Accessibility Strengthening Act from 2025: What Companies Need to Know Now

On June 28, 2025, the Barrierefreiheitsstärkungsgesetz (BFSG) will come into effect. This law makes accessibility a mandatory requirement for a wide range of digital products and services, including those in the private sector. The aim is to provide people with disabilities equal access to digital offerings. This overview explains who is affected, what is required, and what penalties may be imposed.

Background: Why does the BFSG exist?

The BFSG implements the EU Directive 2019/882, also known as the European Accessibility Act (EAA). This directive requires member states to ensure that certain digital products and services are designed to be accessible in the future. In Germany, the implementation is through the BFSG, which was passed on July 22, 2021, and will become legally binding on June 28, 2025.

The goal is to enable societal participation for all people, particularly those with disabilities, but also for older individuals or those with temporary limitations (e.g., after an accident).

Who is affected?

Companies offering the following products or services:

• Websites and mobile applications (e.g., online shops, customer portals, apps)
• E-books and e-readers
• Banking services (e.g., online banking)
• Telecommunications services
• Self-service terminals (e.g., ticket machines, ATMs, check-in terminals)
• Hardware such as smartphones, tablets, routers, or smart TVs

The obligation for accessibility applies not only to public institutions but also to private companies, as long as they target end customers in the EU internal market.

Exceptions:

• Micro-enterprises with fewer than 10 employees and an annual turnover or balance sheet total of less than €2 million are exempt from the BFSG obligation (§ 2 Abs. 1 BFSG).
• Existing products can continue to be marketed.
• Transition periods apply to already installed terminals (e.g., ATMs) until 2040.

What does "accessible" mean?

According to § 3 BFSG, accessibility means that products and services are designed in such a way that they can be found, accessed, and used by people with disabilities without external assistance—under normal conditions.

Technically significant are:

• The Web Content Accessibility Guidelines (WCAG) 2.1, Conformance Level AA
• The European standard EN 301 549, particularly for information and communication technology

The four principles of the WCAG are:

• Perceivable (e.g., alternative texts for images)
• Operable (e.g., keyboard navigation)
• Understandable (clear language, logical structure)
• Robust (compatible with assistive technologies)

What specific requirements does the BFSG impose?

Companies must ensure that:

• Digital offerings are designed to be accessible (websites, apps, e-services)
• Technical documentation is created (conformity assessment)
• Accessibility statements are published
• Quick corrective actions can be taken in case of violations
• CE marking and market surveillance procedures are followed (for products)

These requirements affect not only the IT sector but also communication, customer service, and product development.

What happens in case of violations?

Compliance with the BFSG is monitored by the market surveillance authorities of the federal states. Additionally, consumers can file complaints if they encounter barriers.

In case of violations, the following penalties may be imposed:

• Fines of up to €100,000
• Sales bans or recall actions
• Reputational damage through public notices and lawsuits

Digital accessibility doesn't end with design – we think further

Are you facing the implementation of accessible features in your web app, booking platform, or CMS-based website? Our department for App & Software Development and Content Management Systems (CMS) supports you in the technical and design implementation—from the WCAG-compliant interface to the accessible structure of your content. Feel free to contact us if you need assistance.

Request a free initial consultation and get started!

What should companies do now?

1. Conduct an inventory

Review your digital offerings: website, app, booking tools, forms, customer portals—where is accessibility present, where is it not?

2. Check conformity

Conduct an accessibility audit. Tools like Axe, WAVE, or Lighthouse provide initial insights. For legal certainty, a professional assessment is recommended.

3. Start technical implementation

Adapt content according to WCAG 2.1 AA, develop accessible design, incorporate keyboard navigation, correctly structure PDFs, add video subtitles, etc.

4. Establish training & processes

Permanently integrate the topic of accessibility—into content creation, design development, and editorial work.

5. Prepare documentation

CE marking, accessibility statement, and conformity assessment must be available by the deadline.

Sources and Further Reading

Svaerm – What does digital accessibility mean?

DKD: Who must be accessible?

BMAS – Info on BFSG

W3C – Web Content Accessibility Guidelines