not medically confirmed - the most useful single line observed anywhere in the field - and is the only operator asking whether a prescription has been refused elsewhere. Zava tells patients not to estimate their weight and to re-weigh if unsure. MedExpress glosses every clinical term in plain language, ahead of all seven rivals, though it carries no equivalent nudge against under-reporting. | NOT OBSERVED Questionnaire not completed | Internal decision |
| Question economy | Zava, eleven questions on one scroll. GoLighter, ten on a separate prescribing domain. Fit fürs Leben, two clinical questions before a preliminary result. Voy, around twenty-four screens, the longest in the market. MedExpress runs fourteen screens, one question per screen throughout. | UNKNOWN COUNT One question per screen, the same format as MedExpress and Voy; total screens unknown, since the questionnaire could not be advanced past screen one | Internal decision |
| Itemised consent | DoktorABC is the most granular: separate truthfulness, liability, doctor-notification, support-staff access and delivery-route clauses. Voy runs a terminal itemised list including an explicit off-label acknowledgement. Zava bundles terms, withdrawal notice and privacy into one tick. GoLighter uses a single "I understand and confirm" button rather than a checkbox, and takes acceptance of its prescribing entity's terms in the click that starts the questionnaire. MedExpress bundles one combined tick with a separate health-data tick, spread over four screens. | NOT OBSERVED In-form consent structure not reached. Its terms separately require the patient to confirm intake answers are accurate, warning that inaccurate answers "can seriously endanger your health" | Partly regulatory |
| Pharmacy choice stated in the flow | Zava is broadest: free same-day collection from any of 6,500 German pharmacies with electronic transmission to the patient's chosen pharmacy, partner-pharmacy shipping, or a paper prescription by post for a fee. GoLighter offers a prescription-only route so the patient fills at their own pharmacy, and a route to find a local doctor out of the online funnel entirely. DoktorABC states the choice in the clearest single sentence. MedExpress states nothing. | NOT STATED Its terms describe the medicines contract as being with Wellis Pharmacy B.V. specifically; no alternative-pharmacy option appears on the pages reviewed | Regulatory requirement |
| Transfer-in evidence | Voy runs the most rigorous policy: a copy of the last prescription, an invoice, or a photograph of the dispensing label showing name and date, otherwise the lowest starting dose. GoLighter grades prior use by outcome instead - more or less than four per cent of body weight lost in three months - and asks for no documents. Zava relies on self-declaration with a two-week gap rule. MedExpress asks the question fifteenth and attaches no consequence to a yes. | NOT OBSERVED Questionnaire not completed | Internal decision |
| Evidence deferred out of the form | GoLighter requires a photograph but offers "upload later" and chases it by reminder email, stating plainly that the medical team cannot assess the request without it. Zava asks for photographs on a public process page and at first request rather than inside the assessment. Both keep a hard evidence requirement without letting it stop the form. MedExpress asks for nothing, at any point. | NOT OBSERVED No photograph requirement appears on the marketing or legal pages reviewed; the questionnaire itself was not reached | Internal decision |
| Pre-filled repeat questionnaire | Zava alone. A prompt at the top of the assessment - "did you have a prescription from us in the last twelve months? Save time now with your pre-filled repeat questionnaire" - routes returning patients to a populated form rather than a blank one. MedExpress instead sends a returning patient straight to a bare sign-in wall on screen one. | LOGIN LINK A site-wide "Anmelden" (log in) link exists in the header; whether a returning patient reaches a pre-filled form was not reached | Internal decision |
| Mid-funnel off-ramp | Voy alone, with explicit "I do not want to continue" buttons at the contraception and thyroid-monitoring information screens rather than only at the end. MedExpress has none. | NOT OBSERVED Questionnaire not completed | Internal decision |
| Payment only on approval | DoktorABC states on its public category page that billing follows the doctor's approval and that costs arise only if the treatment is approved. Juniper offers a twenty-five-day money-back guarantee instead, conditional on medical grounds and a doctor's certificate; GoLighter a 180-day guarantee conditional on weight lost. MedExpress takes the card before the prescribing decision is made. | REFUND, NOT DEFERRAL Its FAQ promises a full refund if treatment proves not medically suitable, which reads as payment taken up front and returned on refusal rather than billing withheld until approval. Not confirmed against an actual payment screen | Internal decision |
| Save and resume | Nobody has a working one. Juniper comes closest by taking name and email before any clinical question, which creates a persistent profile and a remember-this-device option - the architecture that would allow resumption, though resumption itself could not be evidenced because the quiz stalled. MedExpress restarts a returning patient at screen one, the same as the rest of the field. | NOT OBSERVED Questionnaire not completed | Internal decision |
| Signalled route to a clinician | Fit fürs Leben makes a video call mandatory and says so on the first screen and in its marketing copy. DoktorABC keeps one as a doctor-triggered option. Neither is presented as friction; both are presented as care. MedExpress's journey simply ends at a submit button. | STATED, OFF-FORM The category page describes a free phone consultation with medical staff before doctor review, ahead of any of the eight on how early it is promised; whether the questionnaire itself signals it before submission was not reached | Regulatory requirement |
Sources: funnel crawl page text, 14 and 15 August 2026, follow-up 19 and 20 August 2026, for the eight crawled operators. Wellis column from its public marketing and legal pages, read 31 August 2026; its questionnaire could not be advanced past the first screen this round, so cells marked "not observed" are unknown rather than absent.
| Operator | Form architecture | Steps to a gate | Progress | Clinician contact | Named clinician |
|---|---|---|---|---|---|
| Voy | One question per screen, heavily branched widget | ~24 question screens | Not confirmed | None evidenced | One, used as the brand voice throughout |
| MedExpress | One question per screen | 14 clinical screens | Unlabelled bar | None signalled | Three, with registration numbers, off-form |
| Wellis | One question per screen (not advanced past screen one) | Unknown - not reached | Ordinal number only, no total seen | Free phone consultation, stated on category page, off-form | Four staff named with Dutch BIG numbers, off-form |
| DoktorABC | Single continuous scroll | ~15 items and blocks | Named four-stage bar | Doctor-triggered | None named on the pages read |
| Zava | Single continuous scroll | 11 questions | Named six-stage bar | None evidenced | Three, as content-review bylines |
| GoLighter | Commercial front, then prescriber on a separate domain | 10 questions; terms accepted before they load | None evidenced | None evidenced | None; a nutrition coach is named |
| Fit fürs Leben | Single stepper | 2 clinical questions to a preliminary result | Numeric percentage | Mandatory video | One, doctor and supervisory-board chair |
| Juniper | Quiz app on a separate subdomain | Name and email before any clinical question | "Three simple steps" | Not reached | One, medical director, on the homepage |
| Dokteronline | Retail catalogue and cart | Account created before any clinical question | Checkout label only | Not reached | One, named pharmacist with a register number |
Screen count is not clinical rigour, and the table is ordered longest to shortest to make that visible rather than persuasive. Fit fürs Leben's two questions defer the history to a call. GoLighter's ten carry a wider exclusion set than the count suggests. Voy's twenty-four reflect the most complete exclusion and interaction screening captured anywhere in this market. The clinical substance behind each count is compared in the Policies view.
MedExpress's form sits in the least favourable position available: long enough to feel like Voy's, without Voy's named clinician, transfer-in evidence or off-ramps, and without Fit fürs Leben's call. Wellis cannot be placed on this spectrum with the same confidence - its questionnaire opens in the same one-question-per-screen format, but the only architecture claim this report can make with evidence is the one made off the page: a free phone consultation described as a required step, earlier and more explicit than anything the eight offer inside their forms.
A benchmark is only as good as its weakest number, and one number in this market does not reconcile.
| Operator | Internal funnel slide, 27 Apr 2026 | Crawl, Aug 2026 | Most likely explanation |
|---|---|---|---|
| Zava | 8 questions | 11 questions | Genuine change, or free-text branches counted differently |
| DoktorABC | 10 questions | ~15 items and blocks | Consent and information blocks counted in one and not the other |
| GoLighter | 11 questions | 10 questions | Close agreement; within counting tolerance |
| Voy | 18 questions | ~24 screens | Information and interstitial screens counted as screens, not questions |
The two counts were made four months apart, by different methods, and neither is wrong. They are not interchangeable, and any comparison that mixes them will misstate a competitor by up to six steps. Everything in this view uses the August crawl count; anything quoting the April slide says so. Three of the top five operators by search visibility in October 2025 had left the leaderboard by February 2026, so a four-month-old funnel count in this market should be treated as historical rather than current.
Two exclusion checklists, three medicine-interaction screens with explicit monitoring timelines, documentary transfer-in evidence, contraception disclosure with a genuine opt-out, and a named clinician narrating every explainer. No other operator screens this thoroughly, and none converts a clinical control into patient-facing wording as clearly.
The instruction to answer yes on the eating-disorder question even without a confirmed diagnosis is the best safety line in the market. Billing only on approval removes the strongest objection available at a payment page, and the itemised consent block is the most granular of the eight.
The broadest pharmacy offer in the market, stated in full, and the only pre-filled repeat questionnaire. Its eleven questions on one scroll are the lightest clinical screen of the eight, which is a risk position as well as a conversion one.
The only form in the field that glosses every clinical term in plain language, and the only operator carrying two independent third-party certifications - LegitScript and SCOPE from the World Obesity Federation - alongside prescriber registration numbers. No competitor publishes a registration number.
A body mass index calculator before the funnel, a verdict on the screen after the first question, a photograph requirement that can be deferred to a reminder email, and a prescription-only route out to the patient's own pharmacy. The most patient-flexible construction in the market, attached to the widest exclusion set.
The mandatory video consultation is stated on the first screen of the form and in the public marketing copy, not discovered later. Whatever the conversion cost, it is the clearest §9 posture of the eight and the one closest to the Munich standard.
Four mechanisms nobody in this market has taken, in order of how cheap they are to take.
No operator has a working one. On a market where the large majority of patients arrive on a phone and the longest forms run past twenty screens, the first operator to let a patient leave and come back is taking a differentiator rather than catching up. Juniper has already laid the architecture by capturing name and email first, which is a worse trade for the patient and a better one for the operator.
Three operators return a verdict, but none of them pairs it with the reasoning. A screen that states the threshold, returns the figure and explains what happens next costs a calculation and two sentences, states a threshold rather than a decision, and lands on the screen that loses the most patients.
Voy demands documents and stops without them. Zava asks nothing and proceeds. Nobody occupies the middle: request evidence, accept its absence, default to the lowest starting dose, and keep the patient. It is Voy's clinical control without Voy's friction, and it is the single most valuable unoccupied position in this benchmark.
Only Voy discloses the monitoring burden of interacting medicines before the patient pays, and it ends the disclosure in a real choice. Every other operator either excludes the patient or says nothing. Detail in the Policies view.
Voy interleaves named testimonials carrying weight-loss figures, and aggregate outcome statistics, between safety questions. In this market that is where §3, §10 and §11 of the Medicines Advertising Act bite, and it is the one place where a funnel and a clinical screen work against each other.
Dokteronline runs product, dose, package, cart, account, then the questionnaire - the only operator of the eight to place account creation before clinical content. Juniper takes name and email on the first quiz screen and creates a durable profile for a patient who has answered nothing.
GoLighter takes acceptance of the prescribing entity's terms by click-through at a domain handoff before any clinical content loads, then closes the questionnaire with one confirm button covering four distinct declarations. §630e BGB is an evidential requirement before it is a wording one, and a button is a weaker record than a set of ticks.
Zava's eleven broad questions and Fit fürs Leben's two are the lightest screens in the market. Test purchases by the Verbraucherzentrale Nordrhein-Westfalen and its Rhineland-Palatinate counterpart found four of ten platforms required no proof of identity or weight at all. That is the cohort courts and consumer bodies are targeting. Measured exclusion rates supplied for this study show contraindication lists costing 1.77 and 0.64 per cent of checks and completing in around ten seconds, so length is not what loses patients. INTERNAL
The pre-crawl working hypotheses, tested. The overturned ones are the more useful half.
| Hypothesis before the crawl | Verdict | What the evidence showed |
|---|---|---|
| Medicine names appear late, only after a gate | OVERTURNED | Four of eight name a brand on a public page with no gate at all. Only Voy and Juniper hold the line the overlay expected of the whole market |
| Pricing sits behind a gate as a consequence | OVERTURNED | Public per-pack and per-dose price tables are the norm, several shown directly beneath a percentage weight-loss claim |
| Consent is more itemised and appears earlier | SPLIT | DoktorABC and Voy itemise; Zava bundles three documents into one tick and GoLighter uses a single confirm button. Health-data consent is separable at some operators and not at others |
| Pharmacy choice presented as a choice even where a partner is defaulted | CONFIRMED | Zava, GoLighter and DoktorABC all state a choice explicitly; the Netherlands partner pharmacy appears in Zava's footer as one route of three |
| Refunds attach to the consultation rather than the medicine | SPLIT | Discounts do attach to the fee. Guarantees do not: two operators promise money back against a quantified weight outcome |
| Identity and insurance-card requests more common than in comparable markets | OVERTURNED | No operator requested an insurance card. Only two ask for a photograph at all, and one of those lets the patient defer it |
The pattern in the overturned rows is consistent: the market is markedly more exposed on public product advertising than a reading of the law would predict, and markedly less demanding on identity than a reading of the consumer-protection pressure would predict. Both gaps run in the same direction - towards conversion.
This market has one settled policy and no settled clinical rule set. Every operator gates on body mass index 30, or 27 with a weight-related comorbidity, because that is the licensed indication for Wegovy and Mounjaro and because the consumer bodies test against it. Beyond that threshold the operators diverge widely enough that two of them screening the same patient could reach different answers, and the divergence is not a spectrum from light to thorough - it is different judgements about what matters.
Three positions exist on the commercially most valuable question. On transfer-in, Voy demands documentary proof before continuing a claimed dose and defaults to the lowest starting dose without it; GoLighter grades prior use by outcome, more or less than four per cent of body weight lost in three months, and asks for no documents; Zava takes the patient's word with a two-week gap rule. MedExpress asks the question and attaches no consequence to the answer, which leaves the reviewing clinician deciding without structured evidence. Wellis's position on this question is not established - its questionnaire was not reached.
On exclusions the surprise is GoLighter. Its ten-question form is among the shortest in the market and its exclusion set among the widest: an age ceiling at seventy-five, severe psychiatric illness including suicidality, categorised blood pressure, and - harder to justify on current evidence - HIV and AIDS and Creutzfeldt-Jakob disease. Zava runs the opposite policy, converting most named conditions into comorbidities that qualify a patient rather than exclude them, and adjusting the healthy-weight threshold by ethnicity. Voy screens most thoroughly of all, with two exclusion checklists and three medicine-interaction screens carrying explicit monitoring timelines.
The most transferable idea in this view is not an exclusion at all. It is Voy's construction of a monitoring disclosure that ends in a genuine choice, made before payment. Wellis's marketing copy promises a phone consultation and doctor review before any prescribing decision, which would put the monitoring conversation ahead of the decision by construction if it holds inside the form - but that is a reading of marketing copy, not an observed questionnaire, and needs confirming before it is treated as equivalent to Voy's explicit in-form opt-out.
Competitor positions are sourced to page text captured during the crawls. Wellis positions are stated only where its public marketing or legal pages support them, and are marked as such throughout this view. No line-by-line reconciliation of any single operator's exclusion list against the whole field exists yet; the table in section 03 covers the three funnels where the complete set was captured.
| Operator | Stated threshold | Adjustments and qualifiers | When the patient is told |
|---|---|---|---|
| GoLighter | Flat 27 and above. The question footnote states that treatment with a GLP-1 medicine is suitable from a body mass index of at least 27, with no comorbidity condition surfaced anywhere in the form | None. Blood pressure asked separately and categorised low, normal or high | IMMEDIATELY The next screen returns a verdict; a calculator also runs on the homepage before the funnel starts |
| Zava | 27 to 30 with a weight-related comorbidity, or 30 and above with no comorbidity requirement | Ethnicity asked and stated to adjust the healthy-weight threshold. Diabetes, pre-diabetes, hypertension, high cholesterol and sleep apnoea treated as qualifying comorbidities rather than exclusions | Not in the form; the threshold is published on the category page |
| Fit fürs Leben | 27 with a comorbidity, or 30 and above | None observed. The deep history is deferred to a mandatory video call | AFTER TWO A preliminary "you are eligible" after body mass index and one risk question |
| DoktorABC | Not published as a figure on the pages read | None observed | LIVE IN-PAGE Calculates the figure and states that it qualifies the patient |
| Voy | Not stated as a single figure in the question tree | Ethnicity asked, with a clinician explainer that the healthy range and health risks vary by ethnicity and that this can support prescribing outside the licensed indication where medically sensible. A free-text other-conditions field is noted as potentially qualifying a lower-body-mass-index patient | At the end: a success screen carries the verdict and a pre-rendered hard stop carries the rejection |
| MedExpress | 30, or 27 with a weight-related comorbidity - the licensed indication | None stated in the form. Ethnicity not asked | NEVER Height and weight taken, nothing returned |
| Wellis | 30, or 27 with a weight-related comorbidity - the licensed indication, published on its treatment and frequently-asked-questions pages rather than confirmed inside the form | Not observed in the form. Its pages state each case is individually reviewed by a licensed physician | CALCULATOR, NO VERDICT A homepage calculator returns a weight category before the funnel starts; whether the questionnaire itself gives a verdict was not reached |
| Dokteronline | Not stated. Category copy argues the opposite case, that body mass index alone is not a sufficient measure | None observed | Not reached; the questionnaire sits behind an account wall |
| Juniper | Not reached | Not reached | Framed as "check in three simple steps whether you are eligible", then the quiz stalled |
Two things follow. GoLighter's flat 27 is the loosest published threshold in the market and sits below the licensed indication for a patient with no comorbidity, which makes it the most likely of the eight to fail a consumer-body test purchase. And the operators that state a threshold early are the same ones that return a verdict early: the threshold and the feedback are one design decision, not two, which is why an operator that publishes the threshold but says nothing in the form is paying twice for the same caution.
Recorded from the three funnels where the complete exclusion set was captured. A dash means the item did not appear, which is evidence of absence for these three forms only.
| Criterion | GoLighter | Zava | Voy |
|---|---|---|---|
| Age ceiling | Yes, 75 and over | - | - |
| Pregnancy, breastfeeding, trying to conceive | Yes, single combined item | Yes | Yes, split into two questions, with a pre-rendered hard stop |
| Eating disorder | Yes | Yes, ever diagnosed | Yes, current or past |
| Severe psychiatric illness including suicidality | Yes | - | Depression appears as a qualifying comorbidity, not an exclusion |
| HIV and AIDS | Yes | - | - |
| Creutzfeldt-Jakob and related | Yes | - | - |
| Type 1 diabetes | Yes, combined with type 2 | Comorbidity, not exclusion | Yes, exclusion; type 2 sits separately as a comorbidity |
| Tendency to hypoglycaemia | Yes | - | - |
| Blood pressure | Asked and categorised, three bands | Hypertension as a comorbidity | Hypertension as a comorbidity |
| Heart disease or heart failure | Yes | - | Yes in checklist one; mild heart failure and prior events appear as comorbidities in checklist two |
| Liver, gallbladder or kidney disease | Yes, combined | Kidney disease only, with examples | Yes, separately, with gallbladder conditional on the organ being present |
| Thyroid or adrenal disorder | Yes, as hormone disorder | - | - |
| Pancreatitis | Yes, past or present | - | Yes, current or past |
| Bowel obstruction or gastroparesis | Yes | - | Yes, with inflammatory bowel disease |
| Retinal disease | Yes | - | Yes, diabetic eye disease |
| Cancer | Yes, any cancer | - | Yes, active cancer |
| Endocrine neoplasia or medullary thyroid cancer | Yes, personal or family history | - | Yes, personal or family history |
| Allergies | - | Yes, with examples | Yes, named GLP-1 brands plus named excipients |
| Catch-all for anything unnamed | Yes, other conditions or prescription medicines | Yes, twice, with free-text branches | Yes, free text |
An age ceiling exists at one operator only. GoLighter excludes seventy-five and over; nobody else does. Frailty and the current safety signal make it a defensible position, and its absence elsewhere is a considered position only where somebody has actually considered it.
Severe psychiatric illness including suicidality is screened by GoLighter alone. Against the volume of regulatory attention on psychiatric adverse events with this drug class, that is the most substantive single gap the crawl found across the market, and it sits at seven of the eight operators rather than at one.
HIV, AIDS and Creutzfeldt-Jakob disease read as inherited rather than reasoned. Neither has a plausible mechanism-based link to GLP-1 prescribing, and both appear only in the operator with the widest list. Width is not the same as quality, and this is the row that shows it.
Ethnicity as a threshold adjustment is run by two of eight, Zava and Voy, both with an explanation attached and Voy explicitly linking it to prescribing outside the licensed indication. It is a clinical position with a data-protection dimension, not a form question, and the six operators that do not ask have taken the opposite position by default rather than by decision.
The widest divergence in the market, on the most valuable patient in it. Someone arriving on an existing dose is the easiest patient to convert and the easiest to get clinically wrong.
| Operator | Evidence required | Gap rule | What happens to the dose |
|---|---|---|---|
| Voy | DOCUMENTS A copy of the last prescription, an invoice, or a photograph of the medicine packaging with the pharmacy dispensing label showing the patient's name and the date of supply | Explicit four-band question: under two weeks, two to three, three to four, over four | Stated verbatim in the form: with evidence the patient can stay on the current dose or move up if needed; without it, the starter preparation at the lowest dose |
| GoLighter | OUTCOME No documents. Prior use graded by result instead: more than four per cent of body weight lost in three months, or less than four per cent | About one week between injections stated as usually sufficient when switching, with the exact interval determined individually | Consequence of the two branches not observed. Switching is routed to the medical team or customer service before any change |
| Zava | SELF-DECLARED Question one asks whether the patient currently uses a weight-management medicine, including holding a prescription not yet started | Two weeks, stated for Mounjaro and Wegovy: answer yes only if the last dose was under two weeks ago | The gap rule decides whether the patient counts as continuing. Dose mapping not reached |
| MedExpress | NONE Prior use asked fifteenth. A yes opens nothing | None in the form | No in-form consequence. The decision sits entirely with the reviewing clinician, with no structured evidence in front of them |
| Wellis | NOT OBSERVED Questionnaire not completed. Its public pages describe eligibility as individually reviewed but say nothing about evidence for a claimed existing dose | Not observed | Not observed |
| Others | Fit fürs Leben asks one risk question before declaring eligibility and defers the history to a video call. Dokteronline and Juniper were not reached | - | - |
Voy's wording is the most useful artefact in the crawl, because it converts a clinical control into a conversion mechanic: the patient is told exactly what to supply and exactly what happens without it, which turns a refusal into a lower starting dose rather than a lost patient. GoLighter's outcome grading is the more interesting idea and the weaker control - it captures response rather than exposure, so it cannot distinguish a patient stepping up from one restarting after a long gap. The unoccupied position is the combination: ask for evidence, accept its absence, default low, keep the patient.
Entry route matters as much as evidence. Zava is the only operator routing a returning patient to a pre-filled repeat questionnaire, and GoLighter asks at the top of its funnel whether the patient is already a patient, warning that answering yes in error will delay or reject the request. Neither is a clinical control; both express the same policy as a shorter journey.
The sharpest divergence is not what an operator excludes but what it does with a medicine it will not exclude.
Three separate interaction screens. First insulin, sulfonylureas and orlistat. Then a long narrow-therapeutic-index list - coumarin anticoagulants, anti-epileptics, rifampicin, antiarrhythmics, digoxin, immunosuppressants, and level-monitored drugs including lithium, methotrexate, theophylline and colchicine. Then levothyroxine, liothyronine and methotrexate for non-cancer indications, which trigger a monitoring notice with explicit timelines: thyroid function checked by the patient's own doctor six to eight weeks after starting or after any dose change and every six to eight weeks until the final dose, and monthly laboratory checks for methotrexate until the dose is stable.
The notice ends in a choice - "I understand" or "I do not want to continue" - so the patient accepts the monitoring burden before paying rather than after.
A single medicine question covering other GLP-1 medicines, medicines that can cause weight gain (insulin, sulfonylureas, psychotropics, beta-blockers) and coumarin derivatives such as warfarin. No monitoring notice, no timeline, no opt-out point.
One question on other regular or recently completed medicines including as-needed and emergency use, and one on allergies, each opening a free-text field. The clinical work moves to the reviewer rather than being structured in the form.
The interactions and monitoring screen was not reached. Its public pages promise a phone consultation and doctor review before any prescribing decision, which is a different sequencing point again - if it holds inside the form, it would put the monitoring conversation before the decision by construction rather than by an explicit opt-out screen. That reading rests on marketing copy, not an observed questionnaire, and should be checked before it is relied on.
The weakest link in this market, and the one a consumer body has already tested to destruction.
| Operator | What is required | Where it sits |
|---|---|---|
| GoLighter | A photograph of the patient, with no specification of face, body or scale. The form states plainly that the medical team cannot assess the request without it | Inside the form but deferrable: an "upload later" option sends a reminder email with a link after submission |
| Zava | Photographs at the first request and after a longer period of treatment, stated on the published process page and in the frequently asked questions. Exact specification not reached | Outside the assessment form entirely |
| Voy | No identity document. A photograph only as one of the accepted forms of transfer-in evidence | Inside the form, at the prior-use question |
| MedExpress | No photograph and no identity document requested at any point in the German form | Not applicable |
| Wellis | No photograph or identity requirement appears on the marketing or legal pages reviewed; the questionnaire itself was not reached | Not observed |
| DoktorABC, Treated, GreenMedical | Questionnaire alone, per the market review | Not applicable |
The test purchases run by the Verbraucherzentrale Nordrhein-Westfalen and its Rhineland-Palatinate counterpart between 2 and 11 March 2026 are why this matters. Of ten platforms identified, four required no proof of identity or weight at all. None dispensed to a tester at a body mass index of 21.6. After the tester adjusted the entered weight to a body mass index of 32.4, five platforms prescribed without difficulty and one accepted artificial-intelligence generated body photographs, with no personal doctor contact anywhere. That finding is the empirical spine of every enforcement argument now being made in this market, and it lands on the questionnaire-only model rather than on any one operator.
Two consequences follow for the market as a whole. Requiring nothing puts an operator in the same group as the four platforms the consumer body singled out, and the threshold the report itself implies - that a normal-weight tester, or one entering a falsified weight, cannot obtain a prescription - is a test most of this field would currently fail. And GoLighter's deferral pattern shows the requirement and the friction can be separated: ask for the photograph, let the patient submit without it, chase by email, and hold the prescription rather than the form.
Two operators go well beyond a yes-or-no question, and both do it in the same place: an information screen between the clinical questions and the decision. Voy states that treatment is unsuitable in pregnancy or when trying to conceive, that contraception is required if the patient is sexually active, that Mounjaro requires a non-oral method such as a condom or a coil, and that patients on an oral contraceptive need an additional method because its effectiveness may be reduced - then offers "I understand" or "I do not want to continue". GoLighter recommends a non-oral method for the first four weeks and at every dose increase, names all three molecules in the warning, and adds a point nobody else makes: that these medicines can increase fertility through weight loss, and that a patient trying to conceive, pregnant or breastfeeding should stop the medication.
The fertility statement is the transferable item. It is the only place in this market where an operator tells a patient something that works against the sale, and it is clinically correct. Both operators also demonstrate the structural point that runs through this view: a disclosure ending in a genuine choice is worth more evidentially than a tick, and costs one screen.
Only Juniper publishes a full set: a recommended treatment duration of six to twelve months, no known withdrawal symptoms on stopping, appetite and satiety effects persisting for weeks afterwards, some patients regaining weight, and a missed-dose rule worked through with a calendar example - take within five days of the due date, otherwise skip and resume on the next scheduled day. GoLighter routes switching decisions to the medical team and states an interval of about a week between injections. No other operator publishes a stopping policy at all.
The continuation floor is the market-wide gap. Published floors run from body mass index 19 to 23, with 21 the most common, and none of the eight crawled forms surfaces one to the patient. The Munich court's reasoning shows why this is not a detail: it relied partly on the defendant's own advice to discontinue if less than five per cent of body weight was lost within three months, using an operator's stopping policy as evidence that the condition requires monitoring a remote prescriber cannot provide. A published stopping rule is therefore both a clinical safeguard and, on that reading, a piece of evidence against the model that publishes it.
Zava runs the broadest routing policy in the market and states it in full: free same-day collection from any of over 6,500 German pharmacies, with the prescription transmitted electronically to the pharmacy the patient chooses when the request is approved before 15:30; free or express partner-pharmacy shipping including cold-chain medicines; or a paper prescription by post for a fee. Delivery to near-border parcel shops is refused outright, citing medicine-import restrictions, and such orders are cancelled. Its footer discloses that medicines may be supplied by a named Netherlands pharmacy, which is the shipping route and not the other two. GoLighter offers a prescription-only route so the patient fills at their own pharmacy, and a route out of the online funnel to find a local doctor. DoktorABC states the choice in the market's clearest single sentence. Wellis reads the other way on the pages available: its terms describe the medicines contract as being with its own captive pharmacy, Wellis Pharmacy B.V. in the Netherlands, and nothing reviewed offers a German alternative - the position §11 was written to discourage, on the wording of the terms rather than an observed funnel screen.
None of this is generosity. §11 of the Pharmacies Act, extended in 2019 to pharmacies established elsewhere in the European Union supplying German patients, plus consent for transmitting health data to a named pharmacy, is what produces the wording. A Frankfurt ruling of 28 May 2025 (2-06 O 150/25) found no unlawful steering where the customer can choose to take the prescription and redeem it at a pharmacy of their own choice, which makes GoLighter's prescription-only route the safe-harbour construction rather than a commercial concession. An operator that never hands the patient a transferable prescription has built commercial lock-in out of a transmission choice.
On withdrawal rights the field splits several ways. GoLighter excludes the fourteen-day right for cold-chain medicines and names Wegovy and Saxenda directly in doing so. Zava bundles the withdrawal notice with its terms and privacy policy into a single tick. Wellis's terms state a fourteen-day right for non-prescription products only, and say plainly that prescription medicines cannot be returned "for health and safety reasons" - the same substantive position as GoLighter's exclusion, reached by a blanket rule rather than a cold-chain carve-out, and on the wording of the terms the clearest of the positions recorded here under §356 BGB as renumbered in June 2026.
Because these medicines fall outside statutory reimbursement, price is a live competitive lever and the pricing structure is itself a policy choice. The figures below are from a competitor pricing tracker with data to July 2026 and should be treated as a snapshot in a fast-moving market. INTERNAL
| Operator | Wegovy starter | Mounjaro starter | Consultation fee | Payment model | Trustpilot |
|---|---|---|---|---|---|
| Voy | €152-172 | €254-274 | Included | Subscription | 4.7 |
| MedExpress | €171.96 | €206.02 | €30 | One-time order | 4.7 |
| Wellis | €172.00 | €289.00 | None stated | Recurring four-week supply, on the pages read | Not verified |
| Zava | €171.96-206.80 | Falling | €33.99-34.90 | Subscription and one-time | 4.8 |
| Juniper | €172 | €239 | Included | Subscription | 4.6 |
| GoLighter | €171.96-249.90 | Rising sharply | €33.99-39 | Subscription | 4.6 |
| HealthExpress | €171.96-233.74 | Flat | Included | Subscription | 4.5 |
| DocMorris | €171.96-206.00 | Flat | Included | Subscription | 4.0 |
| DoktorABC | €200.96-235.02 | Rising | €49 | One-time order | 4.7 |
Three corrections to the common reading of this market follow from the table. First, there is no medicine price leader: six of eight operators start Wegovy at €171.96 or €172, which is convergence rather than competition, and the only material undercut is Voy's €152 on a twelve-month commitment. Wellis's published €172.00 sits inside the same convergence, for the record, though it is outside the eight and its payment structure was not confirmed against an actual checkout. Second, the fee is where the real spread sits - €30 to €49 among those charging one, against four operators that bury it in a subscription - so an operator competing on price is competing on the fee and on payment structure, not on the medicine. Third, payment model splits the field more cleanly than price: six operators run subscriptions with the fee included and two run one-time orders with a visible fee. The subscription operators are also the ones offering guarantees, which is the same commercial logic viewed from the other end.
Review volume tells a different story from review score. Ratings cluster between 4.5 and 4.8, so the score discriminates poorly; Zava's 4.8 rests on more than 42,000 reviews while a category page elsewhere in the field displays under 2,000. Two scores moved materially in a single month to July 2026, DocMorris from 4.6 to 4.0 and Oviva from 4.5 to 4.0, and no source held explains either fall.
Source: DE GLP-1 competitor pricing tracker, data to July 2026; category-page review counts from the 14 and 15 August 2026 advertising capture.
| Operator | Guarantee | Condition |
|---|---|---|
| GoLighter | 180 days, money back if the patient does not lose at least ten per cent of starting weight | A quantified clinical outcome, contractually framed |
| Voy | Refund if the patient does not lose at least ten per cent in six months | Same construction; recorded as present in the terms but not used in the advertising |
| Juniper | 25 days money back | Medical grounds plus a doctor's certificate |
| Fit fürs Leben | None; membership at €39 every four weeks, cancellable monthly | - |
| MedExpress | None. A first-order discount code applied to the treatment fee only | - |
| Wellis | Full refund of the amount paid if a doctor finds treatment not medically suitable, stated in its frequently asked questions | A suitability decision, not a weight-loss outcome |
An outcome-conditional guarantee is a different order of claim from a described typical result, and it is not primarily a refunds question. §3 of the Medicines Advertising Act restricts claims of certain success, and a contractual promise of a specific weight loss sits closer to that line than any percentage on a landing page. The court that enjoined GoLighter's advertising did so partly over the phrase "reach your target weight". Wellis's refund is conditional on a clinical suitability decision rather than a weight-loss figure, which keeps it out of that argument entirely - a materially different, and lower risk, construction from GoLighter's and Voy's. The guarantee mechanics belong here; the claim risk is in the Advertising view.
Recorded, not resolved. Each is a point where operators in this market hold materially different clinical positions, and the difference is a judgement for a market medical lead rather than for a funnel comparison.
Three positions coexist: documentary evidence before continuing a claimed dose, outcome-graded prior use with no documents, and self-declaration with a gap rule. A fourth operator asks the question and attaches no consequence, which is not a fourth position but the absence of one.
An age ceiling at seventy-five and severe psychiatric illness including suicidality are each screened by a single operator. Both are defensible on the current safety picture; neither is market practice. HIV, AIDS and Creutzfeldt-Jakob disease sit in the same list and are not defensible on the same reasoning.
Two operators ask ethnicity and state that it adjusts the healthy-weight threshold, one linking it explicitly to prescribing outside the licensed indication. Six do not ask. The question carries a data-protection dimension as well as a clinical one.
One operator requires photographs outside the form, one requires them inside with deferral, one accepts a photograph only as transfer-in evidence, and the rest take the questionnaire alone. The consumer-body test purchases make this the position most likely to be tested externally.
Published floors across the wider market run from body mass index 19 to 23, most commonly 21. No crawled form surfaces one, so a patient cannot know at what point treatment should stop.
One operator instructs patients to answer yes even where a diagnosis is not confirmed. Adopting it changes what a form captures and therefore what a prescriber sees, which makes it a clinical decision rather than a wording one.
German law forbids almost everything that converts. §10 of the Medicines Advertising Act bars advertising a prescription medicine to the public at all, and since the Bundesgerichtshof ruling of 26 March 2026 naming the class plus its indications and offering a route to a doctor is enough to breach it. §9 bars advertising the remote consultation itself unless recognised professional standards say personal contact is unnecessary, which a Munich court has held a questionnaire-only obesity pathway does not satisfy. The field is therefore not competing on compliance. It is competing on how far past the line to go, and on how well structured each operator is to survive being caught.
Four of the eight name a medicine on a public page with no gate: MedExpress, Zava, Dokteronline and Fit fürs Leben. Three of those four also place a percentage weight-loss claim and a price in the same view. Only Voy and Juniper gate the molecule, and only Voy's is verified - a direct text search of its public site returns no brand or active-ingredient name anywhere, with the first mention several screens inside the questionnaire. Dokteronline is the most exposed of the eight, listing twelve named products with efficacy figures including four investigational compounds not authorised in Germany.
The market's second axis is social proof, and it runs the opposite way. Five of eight use named or initialled testimonials carrying a specific weight and timeframe. Two operators - Juniper and Voy - have built their paid social almost entirely on it: twenty-seven active creatives, three-quarters video, before-and-after imagery and customer reviews in nearly half at one; all video, a review badge on every ad and a quarter influencer-generated at the other. This is the part of the market where §11 and the Cologne appeal court's known-person doctrine sit closest to the commercial engine, and where the enforcement record is thinnest so far.
Enforcement is not coming from the medicines regulator. The Bundesinstitut für Arzneimittel und Medizinprodukte has taken no published advertising action against a telehealth platform, and there is no German equivalent of the United States programme that sent warning letters to thirty telehealth companies in February 2026. It comes from competition associations, pharmacists' chambers and, faster than any of them, the advertising platforms themselves. Three of the eight are currently dark or disabled on paid social.
The most useful finding for any operator in this market is that the two most exposed positions are separable. An operator can hold the strongest verification and certification posture in the field and still carry the most exposed public product page, because they are different decisions taken by different functions. Section 10 works one operator's position through in detail to show how that happens.
All of these operate as market-conduct rules through §3a of the Unfair Competition Act, which is what gives competitors and qualified associations standing to sue. A separate layer, the audiovisual rules on commercial communications for prescription-only medicines, applies to any video or connected-television creative.
The Wettbewerbszentrale and the Verband Sozialer Wettbewerb are the lead actors and were the claimants in both Federal Court of Justice decisions of 26 March 2026. Their membership includes medical chambers, doctors and clinics, so the body most likely to sue a GLP-1 platform is institutionally aligned with the profession that opposes questionnaire prescribing.
The Apothekerkammer Nordrhein obtained the March 2025 injunction against the largest advertising campaign in this market. A chamber brought the Munich weight-loss injection case too. Chambers act on what they can see, which makes visibility itself a risk factor.
The Verbraucherzentrale Nordrhein-Westfalen and its Rhineland-Palatinate counterpart do not litigate but supply the evidence others use. Their March 2026 test purchases are the empirical basis of the current duty-of-care critique.
The federal medicines authority's documented GLP-1 activity is confined to supply, a counterfeit-pen investigation and an opinion on off-label use. No published advertising action against a telehealth platform exists. Its absence is a present fact, not a guarantee.
The procedural shape matters more than the identity of the claimant. A cease-and-desist letter is followed, often within days, by an application for a preliminary injunction, which can be granted in weeks and carries penalties of up to €250,000 per breach. Main proceedings then run for years. Every GLP-1 advertising decision in this market so far is interim and appealable, which means the law shaping the market is provisional and the commercial consequences are not.
| Operator | First brand mention | Where | Gated? | Price beside the claim? |
|---|---|---|---|---|
| Dokteronline | Twelve named products with active ingredient, form, price and efficacy figure, including four investigational compounds shown as currently unavailable | Category listing page | NO GATE | Yes - every element in one card, with no separation between clinical claim and price |
| Fit fürs Leben | Four brands in an interactive efficacy chart with a labelled placebo bar | Homepage, plus dedicated per-medicine price pages | NO GATE | Yes - full dose-escalation price table with a non-reimbursement note attached |
| MedExpress | Three brands, each with the active ingredient in brackets | Category page, one click from the homepage | NO GATE | Yes - brand, percentage and price in the same tile |
| Wellis | Two brands, Wegovy (injection and pill) and Mounjaro, each named directly | Category page, one click from the homepage | NO GATE | Yes - a struck-through list price and the discounted four-week price beside each brand |
| Zava | Three brands plus a named generic entrant | Public guide page, framed as editorial with a named medical-reviewer byline and a last-updated date | NO GATE | Prices per product; no discrete percentage claim on the page read |
| GoLighter | None on the homepage; one brand named in separate guide articles | Guide pages, one step outside the buy flow | SPLIT Generic in the transaction, named in editorial | Dose-by-dose price table using generic descriptors only |
| DoktorABC | Generic tiles. Two brands appear only in a study footnote, one of which is a United States brand not marketed in Germany | Category page footnote | FOOTNOTE | Fee and medicine price beneath the percentage claim |
| Voy | Four brands, inside the gated questionnaire at the prior-use branch | Several screens in | FULLY GATED Verified by direct text search of the public site | No - service price only, with a voucher code in the call to action |
| Juniper | Withheld; the published answer is that ingredients can be discussed after the eligibility review | Help centre only | FULLY GATED | No - service price only |
Half the market names a medicine publicly, which is the market norm and not a safe harbour: the two injunctions of March 2025 both landed on this posture, one against a Netherlands pharmacy and one against a Munich-established operator, so neither foreign nor domestic establishment protected the advertiser. Wellis's category page, outside the eight, sits in the same exposed group, with brand and price together and no gate of any kind.
Paid channels behave differently again, and a competitor advertising review held in this market records the pattern. Search ads largely avoid brand names and use "Abnehmspritze" or "Diät Spritze" instead, with Zava the exception, running Mounjaro in a search headline while keeping it off the landing page. Shopping ads invert it and put product names in the headline, HealthExpress and Dokteronline among them. One operator's own internal review records two aggressive ad variations, built around pen wording, a discount code and the full price in the headline, delivering 45 per cent of impressions and conversions, with shopping ads on drug-related terms carrying around 80 per cent of shopping traffic. INTERNAL The commercial dependence on the exposed side of the line is measurable, which is what makes this a decision rather than a cleanup.
The United States brand name appearing in a German footnote reads as reused source material rather than a deliberate choice, but it still places a named medicine on a public German page.
| Operator | Headline figures as displayed | Named testimonials | Sourcing shown |
|---|---|---|---|
| GoLighter | Ø20.7%, Ø22.5%, Ø17%, Ø8% per product; 93% and 86% wanting to continue; 95% better eating behaviour, 69% more physically active, 67% improved mental health; a cardiovascular-risk reduction claim on two tiles; 180 days or money back if the patient does not lose 10% | Two, with starting weight, end weight and elapsed weeks | No named source for the outcome figures; four academic citations in the footer, including OASIS 4 |
| Voy | 21% average in ten months, tied to the patient's own entered target weight; 94%, 64% and 94% aggregate wellbeing figures; a bare superlative market-leadership claim on the homepage | Four on the homepage and four inside the questionnaire, with two first names appearing in both sets carrying different figures | A dated patient survey, on the aggregate statistics only |
| Juniper | Up to 20% in six months; 4.5 times more than the medicine alone; 87% continuing past month one; 76% holding their weight; a homepage slider projecting up to 18 kg | Three, with age and kilograms lost; more than 60,000 successes claimed | A telemedicine journal citation and an own-customer analysis |
| DoktorABC | Up to 20% after eight months; a slider projecting −23 kg in a year from a 115 kg start; 86%, 91% and 94% outcome statistics | None; aggregate percentages only | A long-term study footnote naming two brands |
| Fit fürs Leben | Over 20% average and one in three reaching 25% or more, for a dose not yet available in Germany | A member-experiences page exists, not opened in this pass | A named external article with the URL in-page, plus a results-may-vary caption and a labelled placebo comparator |
| Dokteronline | Per-product figures presented as catalogue specification: 10%, up to 20%, 15%, 5-10%, up to 17%, up to 14% | None | Presented as product data; manufacturer named on the product page |
| MedExpress | Up to 21%, 23% and 17% per product; around 17% average after 64 weeks for the oral | None named. A dated review carousel on homepage and category page, one review of which states a personal result of about a kilogram a week | A footnote marker present; the underlying citation was not captured |
| Zava | No discrete percentage captured on the guide page read | None | Manufacturer information leaflets, dated, per medicine |
Two constructions in this table are riskier than the percentages that dominate it. A quantified personal result inside an unverified customer review is a testimonial for §11 purposes whether or not the operator wrote it, so an operator running no named testimonials may still be carrying testimonial exposure through a review widget. And a projection tied to the patient's own entered weight - two operators do this - converts an average into an individual promise at the moment of highest intent.
Wellis's outcome claims and testimonial use were not assessed this round - the category page read for this report carried price and brand but was not checked for percentage figures or reviews, so it is left out of the table above rather than assumed clean.
Not compliance strategies. Techniques for advertising something that cannot lawfully be advertised, in a form that is harder to enjoin.
Voy and Juniper only. No medicine name on any public page, with the reveal after the patient is inside. Voy's is verified by direct text search, which makes it the most defensible public estate in the market.
One operator runs a brand in a search headline and keeps it off the page it lands on; others invert it. Either way the brand appears in only one of the two places a complaint would cite.
Guide and advice articles hold the brand names, one step outside the transaction, under an article title, a named medical-reviewer byline and a last-updated date. The construction argues that the content is information rather than promotion.
One operator's only brand mention on its category page sits inside a citation supporting a percentage. A footnote is the smallest available surface for a product reference.
A homepage chart with a labelled placebo bar, an averages caption, a results-may-vary line and an external source URL. It is the most clinically styled public claim in the market, and the styling is the defence.
"Abnehmspritze" and "Diät Spritze" across the whole market, in search copy and affiliate guidance, treated as neutral everyday vocabulary. This is the technique the Munich court specifically defeated, holding that the public knows which medicines are meant.
First-fee waivers and first-order codes applied to the consultation charge, with affiliate discounts capped at the fee. It keeps §7 and medicine pricing out of the argument. One operator's voucher, embedded in the primary call to action and framed against a total package price, does not clearly hold that line.
A free support package of nutrition guides, trackers and planners, tied to the consultation rather than the medicine - value added without a medicine-linked inducement.
"Pre-order" is not available for a prescription medicine, so one operator's oral-product copy became "request an online consultation". A pre-order implies a product sale; a consultation request implies a service. INTERNAL
Efficacy language fixed to "around" and "approximately" rather than a flat figure, as a medical-review touchpoint, moving the claim away from a promise of certain success. INTERNAL
LegitScript and SCOPE accreditation from the World Obesity Federation plus prescriber registration numbers at one operator; a TÃœV mark held through a prescribing entity and an independent medical advisory board at another. A third-party mark carries trust without making a product claim.
One funnel runs across four domains: commercial brand, prescribing entity, consultation, checkout. The consumer brand carries generic copy while the clinical content sits with an Ireland-registered practice on another domain. It did not prevent an injunction, but it is the most deliberate structural answer in the market.
One operator has taken weight loss dark and shifted 80 per cent of its social spend to another category; one has been dark since January 2026 despite the best review score in the market; two run no weight-loss social activity at all. Withdrawal is a strategy, and half the field is using it.
| When | Who | What triggered it | Status |
|---|---|---|---|
| 3 March 2025 | A Netherlands online pharmacy, sued by a pharmacists' chamber LG München I, 4 HK O 15458/24 | Advertising questionnaire-based weight-loss prescribing to German consumers, under both §10 and §9. The court held that questionnaire-only remote treatment of obesity does not meet recognised professional standards and that personal medical contact is required first, citing the national obesity society's patient guideline on the investigations required | Interim injunction, not final |
| 18 March 2025 | A Munich-established operator and its weight-loss brand, sued by the North Rhine pharmacists' chamber | "Buy Wegovy online - request a prescription", a primetime television spot promising the viewer would "reach your target weight", and describing itself as an internet pharmacy while operating none. §10 and §3 | Interim injunction, appealable |
| 26 March 2026 | A medical cannabis platform, sued by a competition association BGH, reported as I ZR 74/25 | Naming a class of prescription medicine with its treatable indications and enabling treatment requests. No product or manufacturer named, and it still breached §10 | Revision dismissed; a constitutional complaint has been filed |
| 26 March 2026 | The same Munich operator, on its questionnaire model with Irish partner doctors BGH I ZR 118/24 → CJEU C-265/26 | Whether freedom to provide services precludes §9 banning advertising of remote treatment by doctors established in another member state. The closest analogue in this market to any cross-border prescriber structure | Referred 26 March 2026, lodged 31 March; judgment unlikely before 2027 |
| Late March 2026 | Consumer bodies for North Rhine-Westphalia and Rhineland-Palatinate | Test purchases from 2 to 11 March. Four of ten platforms required no proof of identity or weight; after the tester raised the entered weight, five prescribed without difficulty and one accepted artificial-intelligence generated body photographs | Published; no action attributed to a named operator |
| 2025 to 2026 | Platform enforcement across the market | One operator's social account disabled since March 2026 for an advertising-standards violation, with no active ads since. Another operator reports an account suspension in mid-July 2026 and a disapproval wave on 1 August, and a shopping-platform suspension threat over a treatment fee being read as a service. INTERNAL | Ongoing, and faster than the courts |
Two lessons. Establishment protected nobody: one injunction hit a Netherlands pharmacy and the other a Munich company, on materially the same conduct. And nothing on this list was brought by a regulator. Every action came from a chamber, a competition association or a platform, which means the trigger is a complaint rather than an inspection, and the shortest route to being enjoined is being the most visible.
Creative mix and search visibility from a competitor tracking programme with data to July 2026. INTERNAL
| Operator | Paid social creative | Search share, May 2026 | Commercial hook |
|---|---|---|---|
| Voy | All video, review badge on every ad, 24% influencer-generated | 42.0% | Voucher code embedded in the primary call to action; €20 price rise across June to July |
| Juniper | 27 active creatives, 74% video, before-and-after imagery, 44% featuring customer reviews - the most media-sophisticated in the set | 22.9% | €77 off the first two months; 25-day money-back guarantee |
| MedExpress | Price-led. No named testimonials and no before-and-after imagery in creative; geo-testing at low budget | 22.1% | First-order code applied to the treatment fee |
| Oviva | Not a prescriber; coaching only | 18.3% | Bids heavily on weight-loss terms, so competes for the same audience |
| Zava | DARK Since early January 2026, despite the best review score in the set at 4.8 across more than 42,000 reviews | 15.0% | Most conservative creative when last active |
| GoLighter | DISABLED Account disabled since March 2026; zero active ads | 14.0% | Countdown timers, a first-fee waiver, and a 70% discount observed in search |
| DoktorABC | DARK On weight loss; 80% of social spend moved to another category | 13.7% | Largest traffic in the set; costs arise only on doctor approval |
| HealthExpress, DocMorris | No weight-loss social activity; search only | Both under 10% | A staged discount nobody else runs: 15% off month one, then 10% for months two to six |
The market churns fast enough to make all of this provisional - three of the top five operators by search visibility in October 2025 had left the leaderboard by February 2026. Cost pressure is the constant: cost per click across the market rose 67 per cent between October 2025 and February 2026 on aggressive bidding, and one operator reports acquisition cost running at €170 against a €140 budget with twelve-month lifetime value against acquisition cost at 0.3. INTERNAL That pressure is the mechanism by which advertising risk increases in this market: it is created by the auction, not by any operator's appetite.
Platform policy is stricter, faster and less negotiable than the courts, and in this market it diverges from the law in both directions. Google's healthcare and medicines policy makes prescription-drug services a restricted category requiring certification, and Germany is on the list of locations where certified advertisers may run them - so a campaign can be technically permitted by the platform and still breach §10. In the other direction, one operator was told in May 2025 that LegitScript certification is not accepted for Germany at all, with eligibility running instead through mail-order pharmacy registration plus platform certification, which is stricter than the published policy implies. INTERNAL Meta does not permit prescription-drug promotion outside a short list of countries that does not include Germany, so the question does not arise there.
The practical consequence is that platform enforcement is where this market actually gets policed. Account disablement, disapproval waves and shopping-feed suspensions have removed more advertising from this market in eighteen months than every injunction combined, and they arrive without a hearing.
Wellis is read here against the same claims a market operator might make about itself, using only its public marketing and legal pages. Nothing below draws on an observed questionnaire, and each line says so where it matters.
| Common claim | Verdict | What the evidence supports instead |
|---|---|---|
| "Runs a cautious advertising posture" | INCORRECT | Its category page names Wegovy and Mounjaro directly, with a struck-through list price and a discounted four-week price beside each, and no gate of any kind - the same exposed posture as MedExpress, Zava, Dokteronline and Fit fürs Leben, not the gated posture of Voy and Juniper |
| "Offers a strong outcome guarantee" | NARROW IT | Its refund is conditional on a doctor's suitability decision, not on a quantified weight-loss result. That is a materially lower-risk construction under §3 than GoLighter's or Voy's percentage-based guarantees, and also a materially weaker marketing claim - it is not an outcome promise at all |
| "Gives the patient pharmacy choice" | INCORRECT, ON THE TERMS READ | Its terms describe the medicines contract as being with its own pharmacy, Wellis Pharmacy B.V. in the Netherlands, with no alternative stated - the opposite of the choice-worded convergence recorded in section 03, though this rests on the terms rather than an observed funnel screen |
| "Is a German-established service" | INCORRECT | Its named doctors carry Dutch BIG registration numbers and its dispensing pharmacy is Netherlands-registered - a cross-border structure of the kind the pending Court of Justice reference concerns, not a domestic one |
| "Screens more thoroughly because it phones the patient" | UNTESTED | A free phone consultation before doctor review is stated earlier and more explicitly than anything the eight offer inside their forms - but what the call covers, and the questionnaire's own exclusion set, were not observed this round, so the claim is unverified rather than confirmed |
| "Is a weight-loss specialist" | NARROW IT | Weight loss is one of four conditions on the same account and platform, alongside erectile dysfunction, premature ejaculation and hair loss - a materially different commercial model from any single-condition operator in the crawled set, and not comparable to one on that basis |
Three of these six lines rest on Wellis's own published terms and marketing copy rather than an observed questionnaire, and are marked as such in the table. A terms-derived reading is a reasonable starting point for Medical and Legal, not a substitute for walking the funnel: the pharmacy-choice and cross-border findings in particular should be confirmed against an actual completed session before either is relied on in a compliance assessment.
180 days or money back on a ten per cent loss at one operator, and a six-month equivalent at another, promise a specific clinical result contractually. That is a different order of claim from a typical result and points straight at §3 - the provision the "reach your target weight" spot broke.
A national market-leadership claim with no methodology, source or footnote anywhere on the page is the easiest misleading-advertising case available in this market to bring.
Two first names appear on one operator's homepage and inside its questionnaire with different figures - ten kilograms in three months in one place, seven in one month in the other. It may be two rotating pools; on the surface it is the same person with two results, which is worse than either claim alone.
A quarter of one operator's creative is influencer-generated. The Cologne threshold sits below national fame and holds the advertiser liable for the influencer as its agent, so this is the social-proof format where exposure transfers in full. Anonymised, non-famous patient stories with no product reference are the version that survives.
The primetime spot is the most expensive creative decision in this market's short history: it produced the injunction, and the audiovisual rules separately prohibit commercial communications for prescription-only medicines. There is no version of a television spot for this product worth the risk.
Social research held in this market identifies a German weight-loss forum with 263,000 users and active medicine threads, notes that advertising there is banned, and proposes posting about an offer and discount regardless. Undisclosed promotional posting is separately unlawful as hidden advertising, and a health forum is the worst available place to be caught doing it. INTERNAL