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BFSG Requirements: What the Law Demands and Who It Affects

Since June 28, 2025, many digital products and services for consumers in Germany must be accessible — the BFSG implements the European Accessibility Act with clear technical requirements for websites, shops and digital services. Here you learn who is affected, which deadlines apply and how a WCAG 2.2 AA audit from €2,480 documents your conformance status.

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In short and in plain language

This page explains the BFSG. The BFSG is a German law. It says that many offers for consumers must be accessible. Accessible means that all people can use them, including people with disabilities.

The law covers online shops, banks and phone services, for example. Travel tickets and e-books are often covered too.

There is an exception for very small firms. But it is just for services, not for products. The rules for websites are called WCAG.

An authority can check if firms follow the law. Breaking the law can lead to a fine. Firms that are covered must also publish an accessibility statement.

Not sure if the law applies to you? We check your site and help with a first assessment. Write to us or give us a call.

Key figures

EN 301 549

Testing basis

WCAG 2.2 AA

Testing standard

Fixed price

for SME website audits

4

POUR principles of WCAG

The Accessibility Strengthening Act (BFSG) is the central German law for digital accessibility in the private sector. It implements the European directive (EU) 2019/882, the European Accessibility Act (EAA), into national law. While federal public bodies have been obligated to accessibility through BITV 2.0 of 2011, the BFSG extends this obligation to private companies for the first time. This article explains the law's requirements, its scope, the technical standards and the consequences of non-compliance. As a specialized audit and implementation agency, we guide you from the BFSG quick check for €490 through the WCAG 2.2 audit from €2,480 to documentation — see our accessibility services for an overview. We assess our own website against WCAG 2.2 AA ourselves; status and known limitations are set out in our accessibility statement.

BFSG Deadlines: What Has Applied Since June 28, 2025

BFSG · German Accessibility Strengthening Act
The deadlines — and what applies now
Since 28 June 2025, accessible websites and shops have been mandatory for many companies
28 June 2025
Obligation in force
Online shops, booking flows and consumer apps must be accessible — technical benchmark EN 301 549
since September 2025
Market surveillance active
Joint authority of the federal states checks on request and by sampling — violations can be prohibited and subject to fines
Transition until 27 June 2040 at the latest
Self-service terminals
Existing devices until the end of their service life, at most 15 years — new devices accessible immediately
Your roadmap
Audit → remediation → statement
Audit report with a prioritized findings list, then remediation and the accessibility statement under Section 14
Fine range · BFSG Section 37
€100,000
maximum under Section 37(2)
Who is affected
Online shops and booking flows
B2C websites with online contracting
Micro-enterprises partly exempt
WCAG 2.2 auditfrom €2,480 fixed price
In force sinceJune 28, 2025
Overview: entry into force, market surveillance, transition for self-service terminals, fine range under BFSG Section 37 and the path to conformance. Schematic view.

Assess BFSG conformance

from €2,480 fixed price, net
  • Testing against WCAG 2.2 AA and EN 301 549
  • Prioritized findings list with severity levels instead of raw tool output
  • Foundation for your accessibility statement under Section 14 (fixed price €390)
  • Optional ongoing BFSG monitoring from €49 per month
Request a Free Initial Consultation View WCAG audit

WCAG 2.2 audit for SME websites up to 30 pages. Quick start with the BFSG quick check for €490.

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

The BFSG in numbers

28.06.2025
Date of entry into force
up to 100,000 EUR
Fines for violations (BFSG Section 37)
27
EU states with the European Accessibility Act
2030
End of transition period for legacy contracts

Legal Foundations and European Context

The Bundestag passed the BFSG on May 20, 2021; it was signed into law on July 16, 2021 and published in the Federal Law Gazette on July 22, 2021 (BGBl. I p. 2970). Its obligations have applied since June 28, 2025. The law is based on EU Directive 2019/882, which obliges all EU member states to implement uniform accessibility requirements for certain products and services. The goal is removing barriers to the free movement of goods and improving participation of people with disabilities in economic and social life.

The directive defines functional requirements that are technically specified through the European standard EN 301 549. The reference so far is version V3.2.1 from 2021, which references the Web Content Accessibility Guidelines (WCAG) 2.1 at conformance level AA for web content. Version V4.1.1, published in September 2026, adopts WCAG 2.2 but only establishes a presumption of conformity once it is cited in the Official Journal of the EU (status: October 2026). WCAG 2.2 has been a W3C Recommendation since October 2023, and according to the W3C, content that conforms to WCAG 2.2 also conforms to WCAG 2.1. We therefore recommend WCAG 2.2 AA as the assessment standard. Our WCAG 2.2 audit tests against WCAG 2.2 AA and EN 301 549 and prepares you for the legal requirements.

Which Products and Services Are Affected?

The BFSG defines its material scope in Sections 1 and 2. Both physical products and services placed on the market or provided after June 28, 2025 are affected. The digital sector is particularly strongly affected, as many online services for consumers fall under the law, above all electronic commerce.

Electronic Commerce Services

Online shops selling products or services to consumers are affected unless the company is a micro-enterprise. This covers the entire purchase process: product search, catalog navigation, shopping cart, checkout, payment, order confirmation and customer account. Every single step must be accessibly designed.

Consumer Banking Services

Online banking, account opening processes, credit applications, transfers, standing orders and other digital consumer banking services must meet accessibility requirements. This applies to both web interfaces and mobile banking applications.

Telecommunication Services

Telephone services, messenger services and their associated customer portals and self-service areas fall under the BFSG. Contract conclusions, tariff changes and cancellations must also be possible through accessible digital channels.

Passenger Transport Services

Digital booking systems, timetable information, ticket portals and check-in systems for passenger transport must be accessibly designed. This applies to air, bus, rail and waterborne transport; for urban, suburban and regional transport services, the requirements only cover interactive self-service terminals.

E-Books and Reader Applications

Electronic books and their associated reader applications and distribution platforms must provide accessible formats, navigable content structures and adjustable display options. EPUB 3 with accessibility features is the recommended standard.

Hardware Products with Digital Interface

Computers, smartphones, tablets, e-book readers, televisions and machines (ATMs, ticket machines) must also meet accessibility requirements. Requirements apply to both hardware operation and software interfaces.

Technical Requirements: EN 301 549 and WCAG

Under BFSG Section 3, the concrete requirements are set by the ordinance under the BFSG (BFSGV). They are technically specified by the standard EN 301 549, whose reference version to date, V3.2.1, references WCAG 2.1 Level AA for web content. WCAG is based on four principles known as POUR: Perceivable, Operable, Understandable and Robust. Each principle contains guidelines and measurable success criteria that determine a website's conformance.

Perceivable

Information and user interface components must be presentable in ways all users can perceive. Text alternatives for non-text content, captions for videos, sufficient color contrasts (at least 4.5:1 for body text), adjustable text sizes without loss of function and content understandable without color alone.

Operable

All functionality must be accessible via keyboard. Sufficient time for using content, no content that causes seizures, clear navigation mechanisms and orientation aids. New in WCAG 2.2: minimum target size (24x24 CSS pixels) and alternative controls for drag-and-drop interactions.

Understandable

Text must be readable and understandable. Web pages must behave predictably and offer consistent navigation. Input assistance prevents and corrects errors. Forms must provide labels, instructions and meaningful error messages with correction suggestions.

Robust

Content must be robust enough to be reliably interpreted by various user agents, including assistive technologies. Valid HTML, correct ARIA attributes and compatible implementation are crucial for interoperability with screen readers and other aids.

Abstract criteria become concrete corrections

The WCAG success criteria sound technical, but their violation is very real day-to-day: an order form a screen reader cannot read out, or a contrast that visually impaired customers cannot make out. Our remediation starts exactly there — in the source code and verifiable against WCAG 2.2 AA rather than with superficial widgets.

  • Missing form labels are correctly linked and marked
  • Color contrasts are raised to at least 4.5:1
  • Visible focus ring and logical keyboard order in the checkout
Before3 barriers
Email
Field without a label — screen reader reads nothing
Contrast 2.4:1 — below 4.5:1
Focus ring not visible
VS
AfterWCAG 2.2 AA
Email address
Label linked, required field marked
Contrast 7:1 — clearly passed
Visible focus ring, correct keyboard path

Exemptions and Transitional Provisions

The BFSG provides certain exemptions. The most important concerns micro-enterprises, i.e. companies with fewer than ten employees and annual turnover or balance sheet total of no more than two million euros (BFSG Section 2 No. 17). If they provide services, such as an online shop, the accessibility requirements do not apply to these services (BFSG Section 3 Para. 3). The exemption does not apply to products: a micro-enterprise that makes products covered by the BFSG available on the market, such as smartphones or e-book readers, remains obligated in that respect.

Further exemptions exist for fundamental alteration and disproportionate burden (BFSG Sections 16 and 17). An economic operator may invoke them if compliance with accessibility requirements would require a fundamental alteration of the essential characteristics of the product or service or constitute a disproportionate burden. The assessment must be documented and provided to the market surveillance authority upon request. In practice, these exemptions are likely to apply in few cases, as most accessibility requirements can be implemented with reasonable effort.

Products placed on the market before June 28, 2025 are not covered by the law (BFSG Section 1 Para. 2). Service providers may continue to use products they lawfully used before this date for their services until June 27, 2030; service contracts concluded before the deadline may continue unchanged until they expire, but no longer than June 27, 2030 (BFSG Section 38). However, new service contracts concluded after the deadline must immediately meet the requirements.

Enforcement and Consequences of Violations

Enforcement of the BFSG falls to the market surveillance of the federal states. The 16 states have set up a joint authority based in Magdeburg for this purpose, the Market Surveillance Office of the Federal States for the Accessibility of Products and Services (MLBF), which began its nationwide work in September 2025. In the event of violations, the authority can require the non-conformity to be eliminated, restrict or prohibit distribution of the affected product or provision of the service, and impose fines.

Fines can amount to up to 100,000 euros per BFSG Section 37. In addition, the law grants associations rights of their own: associations recognized under Section 15(3) of the Disability Equality Act (BGG) and qualified entities under the Injunctions Act (UKlaG) can apply to the market surveillance authority for proceedings against a company and file legal remedies against its decision (BFSG Sections 32 and 33). Such an application is possible independently of individual complaints.

Risk of Inaction

Beyond direct financial consequences, non-compliance with BFSG requirements carries significant reputational risk. Media reports about poor accessibility and proceedings initiated by associations can sustainably damage company image. Investing in accessibility is therefore not just a legal necessity but also a business decision.

Unsure whether your website meets the BFSG requirements?

A WCAG 2.2 audit shows where you stand in a reliable report — with a prioritized findings list and a fixed price from €2,480. The BFSG quick check for €490 delivers an initial assessment.

Request a Free Initial Consultation Call: +49 5123 9579000

Accessibility Statement: Mandatory Document Under BFSG

Under BFSG Section 14 in conjunction with Annex 3, service providers must provide information on how their service meets the accessibility requirements; this document is often called an accessibility statement. Where applicable, it covers a general description of the service in an accessible format, the explanations needed to understand how the service is provided, a description of how it meets the accessibility requirements, and the competent market surveillance authority. The information belongs in the general terms and conditions or another clearly perceivable place and must be accessible to the public, on websites typically via a footer link similar to the legal notice and privacy policy.

Details such as a rating as fully, partially or not conformant, known limitations or a feedback mechanism are not explicitly required by the BFSG, but they make the status traceable. We create the accessibility statement and update it individually on request; our compliance monitoring provides the measurement data for it.

BFSG and BITV 2.0: Differentiation

In addition to the BFSG, Germany has the Accessible Information Technology Regulation (BITV 2.0), based on the Disability Equality Act (BGG). BITV 2.0 of 2011 targets federal public bodies and requires accessible design of their websites and mobile applications. The technical requirements of both regulations largely overlap, as both rely on harmonized standards and thus on EN 301 549.

The key difference lies in the addressees: BITV 2.0 applies to the public sector, the BFSG to the private sector. Companies taking part in public procurement do not thereby become addressees of BITV 2.0 themselves, but they encounter accessibility requirements in the tender documents: for contracts at or above the EU thresholds, the specification for services intended for use by natural persons must take into account accessibility criteria for people with disabilities or design for all users, except in duly justified cases (Section 121(2) GWB). Technically, both paths share a common core: WCAG 2.2 AA covers the requirements of WCAG 2.1 AA, on which chapter 9 of EN 301 549 relies in its reference version to date; our WCAG audit is aligned with this. Under BITV 2.0, public bodies must additionally meet the other requirements of Table A.1, for example on user preferences, documentation and support; that is what the BITV assessment is for.

Checklist: Is Your Company Affected?

The following checklist helps with an initial assessment of whether your company falls under the BFSG. If uncertain, we recommend individual consultation, as the determination can be complex in individual cases.

  • You sell products or services online to consumers (B2C)
  • Your company is not a micro-enterprise: it has at least ten employees, or both annual turnover and balance sheet total exceed two million euros
  • Your website contains transaction functions (ordering, contract conclusion, booking)
  • You offer banking services, telecommunications or passenger transport
  • You distribute e-books or digital media products
  • You operate machines with digital interfaces (ATMs, ticket machines)

If at least one of these points applies to your company, you should have the accessibility of your digital offerings checked. The more points apply, the more extensive your obligations. Contact us for an individual assessment of your legal situation.

Practical Implementation: What Companies Should Do Now

Confrontation with the BFSG triggers uncertainty in many companies: where to start? Which measures have priority? We recommend a three-step approach.

  1. Baseline assessment

    A professional WCAG 2.2 audit captures the current state and identifies action areas. The result is a reliable data foundation rather than a gut feeling.

  2. Prioritized remediation

    We start with the most critical barriers in business-critical areas: for online shops the purchase process, for service websites the contact forms and booking processes.

  3. Sustainable anchoring

    Training for your team and automated monitoring help develop new content and features accessibly from the start.

Timeline planning should be realistic: how long audit, remediation and re-audit take depends on the scope and complexity of the website. This timeline cannot be arbitrarily shortened as thorough testing and careful implementation determine result quality. Companies whose offering does not yet meet the requirements should still act promptly, as the obligations have applied since June 28, 2025.

International Perspective: BFSG in European Comparison

The BFSG is the German implementation of an EU-wide directive. All 27 EU member states had to transpose the European Accessibility Act into national law by June 28, 2022 and apply it from June 28, 2025. The requirements are aligned EU-wide by the directive and technically rely on EN 301 549, so companies meeting German requirements generally also meet requirements in other EU markets. For internationally active companies this means: an investment in WCAG 2.2 AA conformance applies EU-wide and does not need to be conducted separately for each market. Only language-specific aspects like HTML language markup (lang attribute) and translation quality must be checked separately for each language area.

The Role of Market Surveillance in Practice

Enforcement of the BFSG lies with the joint market surveillance office of the federal states. It has the power to check websites and digital services for conformance and take action for violations. It checks services when there is a specific reason and also without one, by means of samples (BFSG Section 28). In addition, consumers, recognized associations and qualified entities can apply for proceedings against a company (BFSG Section 32). For companies this means: a review can be triggered both by a sample check and by an application.

A proactive approach is therefore sensible: companies that invest early in accessibility not only reduce their legal risk but can also publish a complete accessibility statement documenting their status and conformance efforts. We support you at every step of this process: from the initial audit through technical implementation to documentation and long-term monitoring. Contact us for an individual assessment of your situation.

In depth: enforcement, exemptions and limits

How the BFSG is enforced in practice and what role market surveillance, associations and competitors play is covered in the article on BFSG enforcement and legal risks. Whether you really are exempt as a microenterprise is clarified in the article on the microenterprise exemption. And anyone wishing to invoke disproportionate burden will find the requirements for the assessment in the article on section 17 BFSG.

Key Points on the BFSG Requirements

  • Since June 28, 2025, online shops and other digital services for consumers must be accessible; the technical benchmark is EN 301 549, and WCAG 2.2 AA is the recommended assessment standard
  • Violations can be penalized with fines up to €100,000 (BFSG Section 37); associations can also apply for market surveillance proceedings (BFSG Section 32)
  • Micro-enterprises with fewer than ten employees and no more than two million euros in annual turnover or balance sheet total are exempt for services such as online shops, but not for products
  • An accessibility statement under Section 14 is mandatory; retrofitted overlay widgets do not replace accessibility in the source code
  • The path to conformance: BFSG quick check for €490, WCAG 2.2 audit from €2,480, ongoing monitoring from €49 per month

Frequently Asked Questions About the BFSG

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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