The network enforcement law could have consequences for a messenger service for the first time.
The Federal Office of Justice is conducting two fine proceedings against the Telegram company, as a spokeswoman for the Federal Ministry of Justice said in Berlin on Monday.
The reasons are the lack of an easily recognizable and immediately accessible reporting channel for criminal content as prescribed in the Network Enforcement Act and the lack of naming an authorized recipient for requests from courts in Germany, she explained.
The Federal Office of Justice had sent two hearing letters to the company based in the United Arab Emirates by way of international mutual legal assistance.
Telegram now has the opportunity to comment.
A spokesman for the Federal Ministry of the Interior added that they wanted to wait for this answer before speculating about possible follow-up measures.
According to the spokeswoman for the Ministry of Justice, other messenger services for the German judiciary are "generally available".
The Network Enforcement Act is intended to ensure that criminal content on the Internet is prosecuted and deleted.
It also defines the rights of users, for example with regard to a complaint system.
This includes a transparent reporting channel for allegedly criminal content.
The law also obliges providers to name a contact person for the authorities in Germany.
The messenger service Telegram is considered to be particularly unregulated and thus promises more data protection and security for users. The program for exchanging messages, photos or videos came under fire at the same time because right-wing extremists and conspiracy theorists were able to maintain successful channels there.