This comment is not towards you but there's always an excuse with the big German banks.
For example, during Covid when interest rates where negative - some major German banks like Commerzbank charged interest from customers when their balance exceeded an amount like 50000€. Now that the interest rates have gone up - they are not even close to passing on those high interest rates. The same Commerzbank now asks for 50000€ in assets otherwise they charge a 4.90€ subscription charge from their customers.
So yeah there might be technicalities but nothing stops those technicalities being addressed until the law does.
As a reluctant Commerzbank customer, there's some inaccuracies. The amount was 100k€ re: negative interest, and the subscription charge only applies if you're not moving a certain amount of money each month (which is very low, even unemployment payments would be enough to clear that hurdle).
So you're only paying for your second or third account.
For example, during Covid when interest rates where negative - some major German banks like Commerzbank charged interest from customers when their balance exceeded an amount like 50000€. Now that the interest rates have gone up - they are not even close to passing on those high interest rates. The same Commerzbank now asks for 50000€ in assets otherwise they charge a 4.90€ subscription charge from their customers.
So yeah there might be technicalities but nothing stops those technicalities being addressed until the law does.