BFSG: What Germany’s Accessibility Act Means for Your Website

Since 28 June 2025, digital accessibility in Germany is no longer optional — for many companies it's a legal requirement. The Barrierefreiheitsstärkungsgesetz (BFSG, "Accessibility Reinforcement Act") requires certain products and services to be usable by everyone — including the roughly 7.8 million severely disabled people in Germany and anyone navigating with a screen reader, a keyboard, or in poor lighting.

What's new: for the first time the legislator obliges not only public authorities but the private sector. If you run an online shop, offer digital services, or are planning a relaunch, you should know what's coming.

What is the BFSG — and where does it come from?

The BFSG is Germany's transposition of EU Directive 2019/882, better known as the European Accessibility Act (EAA). The goal is a unified European single market for accessible products and services.

The act itself sets out the general obligation. The concrete technical requirements live in the accompanying regulation (BFSGV). And how you meet those requirements in practice is described by a harmonised European standard — which ultimately points to an internationally established set of rules.

For websites and apps, the relevant standard is EN 301 549, which in turn builds on the Web Content Accessibility Guidelines (WCAG) 2.1 at level AA. In short: if you build your site to WCAG 2.1 AA, you meet the core of the legal requirements.

Are you even affected?

This is the key question — and the answer is more nuanced than many alarmist articles suggest. The BFSG doesn't blanket-apply to every website, but to clearly defined products and services offered to consumers. These include, among others:

• Services in electronic commerce — i.e. the classic online shop. This is the point that captures most websites.
• Consumer banking services, e-books, telecommunications services, elements of passenger transport (e.g. ticketing apps).
• Certain products such as computers, smartphones, ATMs and ticket machines, or e-book readers.

The important exemption: micro-enterprises offering services are exempt from the BFSG — defined as companies with fewer than 10 employees and at most €2M annual turnover (or balance-sheet total). Note: this exemption applies to services only, not to companies placing products on the market.

What "accessible" means technically

Behind EN 301 549 sit the WCAG with their four core principles. They are the lens through which you should look at your site:

In everyday terms, for your website that means, for example:

• Sufficient colour contrast (at least 4.5:1 for normal text) — and never conveying information through colour alone.
• Full keyboard operability with a visible focus indicator: anything you can do with a mouse must also work with the Tab key.
• Alt text for meaningful images, captions/transcripts for videos.
• Correctly labelled forms (every field with a label), understandable error messages.
• Clean document structure: logical heading hierarchy, sensible order, semantic HTML instead of <div> soup.

What happens if you don't comply?

Compliance is monitored by the states' market surveillance authorities. They can identify defects, order remediation and, in extreme cases, prohibit the provision of a service. On top of that come possible fines (§ 37 BFSG governs the amount) and the risk of competition-law warnings from competitors or associations. More important than the sanction, though, is usually the reputation and revenue effect: locking out a relevant share of your customers leaves money on the table.

The underrated bonus: accessibility pays into SEO and performance

Many BFSG measures overlap with what Google rewards: clean semantics, sensible headings, alt text, clear structure and fast, robust pages. An accessible page is almost always a better page — for search engines, for your Core Web Vitals and for every single user. Accessibility is therefore not a pure compliance chore but an investment in quality.

How to start sensibly

1. Clarify whether you're affected: Do you offer a covered service? Does the micro-enterprise exemption apply?
2. Audit: check the status quo against WCAG 2.1 AA — automated (tools like axe or Lighthouse) and manual (keyboard test, screen-reader test). Automation only finds part of the issues.
3. Prioritise & implement: the critical blockers first (checkout, navigation, forms), then the finer points.
4. Embed it: bake accessibility into your design system, components and editorial process so new content doesn't reintroduce barriers.

Frequently asked questions about the BFSG

Does the BFSG apply to my small company website?

It depends on what you offer. A pure brochure site without a sales or booking function often isn't directly covered. As soon as consumers can buy or book online, it usually becomes relevant — unless you're exempt as a micro-enterprise (fewer than 10 employees and at most €2M turnover) offering a service.

Is an accessibility overlay or plugin enough?

No. Overlays that promise "accessibility" at the push of a button usually don't fix the underlying problems in the code, and are viewed critically by many affected users and experts. Real conformance happens in the markup, the design and the content — not in a bolted-on layer.

WCAG 2.1 or 2.2?

The decisive reference for the BFSG is the harmonised standard EN 301 549, which points to WCAG 2.1 level AA. Anyone who additionally considers the newer criteria from WCAG 2.2 is on the safe and future-proof side.

When should it have been ready?

The BFSG has applied since 28 June 2025. Newly offered services have had to meet the requirements since then. So if your site isn't yet conformant, the right time for an audit is now.

Sources

• Barrierefreiheitsstärkungsgesetz (statute text) — gesetze-im-internet.de/bfsg
• Federal Accessibility Agency: BFSG FAQ — bundesfachstelle-barrierefreiheit.de
• Federal Ministry of Labour and Social Affairs (BMAS): BFSG — bmas.de
• EU Directive 2019/882 (European Accessibility Act) — eur-lex.europa.eu
• W3C: Web Content Accessibility Guidelines (WCAG) 2.1 — w3.org/TR/WCAG21