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BFSG compliance since 2025

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 to a legally sound accessibility statement.

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WCAG audit from 2,480 € fixed price This site itself meets WCAG 2.2 AA BFSG advice and implementation Audit report in 5 business days

WCAG 2.2

conformance target level AA

5 business days

to the audit report

78

WCAG success criteria tested

50+

accessible projects

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), distribution bans and injunction lawsuits by associations. 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.

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 meet the requirements of the harmonized standard EN 301 549. This standard in turn references the Web Content Accessibility Guidelines (WCAG) 2.1 AA as the minimum technical standard. We go one step further and audit against WCAG 2.2 AA, the current state of the art.

WCAG 2.2 AA · conformance review
Four principles, one conformance verdict
78 criteria 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 reportin 5 business days
WCAG 2.2 audit report from our review team: 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
78 criteria tested · WCAG 2.2 AA78
56 criteria passed56
Level AA reachable after fixesAA
Every finding with success criterion and proposed fix3 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. In 50+ projects we have gained experience that we have consolidated into six coordinated service areas.

WCAG 2.2 Accessibility Audits

Systematic review against all 78 success criteria of WCAG 2.2 at level AA. Automated testing with axe-core and Lighthouse plus manual expert evaluation with assistive technologies.

Learn more

Technical Remediation

Fixing all 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.

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Screen Reader and Assistive Testing

Manual testing with NVDA, JAWS and VoiceOver on Windows, macOS and mobile devices. We test real scenarios: 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.

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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, better SEO and legal compliance.

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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, consumer protection associations can file injunction lawsuits under the Consumer Rights Enforcement Act. 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.com
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?

Virtually every online shop selling products or services to consumers is affected. Only micro-enterprises with fewer than ten employees and an annual turnover of no more than two million euros are exempt, and this exemption only applies to certain product categories (Source: BFSG Section 3 Para. 3). 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 2023), and over 17 million people are over 65 (Source: Destatis 2024).

Online Shops and E-Commerce

All shops selling products or services to consumers must meet BFSG requirements. This covers the entire purchase process: product search, product detail pages, shopping cart, checkout and payment.

Corporate Websites

Websites offering services or concluding contracts online also fall under the BFSG. This includes contact forms, appointment booking, online configurators and self-service portals.

Banking Services

Online banking, account opening, transfers and all other digital banking services 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

Digital booking systems, timetable information and ticket portals for passenger transport must be accessibly designed. This covers websites, apps and digital information displays.

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 like axe-core, Lighthouse and WAVE are indispensable but demonstrably detect only around 30 to 50 percent of all accessibility issues (Source: WebAIM 2024). Complex barriers such as inconsistent navigation order, incomprehensible error messages or poor screen reader compatibility require human expertise. That is why we combine automated scans with manual expert evaluation and testing with assistive technologies.

Three audit layers that build on each other

Automated scans provide breadth, manual expert evaluation provides depth, and tests with real assistive technologies reveal actual usability. Only the combination of these three layers produces a realistic picture of the accessibility of your digital offerings.

  • Automated scans cover around 30 to 50 percent (Source: WebAIM 2024)
  • Manual evaluation of each of the 78 WCAG 2.2 success criteria
  • Real tests with NVDA, JAWS and VoiceOver
1
Automated scans
axe-core, Lighthouse, WAVE, Pa11y — breadth across all pages
40 %
2
Manual expert review
all 78 WCAG 2.2 AA criteria — context and real usability
70 %
3
Assistive technologies
NVDA, JAWS, VoiceOver, TalkBack — real user scenarios
95 %
Result: audit report and conformance statement (BFSG Section 14)EN 301 549

From scope to conformance declaration

  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 following the methodology of EN 301 549, Annex C.

  2. Automated Testing

    Deployment of axe-core, Lighthouse, WAVE and Pa11y for initial systematic analysis. 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. Manual Expert Evaluation

    Trained auditors manually review each of the 78 WCAG 2.2 AA success criteria, with focus on perceivability, operability, understandability and robustness. We evaluate context, consistency and actual usability, not just technical rule conformance.

  4. Assistive Technology Testing

    Practical tests with NVDA and JAWS on Windows, VoiceOver on macOS and iOS, and TalkBack on Android. We run through real user scenarios and document every barrier that interrupts the usage 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 Conformance Declaration

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

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 your most important pages as an entry point.

490 € one-off, net
  • Review of your homepage and two core pages
  • Automated scan plus manual spot check
  • Prioritized shortlist of the most critical barriers
  • Creditable toward a later full audit
Request quick check
Most chosen

WCAG 2.2 Audit

Full audit for SME websites with up to 30 pages.

from 2,480 € fixed price, net
  • All 78 WCAG 2.2 AA success criteria reviewed
  • Automated scans, expert review and screen reader tests
  • Detailed audit report with remediation proposals
  • Audit report within 5 business days
  • 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. According to a study by Aktion Mensch, people with disabilities in Germany have an annual purchasing power of approximately 8 billion euros (Source: Aktion Mensch 2023). 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 competitors are not yet conformant.

AspectWithout accessibilityWith WCAG 2.2 AA
BFSG legal compliancefine and warning riskdocumented conformance
Reachable audiencesystematically limitedmillions of additional users
SEO and discoverabilityuntapped potentialsemantic HTML as a ranking plus
Usability for everyonehurdles for mobile users tooclear navigation and forms
Accessibility statementmissing or incompletemachine-readable per EN 301 549

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 increases discoverability.

Our approach to sustainable accessibility

Typical Results After Implementation

Our clients regularly report measurable improvements after accessibility optimization: average session duration increases, bounce rate decreases and conversion rate improves. This is because 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 (project experience).

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

Technologies and Tools We Use

Our work is based on the current state of the art in accessibility testing and development. We use a combination of established open-source tools, commercial testing instruments and assistive technologies to ensure comprehensive analysis. Our toolkit is complemented by proprietary audit checklists that we continuously develop and adapt to current normative changes.

axe-core and axe DevTools

Widely used open-source tool from Deque Systems for automated WCAG testing. Detects over 80 categories of accessibility issues directly in the browser. Integrated into our CI/CD pipelines for continuous quality assurance.

Google Lighthouse

Automated testing of accessibility, performance and best practices. Lighthouse tests contrast ratios, form labels, tab order and ARIA validity among others. Results feed into our comprehensive report.

NVDA, JAWS and VoiceOver

Manual testing with the three most widely used screen readers. NVDA and JAWS cover the Windows market, VoiceOver tests Apple platforms. This ensures your website works with all common assistive technologies.

Pa11y and Playwright

Automated end-to-end accessibility tests that run through complete user scenarios. Pa11y tests static pages, Playwright simulates interactive flows like login, search and checkout. Both tools integrate into existing test infrastructures.

Colour Contrast Analyser

Pixel-precise testing of color contrast ratios per WCAG 2.2 success criterion 1.4.3. We test not just static colors but also hover states, focus indicators and state changes on interactive elements.

Keyboard and Touch Testing

Systematic testing of complete keyboard operability: Can all functions be reached without a mouse? Are focus order and indicators logical? Does touch operation work on mobile devices with accessibility features enabled?

WCAG 2.2 AA
EN 301 549
BFSG / EAA
axe-core
Lighthouse
NVDA / JAWS
Semantic HTML
WAI-ARIA 1.2
BITV 2.0
Pa11y

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). Although EN 301 549 formally references WCAG 2.1 AA, WCAG 2.2 represents the current state of the art. Courts and supervisory authorities typically orient themselves to the state of the art, not the minimum standard.

  • 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, you are future-proof as EN 301 549 will foreseeably be updated to WCAG 2.2 in coming years. Second, the new criteria address barriers that actually affect real users, particularly people with motor or cognitive impairments. An audit against WCAG 2.2 offers considerably more comprehensive protection against complaints and 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 reduce abandonment rates in checkout processes for all customers (project experience).

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 secure BFSG conformance but position themselves as responsible brands that welcome all people. Those who lay the foundations today will 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; for in-person meetings you will find the locations under regional accessibility.

Three routes to BFSG compliance compared

We meet all three in initial conversations. Two of them 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: Professional associations and the W3C Web Accessibility Initiative advise against it (W3C WAI, Overlay Fact Sheet)
  • Included: Details in the article on accessibility overlays
Our approach

Audit and fix in the code

  • Included: All 78 WCAG 2.2 AA success criteria checked manually
  • Included: Tested with NVDA, JAWS and VoiceOver, not just an automated scan
  • Included: Fixed in your existing system, usually without a relaunch (project experience)
  • Included: Documented proof through the accessibility statement

Typical Courses of Accessibility Projects

Corporate website
Starting point
The automated scan reported only a few errors, yet the keyboard run-through already stalled in the main menu.
Measure
Navigation rebuilt semantically, focus order corrected and submenus made operable by keyboard.
Result
All areas of the site can be reached without a mouse; the findings were closed in the re-test.
Contact form
Starting point
Required fields were marked only by a red border, and error messages had no association with the field.
Measure
Labels associated programmatically, error texts added at the field and a linked error summary inserted.
Result
Input errors are explained comprehensibly instead of merely coloured in.
Application documents
Starting point
Downloadable forms existed only as scanned PDF files without a text layer.
Measure
Documents tagged per PDF/UA, reading order set and form fields labelled.
Result
Applications can be completed with a screen reader; the remaining legacy stock is named in the statement.

Illustrative scenarios from typical project histories (project experience) — anonymized, without client reference and without promised metrics.

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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