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BFSG Compliance and WCAG 2.2 Audits for Your Digital Accessibility

Since June 28, 2025, the German Accessibility Strengthening Act (BFSG) requires businesses to offer accessible digital services. We audit against WCAG 2.2 AA, fix barriers in your existing code and guide you through to your BFSG accessibility statement.

Request a Free Initial Consultation Services in Detail
WCAG audit from €2,480 fixed price Own accessibility statement published BFSG advice and implementation Audit report with prioritized findings

In short and in plain language

This page shows what we do for accessibility. Accessible means that all people can use a website. This includes people with disabilities.

The BFSG is a German law. It says that many firms must make their online services accessible. As a rule, this applies to online shops. It also applies to banks and e-books.

We test your website against the WCAG. These are rules for accessible websites. We test with tools and check each rule by hand. We also use the site without a mouse.

Then we fix the issues in your existing code. We help you with your accessibility statement. We also offer training and ongoing monitoring.

The first talk is free. Write to us or give us a call.

Key figures

WCAG 2.2

conformance target level AA

EN 301 549

European standard as audit reference

A + AA

all success criteria of both levels audited

BFSG

accessibility statement per Section 14

Digital accessibility has been mandatory since June 28, 2025

The German Accessibility Strengthening Act (BFSG) has applied since June 28, 2025. Violations can trigger fines of up to 100,000 euros (Source: BFSG Section 37) and a ban on the offering. In your free initial consultation we show you where your website stands and which barriers to fix first.

BFSG advice and implementation

from €2,480 fixed price, net
  • BFSG quick check as an entry point: €490 net
  • Audit and remediation as a complete package: from €4,900
  • Accessibility statement at a fixed price: €390
  • Ongoing BFSG monitoring: from €49 per month
Request a Fixed-Price Quote All Services and Prices

WCAG 2.2 audit for SME websites up to 30 pages. All prices net. Larger websites and online shops are calculated by page type — you receive the binding fixed-price quote after the audit.

Prices as of October 2026. Ongoing services are booked individually and can be cancelled monthly; there is no minimum term.

The German Accessibility Strengthening Act (BFSG) implements the European directive (EU) 2019/882, the European Accessibility Act (EAA), into German law. Since June 28, 2025, digital products and services, including online shops, banking services and e-books, must be accessible. The technical reference is the European standard EN 301 549, which refers to the Web Content Accessibility Guidelines (WCAG) for websites. We audit against WCAG 2.2 AA; this benchmark covers the requirements of WCAG 2.1 AA, on which version V3.2.1 of EN 301 549 is based (Source: W3C WCAG 2.2). For public bodies subject to BITV 2.0 we assess against Table A.1 of EN 301 549 in the BITV assessment.

WCAG 2.2 AA · conformance review
Four principles, one conformance verdict
All criteria at levels A and AA tested — score per POUR principle, overall rating and the open fine range
93
Perceivable
85
Operable
97
Understandable
90
Robust
88
Overall · Level AA
Fine range for non-conformance · BFSG Section 37up to €100,000
without audit
conformant · €0complaintfine up to €100,000
WCAG 2.2 auditfrom €2,480 fixed price
Audit reportwith prioritized findings
WCAG 2.2 audit report: conformance status per principle, a prioritized findings list and next steps. Example view — values are illustrative.

Four principles, one clear conformance finding

Instead of a raw tool dump, you receive a structured report along the four WCAG principles: perceivable, operable, understandable and robust. Every barrier is mapped to a success criterion, classified by severity and accompanied by a concrete remediation proposal.

  • Conformance status per WCAG principle at a glance
  • Severity levels from critical to low, clearly prioritized
  • Findings linked to specific WCAG 2.2 success criteria
All criteria at levels A and AA · WCAG 2.2A/AA
Findings with proposed fix14
Level AA reachable after fixesAA
Example values · every finding with success criterion3 critical · 11 medium

Six Core Services for Your Digital Accessibility

Accessibility is not a one-time project but an ongoing process. Our services cover the entire lifecycle: from initial auditing through remediation of identified barriers to continuous monitoring and team training. They are organized into six coordinated service areas.

WCAG 2.2 Accessibility Audits

Systematic review against all WCAG 2.2 success criteria at levels A and AA. Automated measurement with axe-core and our own checks, plus assessment of every criterion, keyboard and screen reader output.

Learn more

Technical Remediation

Fixing the identified barriers: semantic HTML, color contrasts, ARIA labels and keyboard-accessible interaction elements. We work directly in the source code of your CMS or shop system.

Learn more

Keyboard and Screen Reader Output

We check whether names, roles, states and status messages are marked up so that screen readers can announce them, and operate every flow without a mouse: navigation, forms, shopping cart, checkout and information search.

Training and Workshops

Practice-oriented training for developers, designers and content editors. Your teams learn to integrate accessibility from the start of the development process.

Learn more

Monitoring and Compliance

Continuous automated monitoring of your website for accessibility issues. Regular manual re-audits and documentation for your accessibility statement.

Strategic Consulting

Analysis of your legal obligations under the BFSG, a prioritized roadmap and measurable goals. Accessibility as a strategic advantage: larger audience, a structure search engines can read well and legal compliance.

Learn more

Why Accessibility Is Now Mandatory: The BFSG Overview

The Accessibility Strengthening Act (BFSG) has been in effect since June 28, 2025 and affects a wide range of digital products and services. Online shops selling products or services to consumers must make their websites accessible. The same applies to banking services, passenger transport, telecommunications and electronic books.

How the BFSG requirements are legally anchored

The technical requirements of the BFSG are based on the harmonized European standard EN 301 549, which in turn references WCAG as the minimum technical standard. In addition to official fines, consumers and recognized associations can ask the market surveillance authority to open proceedings against the provider (BFSG Section 32). Which BFSG requirements specifically apply to your sector we clarify in the initial consultation.

A barrier becomes an operable element

The same function, a login form, once with common barriers and once after remediation. It becomes visible what accessibility means in concrete terms: labeled fields, sufficient contrast, a visible focus and understandable error messages instead of color signals alone.

  • Before: missing labels, weak contrast, no focus ring
  • After: programmatically labeled fields with a clear focus
  • Error hints as text, not conveyed by color alone
Before · login3 violations
e-mail
password
Contrast 2.1:1 — not sufficient
no label, no focus ring
error conveyed by colour only
WCAG 1.4.3 · 2.4.7 · 3.3.1
VS
After · loginWCAG 2.2 AA
name@company.invalid
at least 8 characters
Contrast 7:1, visible focus
programmatic labels (ARIA)
error as text and icon
passed: 1.4.3 · 2.4.7 · 3.3.1 · 4.1.2

Who Is Specifically Affected by the BFSG?

In principle, every online shop selling products or services to consumers is affected. Micro-enterprises with fewer than ten employees and an annual turnover or balance sheet total of no more than two million euros are exempt insofar as they offer or provide services (Source: BFSG Section 2 No. 17, Section 3 Para. 3); it does not apply to products under Section 1 Para. 2, such as computers, payment terminals or e-book readers. Even if your company formally falls under the exemption, we strongly recommend implementing accessibility: around 7.8 million severely disabled people live in Germany (Source: Destatis, end of 2025), and around 19.3 million people are aged 65 or older (Source: Destatis, 2025).

Online Shops and E-Commerce

Shops selling products or services to consumers must meet BFSG requirements unless they are exempt as micro-enterprises. This covers the entire purchase process: product search, product detail pages, shopping cart, checkout and payment.

Corporate Websites

Websites also fall under the BFSG if they offer consumers services with a view to concluding a contract (BFSG Section 2 No. 26). This can include contact forms, appointment booking, online configurators and self-service portals.

Banking Services

Online banking, account opening, transfers and other banking services for consumers must be accessibly designed. The requirements apply equally to web interfaces and mobile applications.

Telecommunications

Telecommunication services and their digital access points, including customer portals, contract conclusions and self-service functions, are subject to the accessibility requirements of the BFSG.

Passenger Transport

In air, bus, rail and waterborne transport, websites, apps, electronic tickets, travel information and interactive information screens must be accessible. In urban, suburban and regional transport this applies only to interactive self-service terminals (BFSG Section 1 Para. 3).

E-Books and Digital Media

Electronic books and associated distribution platforms must meet accessibility requirements. This includes navigable content structures, adjustable text sizes and compatible formats.

Our Audit Process: Systematic, Thorough, Practical

An accessibility audit is only as good as its methodology. Automated tools such as axe-core are indispensable but do not detect all conformance failures (WebAIM Million 2026). Complex barriers such as inconsistent navigation order, incomprehensible error messages or poor screen reader compatibility require human expertise. That is why we combine automated measurement with the assessment of every criterion and checks of keyboard operation and screen reader output.

Three audit layers that build on each other

Automated measurement provides breadth, the assessment of every criterion provides depth, and checking keyboard operation and screen reader output shows whether every flow can be operated. Only the combination of these three layers produces a realistic picture of the accessibility of your digital offerings.

  • Automated checks do not detect all conformance failures (WebAIM Million 2026)
  • Assessment of every success criterion at levels A and AA per view
  • Keyboard without a mouse and screen reader output
1
Automated measurement
axe-core and our own measurements — desktop and smartphone
breadth
2
Assessment per criterion
all criteria at levels A and AA — context and understandability
depth
3
Keyboard and screen reader output
names, roles, states — every flow without a mouse
practice
Result: audit report and accessibility statement (BFSG Section 14)EN 301 549

From scope to accessibility statement

  1. Scope Definition and Page Selection

    Together we define the audit scope. For online shops, the audit typically covers the homepage, category and product pages, search, shopping cart, checkout, login, registration and contact forms. We select representative pages that cover all essential page types and user flows.

  2. Automated Testing

    Automated structure checks with axe-core and our own in-browser measurements, in the desktop and smartphone layout. Automated tests identify technical barriers such as missing alt texts, insufficient contrasts, missing form labels and invalid ARIA attributes. Results are deduplicated and classified by severity.

  3. Assessment per Criterion

    We assess every WCAG 2.2 success criterion at levels A and AA per view, with focus on perceivability, operability, understandability and robustness. We evaluate context, consistency and actual usability, not just technical rule conformance.

  4. Keyboard and Screen Reader Output

    We operate every flow without a mouse and check whether names, roles, states and status messages are marked up so that screen readers can announce them. We document the barriers that interrupt the flow.

  5. Audit Report and Prioritization

    You receive a detailed audit report with screenshots, affected WCAG criteria, severity rating and concrete solution proposals. Prioritization considers both severity and effort, so you can immediately start with the most impactful measures.

  6. Re-Audit and Accessibility Statement

    After remediation of all critical and high barriers, we conduct a re-audit. Upon successful review, we support you in creating and publishing your accessibility statement per BFSG Section 14.

BFSG Packages: A Clear Start, Clear Fixed Prices

All prices net. From a quick check to the complete package of audit and remediation — we determine the right scope together after a brief review. Details on the Services page.

BFSG Quick Check

A fast initial assessment of the home page and one business-critical process as an entry point.

€490 one-off, net
  • Automated measurement plus visual inspection
  • Home page and one business-critical process in scope
  • Short report with the most critical findings
  • Adds test findings to the free initial BFSG assessment from the first consultation (not legal advice)
  • Fully credited against a later full audit
Request quick check
Recommended

WCAG 2.2 Audit

Full audit for SME websites with up to 30 pages.

from €2,480 fixed price, net
  • All WCAG 2.2 success criteria at levels A and AA reviewed
  • Automated measurement, per-criterion assessment, keyboard and screen reader output
  • Detailed audit report with remediation proposals
  • Prioritization by severity and effort
  • Basis for the accessibility statement
Request audit

Audit + Remediation

Complete package: audit and fix barriers in your existing code.

from €4,900 net, project-based
  • WCAG 2.2 audit included
  • Technical remediation of the identified barriers
  • Re-audit after implementation
  • Accessibility statement per BFSG Section 14 included
  • Optional ongoing monitoring from €49 per month
Request full package

Further fixed prices: PDF accessibility from €4.90 per page (minimum €149 per document), plain-language translation €119 per standard page, accessibility statement €390, BFSG monitoring from €49 per month. All details on the Services page.

Accessibility Is Not a Cost Factor but a Competitive Advantage

Companies that view accessibility exclusively as a regulatory obligation are leaving significant business potential on the table. A WebAIM analysis of one million homepages found that 95.9 percent of all tested pages had at least one WCAG error (Source: WebAIM Million 2024). Companies that consistently make their websites accessible stand out in a market where the vast majority of websites are not yet conformant.

AspectWithout accessibilityWith WCAG 2.2 AA
BFSG legal compliancefine and warning riskdocumented conformance
Reachable audiencesystematically limitedreachable for people with disabilities too
SEO and discoverabilityuntapped potentialsemantic HTML, clear structure
Usability for everyonehurdles for mobile users tooclear navigation and forms
Accessibility statementmissing or incompleteper BFSG Section 14 and Annex 3

Many WCAG criteria directly overlap with SEO best practices: semantic HTML, meaningful alt texts, clear heading structure and mobile responsiveness. Accessibility is one of the few measures that simultaneously fulfills compliance, improves user experience and supports discoverability.

Our approach to sustainable accessibility

What Can Be Measured After Implementation

Whether session duration, bounce rate or conversion rate change depends on your offering and your visitors, and shows in a comparison of your own analytics data before and after implementation. Regardless of that, accessible websites are more usable for all users, not just people with disabilities: clear navigation, understandable forms, sufficient contrasts and a logical page structure benefit every visitor.

Unsure whether your website is BFSG-compliant?

We assess your status against WCAG 2.2 AA and show you which barriers to tackle first. No sales pressure, just clear prioritization.

Request initial consultation Audit in detail

How We Test

We test with our own tool set, which loads every page in a real browser and measures it there: in the desktop and smartphone layout and in the states that only open after a click. Automated structure checks are handled by the open-source tool axe-core; contrast, keyboard, focus, target sizes and reflow are measured by our own checks. Whatever no tool decides, we assess per criterion.

axe-core

Open-source rule set for automated WCAG checks. Checks structure, labels and ARIA directly in the loaded page, including opened menus and dialogs. Whatever axe-core cannot decide goes into the assessment of each criterion.

In-Browser Measurement

Every page is loaded in a Chromium browser, driven by Playwright. This way we measure the page as it is delivered, with all scripts and fonts, in the desktop and smartphone layout.

Screen Reader Output

For every control we read out what the browser passes on to screen readers: name, role and state, plus headings, landmarks and status messages. Tests with specific screen readers on specific devices are not included.

Flows and States

We play through flows such as login, search and checkout step by step: opening menus, submitting forms with invalid input, closing dialogs. Every state is measured again.

Contrast Measurement

Contrast per WCAG criterion 1.4.3 on every text element, calculated from the colours the browser actually paints. Where text sits on gradients or images, a screenshot decides.

Keyboard, Focus and Target Sizes

Every flow is operated without a mouse: order, visible and unobscured focus, Escape in dialogs. Plus target sizes per WCAG 2.5.8, reflow at 320 pixels width and text spacing.

At a glance

WCAG 2.2 AA
EN 301 549
BFSG / EAA
axe-core
Playwright
Desktop + smartphone
Semantic HTML
WAI-ARIA 1.2
BITV 2.0
Chromium

Why We Audit Against WCAG 2.2 Instead of WCAG 2.1

WCAG 2.2 was published as an official W3C Recommendation in October 2023 and supplements WCAG 2.1 with nine new success criteria, six of which are relevant for conformance level AA (Source: W3C WCAG 2.2). EN 301 549 version V3.2.1 references WCAG 2.1 AA; version V4.1.1, published in September 2026, adopts WCAG 2.2 as its benchmark. It becomes the reference for the presumption of conformity once it is cited in the Official Journal of the EU (Source: AccessibleEU 2026).

  • Visible focus indicators that are not obscured by sticky headers or cookie banners
  • Sufficiently large touch targets on mobile devices
  • Drag-and-drop functions with an equivalent keyboard alternative
  • Accessible authentication without pure memory or puzzle tasks
  • Consistent help mechanisms across all pages

Choosing WCAG 2.2 over WCAG 2.1 brings two advantages: first, the audit benchmark already matches the WCAG version adopted by the new version of EN 301 549. Second, the new criteria address barriers that actually affect real users, particularly people with motor or cognitive impairments. An audit against WCAG 2.2 therefore covers more requirements than one against WCAG 2.1 and lays the groundwork for a better user experience for all your website visitors.

How Accessibility Improves User Experience for Everyone

The assumption that accessibility only concerns a small user group is a widespread misconception. In truth every website visitor benefits from accessible design. Clear form labels reduce input errors for all users. Sufficient color contrasts improve readability even in sunlight on smartphone displays. A logical tab order and visible focus indicators help power users who prefer keyboard shortcuts. Understandable error messages can reduce abandonment rates in checkout processes for all customers.

The combination of regulatory obligation and economic benefit makes accessibility one of the most sensible investments in the future of your digital presence. Companies that act now not only create the conditions for BFSG conformance but position themselves as responsible brands that welcome all people. Those who lay the foundations today can benefit tomorrow from a broader customer base and a better overall digital experience.

Background from our specialist articles

If you want to form your own picture before commissioning anything, our blog covers the fundamentals: why accessibility overlays are not a BFSG solution, which new success criteria WCAG 2.2 introduces and how to calculate the cost and return of an accessibility audit realistically. If you would rather start from your use case, the overview accessibility by industry helps; regional information is available under regional accessibility.

Three routes to BFSG compliance compared

Two of these three routes do not solve the problem.

Risk

Wait and see

  • Not included: No cost, but no conformance either
  • Not included: Fines of up to €100,000 are possible (BFSG §37)
  • Not included: User groups remain excluded
  • Not included: No evidence for clients and tenders
Shortcut

Install an overlay widget

  • Not included: Quick to install, but it only changes the presentation in the browser
  • Not included: The underlying source code stays unchanged
  • Not included: Accessibility professionals advise against it in a joint statement (Overlay Fact Sheet)
  • Included: Details in the article on accessibility overlays
Our approach

Audit and fix in the code

  • Included: All success criteria at levels A and AA assessed per view
  • Included: Keyboard and screen reader output, not just an automated scan
  • Included: Fixed in your existing system, without a relaunch where the existing setup allows
  • Included: Documented proof through the accessibility statement

Typical Starting Points and Our Approach

Corporate website
Starting point
The automated scan reports only a few errors, yet the keyboard run-through already stalls in the main menu.
Measure
Rebuild the navigation semantically, correct the focus order and make submenus operable by keyboard.
Result
Goal: all areas of the site can be reached without a mouse.
Contact form
Starting point
Required fields are marked only by a red border, and error messages have no association with the field.
Measure
Associate labels programmatically, add error texts at the field and insert a linked error summary.
Result
Goal: input errors are explained comprehensibly instead of merely coloured in.
Application documents
Starting point
Downloadable forms exist only as scanned PDF files without a text layer.
Measure
Tag documents per PDF/UA, set the reading order and label form fields.
Result
Goal: applications can be completed with a screen reader; remaining legacy stock is named in the statement.

Examples, not client projects.

Frequently Asked Questions About Digital Accessibility

How the website of a university department could look

The draft shows structure and handling: degree programmes you can narrow down, an application path in steps, a section on disability provisions and campus access. The university in it is invented.

Draft
University department

Department with degree filter and disability provisions

A draft for a university department: eight degree programmes can be filtered by qualification and study mode, each listing award, standard duration and entry requirements in the same order. The application is described in four steps, and a separate section covers disability provisions and the advisory service hours. On campus accessibility the draft names ramp gradient, hearing loop and tactile guidance — and what is missing.

Degree filterDisability provisionsCampus detailsSubtitles

Illustrative layout drafts. The businesses shown are fictitious; these are not client projects.

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