[buzer]

On the "German DPA can only forward it to Czech DPA" there is now regulation (2025/2518) around the cross-border enforcement and as far as I understand it actually has hard deadlines. However it will only start being in effect around May 2027 and will only affect cases which were filed after that. It is still very long process and does require that the original DPA actually initiates things.

The spam filter loophole is unlikely to be legal. It it contrary to other DPA rulings (like Norwegian DPA ruling on Mowi ASA), EDPB guidelines don't strictly define it but I would say tilt towards that excuse not being sufficient & my understanding is that there are also some court cases from Germany and Austria that treat messages routed to spam as recieved (https://www.nospamproxy.de/en/emails-in-spam-folders-are-con...). Of course if you want to actually enforce it you would need to appeal the decision in court, I have no clue how easy or hard that is in Germany.