--- title: "Germany’s BFSG: What the Accessibility Act Asks of You" url: "https://barrierefreihochzwei.de/en/blog/germany-bfsg-accessibility-act" language: "en" description: "Germany’s Accessibility Strengthening Act has applied since June 2025. Who is covered, which requirements apply, how enforcement works and what to do." published: "2026-10-10T09:00:00+02:00" updated: "2026-10-15T09:42:15+02:00" --- # Germany’s BFSG: What the Accessibility Act Asks of You Since 28 June 2025, Germany’s BFSG has made accessibility mandatory for many consumer-facing digital services. Who is covered, what is required and how to get started. Since 28 June 2025, digital accessibility is no longer a nice-to-have for many businesses selling to consumers in Germany. The Barrierefreiheitsstärkungsgesetz, or BFSG (roughly “Accessibility Strengthening Act”), requires certain products and services to be usable by people with disabilities. In practice, that means online shops, booking flows, consumer banking and a lot of apps. Yet many teams are still unsure where they stand. Does the law apply to us? What exactly do we have to build? And what happens if we don’t? This article gives you a structured overview, from scope and technical requirements to a to-do list you can take into your next planning meeting. If you work in another EU country, much of this will sound familiar, because the BFSG is Germany’s version of a law that exists across the EU. **Please note:** this article provides general information on the legal situation as of October 2026. It is not legal advice. If you need to know whether and how the BFSG applies to your specific service, talk to a qualified lawyer. ## The BFSG in context The BFSG transposes the European Accessibility Act (Directive (EU) 2019/882), usually shortened to EAA, into German law. Every EU member state had to implement the directive, so comparable national laws now apply throughout the single market. The German act sets out the framework and obligations, while the detailed accessibility requirements live in a separate regulation, the BFSGV. The core idea is spelled out in section 3 of the BFSG: products and services are accessible when people with disabilities can find, access and use them in the usual way, without particular difficulty and, in principle, without help from others. That’s a high bar. An online shop where a blind customer can only complete a purchase with a friend reading the screen aloud does not meet it. One important distinction: the BFSG targets private businesses. Websites and apps of public sector bodies in Germany are covered by different rules, namely the Disability Equality Act and the BITV 2.0 regulation at federal level, plus equivalent state laws. Those implement the EU’s Web Accessibility Directive rather than the EAA. ## Who is covered The law distinguishes between products and services. If you design, build or run websites and apps, the services part is the one that matters most to you. ### Products The BFSG covers products placed on the market after 28 June 2025. These include consumer computers and operating systems, self-service terminals such as ATMs, ticketing and check-in machines and payment terminals, smartphones and other consumer devices used for telecommunications or for accessing audiovisual media services, and e-readers. The obligations here fall mainly on manufacturers, importers and distributors. ### Services On the services side, the law applies to the following when they are provided to consumers after 28 June 2025: - electronic communications services - certain elements of passenger transport services by air, bus, rail and water, such as websites, apps, e-tickets and travel information - consumer banking services - e-books and dedicated e-book software - e-commerce services ### What counts as e-commerce That last category has the widest reach. The act defines e-commerce services as services offered through websites or mobile apps and provided electronically at the individual request of a consumer with a view to concluding a consumer contract. The textbook example is an online shop. Booking platforms, online ticket sales, subscription sign-ups and price calculators that lead to a contract typically fall under it as well. Two questions help with a first assessment. Do you serve consumers? Pure B2B offerings are generally outside the scope of the BFSG. And can a contract be initiated or concluded through your website or app? A brochure site with no way to order anything is usually not an e-commerce service. The edges are blurry, though: contact forms, appointment booking and mixed B2B/B2C offers are typical grey areas where legal advice pays off. ## Exemptions and limits ### Microenterprises providing services Microenterprises that provide services are exempt from the accessibility requirements. Under section 2 of the BFSG, a microenterprise employs fewer than ten people **and** has either an annual turnover or an annual balance sheet total of no more than 2 million euros. Both conditions have to be met. A shop with twelve employees is not a microenterprise, however small its revenue. Keep in mind that this exemption only covers services. Microenterprises that make or sell products within the scope of the BFSG are not automatically off the hook. ### Exempted content Section 1(4) of the BFSG excludes certain website and app content. Among other things, this covers pre-recorded time-based media and office file formats published before 28 June 2025, online maps as long as the essential information is also available in an accessible form, third-party content that you neither fund, develop nor control, and archives that are no longer updated. Anything new, or anything you actively maintain, is not covered by these exemptions. ### Fundamental alteration and disproportionate burden Sections 16 and 17 allow an exception where meeting the requirements would fundamentally alter the nature of your service or impose a disproportionate burden. That might sound like a loophole, but it isn’t one. You have to carry out the assessment yourself, document it, keep it for five years and notify the market surveillance authority. For services, the disproportionate burden assessment also has to be repeated regularly. The criteria are set out in Annex 4 of the act. If you want to rely on this, do it with a solid justification and legal support. ## What the requirements look like The BFSGV phrases its requirements in fairly general terms. For services, section 12 requires websites, online applications and mobile apps to be consistently and adequately perceivable, operable, understandable and robust. If those four words ring a bell, that’s because they are the four principles of WCAG, which we unpack in our article on [the WCAG principles](https://barrierefreihochzwei.de/en/blog/wcag-explained-principles-levels). E-commerce services get a few extra requirements in section 19 of the BFSGV: information about the accessibility of the products and services on offer, where the responsible economic operator provides it, and accessible identification, authentication, security and payment functions. Login, two-factor authentication and checkout are explicitly part of the deal. ### EN 301 549 and WCAG 2.1 AA as the benchmark So how do you measure “perceivable, operable, understandable and robust”? In practice, through the European standard EN 301 549, which refers to WCAG 2.1 Level AA for web content. Section 4 of the BFSG also provides a presumption of conformity: if your service meets the relevant harmonised standards published in the Official Journal of the EU, it is presumed to meet the requirements, to the extent those standards cover them. WCAG 2.2 is not explicitly required by law at the moment. It’s still worth aiming for. It builds on 2.1, adds criteria on things like focus visibility, target size and authentication, and has been the current W3C Recommendation since October 2023. If you’re building something new today, targeting 2.2 saves you rework later. ### What this means day to day Here’s a realistic scenario. A fashion retailer runs a well-designed shop, but the checkout embeds a third-party payment form. Its fields have no visible labels, and the “Buy now” button only responds to mouse clicks. For someone shopping with a keyboard or a screen reader, the journey ends right there. Under the BFSG, that’s the retailer’s problem, not just the payment provider’s, because the payment step is part of the service. Typical criteria that trip up flows like this include [Non-text Content](https://barrierefreihochzwei.de/en/wcag/1-1-1-non-text-content) (missing text alternatives for product images and icons), [Contrast (Minimum)](https://barrierefreihochzwei.de/en/wcag/1-4-3-contrast-minimum), [Keyboard](https://barrierefreihochzwei.de/en/wcag/2-1-1-keyboard), [Focus Visible](https://barrierefreihochzwei.de/en/wcag/2-4-7-focus-visible), [Labels or Instructions](https://barrierefreihochzwei.de/en/wcag/3-3-2-labels-or-instructions) and [Name, Role, Value](https://barrierefreihochzwei.de/en/wcag/4-1-2-name-role-value) for custom components such as size pickers or quantity steppers. ## Mandatory accessibility information Besides the technical work, section 14 of the BFSG requires service providers to publish information on how their service meets the accessibility requirements. Annex 3 of the act defines the content. You make this information available in your terms and conditions or in another clearly visible way, and it has to be accessible itself. Where applicable, it should include at least: - a general description of the service in an accessible format - explanations needed to understand how the service works - a description of how the service meets the relevant accessibility requirements - the competent market surveillance authority You need to keep this information available for as long as you offer the service. Most businesses publish it on a dedicated page linked from the footer. Our article on [accessibility statements](https://barrierefreihochzwei.de/en/blog/accessibility-statements-what-goes-in) explains how to structure that page and how it differs from the statements public sector bodies have to publish. ## Accessibility is not a one-off project Section 14 also requires you to keep meeting the requirements over time. Changes to your service, to the requirements or to the relevant standards have to be taken into account. A relaunch, a new checkout plugin or a new campaign landing page are all reasons to check accessibility again. If you find that your service doesn’t comply, you have to take corrective action. The act also requires you to inform the market surveillance authority without undue delay, including details of the non-compliance and the measures taken. And if the authority makes a reasoned request, you have to provide information and cooperate on bringing the service into conformity. ## Market surveillance and penalties Germany’s federal states have set up a joint authority to supervise services under the BFSG: the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF), based in Magdeburg. It can review services and step in when it finds problems. Section 29 lays out a staged process. First, the authority asks you to fix the issues within a reasonable deadline. If nothing happens, it repeats the request and threatens to prohibit the service. If that still has no effect, it can order you to stop offering the service. For an online shop, that is about the worst outcome imaginable. Consumers who can’t use a service, or can only use it with restrictions, because of a breach can ask the authority to open proceedings. Recognised disability organisations and qualified consumer bodies have the same right. There is also a conciliation procedure through the federal arbitration body set up under Germany’s Disability Equality Act. Breaches can also be treated as administrative offences. Depending on the offence, section 37 provides for fines of up to 10,000 or up to 100,000 euros. Offering a service that doesn’t meet the requirements falls into the higher bracket. Whether competitors can additionally pursue breaches under unfair competition law has not yet been settled. ## Transitional periods There was no general grace period: the BFSG has applied since 28 June 2025. Section 38 only contains narrow transitional rules: - Service providers may continue to use products they were lawfully using before 28 June 2025 to provide similar services until 27 June 2030 at the latest. - Service contracts agreed before 28 June 2025 may continue unchanged until they expire, but no later than 27 June 2030. - Self-service terminals lawfully in use before 28 June 2025 may stay in service until the end of their economically useful life, but no longer than 15 years after they were put into operation. For your website or app, this generally doesn’t translate into extra time. If you haven’t started yet, now is the moment. ## What the BFSG is not A few misconceptions keep coming up. The most persistent one: adding an overlay or accessibility widget via a script will make your site compliant. It won’t. These tools can’t reliably fix missing labels, broken structure or components that can’t be operated, and they sometimes get in the way of the assistive technology people already use. Accessibility is built into design, code and content. Nor is the BFSG something you tick off with a single audit. And it isn’t just a developer topic. Content, design, product management, procurement of third-party software and customer support all play a part. Under the BFSGV, even support services such as help desks and call centres have to provide accessibility information through accessible channels. ## Your to-do list If you want a structured way in, this order works well: 1. **Check whether you’re covered:** do you provide one of the listed services to consumers? Are you a microenterprise? Write down your reasoning. 2. **Take stock:** which websites, apps, subdomains, customer portals and embedded third-party services make up your offering? 3. **Test:** check your key user journeys against WCAG 2.1 AA, ideally 2.2. Our article on [accessibility testing](https://barrierefreihochzwei.de/en/blog/accessibility-testing-tools-test-plan) shows how. 4. **Prioritise:** start with anything that blocks people completely, such as sign-up, login, basket and checkout. 5. **Involve your vendors:** ask payment providers, shop platforms, consent banners and chat widgets for accessibility information, and make it part of contract renewals. 6. **Publish the required information:** write your Annex 3 information and link to it where people can find it. 7. **Build it into your process:** add accessibility to your design system, definition of done, editorial guidelines and acceptance testing. 8. **Make feedback easy:** offer an accessible way for people to report problems, and respond quickly. ## Quick checklist - Scope assessed and documented - Key user journeys tested against WCAG 2.1 AA - Login, authentication and payment accessible - Annex 3 information published and accessible - Competent market surveillance authority named in that information - Owners and testing intervals defined ## Conclusion The BFSG turns good intentions into a concrete obligation. Since 28 June 2025, online shops and many other consumer-facing digital services in Germany must be perceivable, operable, understandable and robust, which in practice means meeting WCAG 2.1 AA. On top of that come information duties and a market surveillance regime that can go as far as prohibiting a service. The good news is that none of these requirements are new, and they are well documented. If you test your main user journeys, remove the biggest barriers and make accessibility part of how your team works, you’re on solid ground. And your service gets easier to use for every customer along the way. For an overview of every criterion, head to the [WCAG guide](https://barrierefreihochzwei.de/en/wcag). ## Sources - [Barrierefreiheitsstärkungsgesetz (BFSG) – gesetze-im-internet.de (German)](https://www.gesetze-im-internet.de/bfsg/) - [BFSG regulation (BFSGV) – gesetze-im-internet.de (German)](https://www.gesetze-im-internet.de/bfsgv/) - [Directive (EU) 2019/882 (European Accessibility Act) – EUR-Lex](https://eur-lex.europa.eu/eli/dir/2019/882/oj) - [Bundesfachstelle Barrierefreiheit (Federal Accessibility Agency)](https://www.bundesfachstelle-barrierefreiheit.de/) - [Web Content Accessibility Guidelines (WCAG) 2.1 – W3C](https://www.w3.org/TR/WCAG21/)