A significant difference in both legal systems continues to be the amount of compensation for pain and suffering; in Germany, the amounts awarded are very low by international standards. If Italian law is applicable in German courts and the payment of Italian damages for pain and suffering is requested, German courts already argue with the ordre public objection, i.e. that such high amounts would simply contradict the German understanding of the law and could not be awarded.

Slowly, however, a tendency to adapt can also be seen in Germany. Various regional courts have awarded amounts of 800,000.00 Euro - 1,000,000.00 Euro in extreme cases (see Slizyk, Konkretisierung der Schmerzensgeldbemessung in NJW 3757/21, with references).