In short and in plain language
This post is about your customer support. That means hotline, email, form or chat. These services have their own accessibility rules.
Your team must be able to answer questions about accessibility. One question is whether the service works with tools like screen readers.
The contact channel itself should be accessible. A phone line alone is usually not enough. You also need a way to write.
Very small firms can be exempt for services. Keep a ready answer at hand. Decide who passes on questions.
We are glad to check your form, chat and help pages. You check the phone line and mailbox yourself.
In the fourth quarter, online shops, booking portals and customer accounts see a rise in enquiries: delivery times, returns, forgotten log-in details. Anyone who offers a hotline, a contact form or a chat for this is usually running a support service within the meaning of the ordinance to the German Accessibility Strengthening Act. For such services, § 12 No. 4 BFSGV contains a separate duty that has applied since 28 June 2025 (BFSGV, § 22). It easily slips out of view because it does not live in the code but in the organisation: support must be able to provide information on the accessibility of the service and on its compatibility with assistive technologies, and it must do so through accessible means of communication. This article breaks the provision down into its building blocks, shows which channels are affected and who is exempt, translates the duty into checks per channel and into an answer module, and separates what a website audit can cover from what you need to settle within your team.
Key takeaways
- § 12 No. 4 BFSGV has applied since 28 June 2025 (BFSGV, § 22): anyone offering help desks, call centres, technical support, relay or training services must be able to provide accessibility information there.
- Every contact channel has two checks: can the team provide information on accessibility and on compatibility with assistive technologies, and is the channel itself accessible or does it reliably refer to one that is?
- A voice-only hotline is usually not enough: for auditory modes the ordinance requires at least one mode without hearing, for vocal input one without voice (BFSGV, § 21 para. 2 and 3). A text channel belongs next to it.
- Microenterprises with fewer than ten employees and no more than 2 million euros in turnover or balance sheet total are exempt for services (BFSG, § 3 para. 3), but not for products.
- A checked answer module derived from the accessibility statement, a named referral point and dated records secure the information duty towards market surveillance (BFSG, § 14 para. 5).
- A non-conforming service can lead to a fine of up to 100,000 euros (BFSG, § 37). A WCAG audit covers forms, chat and help pages; the hotline and the mailbox you check yourself.
What § 12 No. 4 BFSGV actually says
§ 12 BFSGV sets out the general requirements for all services covered by the German Accessibility Strengthening Act. Numbers 1 to 3 concern the products used, the information on how the service works and the design of websites and apps. Number 4 is the only one aimed at customer support. It requires that, where support services such as help desks, call centres, technical support, relay services and training services are available, they provide information on the accessibility of the service and its compatibility with assistive technologies through accessible means of communication (BFSGV, § 12 No. 4).
This single sentence contains four building blocks that can be checked separately:
- Trigger: the duty only applies where a support service is available. The ordinance does not force anyone to set up a hotline. But anyone who runs one has to organise it the way number 4 requires.
- Range of services: the provision names five types explicitly, namely help desks, call centres, technical support, relay services and training services (BFSGV, § 12 No. 4). The words "such as" make this a list of examples. A support mailbox, a contact form with a team behind it or a live chat usually performs the same function as a help desk.
- Content: what is required is information on the accessibility of the service and on its compatibility with assistive technologies, for example screen readers, magnification software, braille displays or voice control.
- Route: this information has to arrive through accessible means of communication. A channel that part of the customer base cannot use does not meet this condition on its own.
Manufacturers face the same duty with regard to their products. Where support services are available, they must provide information on the accessibility of the product and its compatibility with assistive technologies through accessible means of communication (BFSGV, § 11). A retailer selling devices covered by the Act, such as tablets or e-readers, under its own brand (BFSG, § 1 para. 2) may therefore be covered by both provisions at once: § 11 for the device, § 12 No. 4 for the online shop as a service.
The requirement comes from the European Accessibility Act. Annex I, Section III, point (d) of the Directive phrases it almost identically for services (Directive (EU) 2019/882, Annex I). Comparing language versions reveals two differences in the German text: it speaks of "Einweisungsdienste" (instruction services) instead of training services, and it relates compatibility to "the product" even though the section governs services. The BFSGV relates it to the service in § 12 No. 4. Annex II of the Directive, which provides implementation examples for many requirements, offers none for support services in the services section; the German version simply reads "Kein Beispiel angegeben", no example given (Directive (EU) 2019/882, Annex II). Companies therefore have to work out for themselves how to meet the duty in day-to-day operations.
Who has to comply and who is exempt
The BFSGV applies to the services covered by the German Accessibility Strengthening Act: telecommunications services, certain elements of passenger transport services, consumer banking services, e-books and e-commerce services, in each case where they are provided to consumers after 28 June 2025 (BFSG, § 1 para. 3). For most companies the last group is decisive: online shops, booking flows and all websites and apps through which consumers can conclude a contract. Whether your offering is included is explained in our overview of the BFSG requirements.
Microenterprises that offer or provide services are exempt (BFSG, § 3 para. 3). A microenterprise is a company that employs fewer than ten people and either has an annual turnover of no more than 2 million euros or an annual balance sheet total of no more than 2 million euros (BFSG, § 2 No. 17). The exemption applies only to services, not to products. A small manufacturer placing products covered by the Act, such as computers or e-readers, on the market remains bound by § 11 BFSGV for their support, even if its online shop is exempt as a service. The details are covered in our article on the microenterprise exemption.
Important for anyone who outsources customer support: the service provider may only offer or provide its service if it meets the accessibility requirements of the ordinance (BFSG, § 14 para. 1). An external call centre or an embedded chat tool does not change this responsibility. How third-party components are attributed to your own service is shown in the article on third-party widgets. The clauses that belong in the contract with the provider are set out in the article on accessibility in contracts and acceptance.
No duty to run a hotline, but duties for every hotline
Two checks per channel: information and access
The wording gives rise to two separate questions for every contact channel. The first concerns content: can the team answering on this channel explain how accessible the service is and which assistive technologies it works with? The second concerns access: is the channel itself designed so that people with different impairments can use it, or does it at least refer reliably to a channel that can?
The distinction matters because the provision is narrower than it is often read. § 12 No. 4 does not require every complaint to be handled accessibly through every channel. It requires the information on accessibility to arrive through accessible means of communication. The digital contact channels on your website are, however, covered by number 3 anyway: websites, including the related online applications, must be perceivable, operable, understandable and robust (BFSGV, § 12 No. 3). A contact form or an embedded chat window therefore has to be accessible simply because it is part of the website.
The European standard EN 301 549 was considerably more specific in its version V3.2.1 from 2021. Its clause 12.2 deals with support services in three requirements. Under 12.2.2, they provide information on the accessibility and compatibility features mentioned in the product documentation (EN 301 549 V3.2.1, 12.2.2). Under 12.2.3, they accommodate the communication needs of people with disabilities "either directly or through a referral point" (EN 301 549 V3.2.1, 12.2.3). Under 12.2.4, documentation issued by support is available in at least one accessible electronic format (EN 301 549 V3.2.1, 12.2.4). Version V4.1.1, published in September 2026, no longer contains these three subclauses. It states that its requirement for digital information about services also covers support services (EN 301 549 V4.1.1, 12.2), and its Annex ZB maps the Directive's requirement on support services to clauses 4.2, 11.5.2, 12.3 and 13.1 (EN 301 549 V4.1.1, Annex ZB). The three old requirements remain useful as a working checklist for support.
The question every team should ask
Who depends on which channel
At the end of 2025, a little over 7.8 million people with a severe disability lived in Germany, which is 9.4 percent of the population (Destatis, 2026). By type of the most severe disability, 4 percent of them were blind or visually impaired (Destatis, 2026), and another 4 percent had hearing loss, balance or speech disorders (Destatis, 2026). Intellectual or mental disabilities affected 16 percent of severely disabled people (Destatis, 2026). A good third, namely 34 percent, were 75 or older (Destatis, 2026).
These statistics only cover people with an officially assessed degree of disability of at least 50. Anyone who hears poorly but has no severe disability card does not appear in them. A figure from the World Health Organization shows how large this group can be: among people over 60, more than a quarter worldwide, that is over 25 percent, have disabling hearing loss (WHO, 2026). As customers get older, the share of those for whom a phone call becomes difficult grows.
According to the German Federation of the Deaf, around 80,000 deaf people live in Germany (Deutscher Gehörlosen-Bund). For them a phone call is not a means of communication. A video call helps only to a limited extent, because under optimal conditions only about 30 percent of speech can be read from the lips (Deutscher Gehörlosen-Bund). Blind and visually impaired people, in turn, often fail at picture puzzles in contact forms, at replies sent as scanned images and at chat windows that cannot be operated by keyboard.
The ordinance does not define explicitly what an accessible means of communication is. Guidance comes from the functional performance criteria in § 21 BFSGV. They are the benchmark for functions for which §§ 4 to 19 set no specific requirement (BFSGV, § 20 para. 1). Where a service offers auditory modes of operation, at least one mode must be available that does not require hearing (BFSGV, § 21 para. 2). Where vocal input is required, there must be at least one mode without vocal input (BFSGV, § 21 para. 3). For people with cognitive impairments, the ordinance requires at least one mode of operation that makes use easier and simpler (BFSGV, § 21 para. 7). Applied to support, this means that a voice-only channel needs an equivalent text channel next to it, and answers must be phrased clearly.
The contact channels one by one
Phone and hotline. For many people a hotline is a particularly fast route, but not for deaf and severely hard-of-hearing people or people with speech disorders. An equivalent text channel therefore belongs next to it, listed alongside the phone number and answered similarly fast. Also expect relayed calls: providers of voice communication services must offer relay services for deaf and hearing-impaired end users that are available at all times (TKG, § 51 para. 4). On such a call, the relay service converts between communication modes, using human assistance, automated translation or a hybrid of both (EN 301 549 V4.1.1, 13.1.1). A team that treats such calls as sales calls or puts them under time pressure cuts off exactly the people the route is meant for. Voice menus with short time windows for pressing keys are a further hurdle.
Email. For many blind and deaf people, email is a particularly convenient route because screen readers and braille displays handle it well and no real-time exchange is needed. Barriers arise on the reply side: scanned letters as image attachments, tables as images, texts full of internal abbreviations. Answers belong in the body of the message, attachments in an accessible format. Under EN 301 549, digital information about a service, explicitly including support services, has to meet the requirements for web content or documents (EN 301 549 V4.1.1, 12.2). How a PDF meets this requirement is described on our page on accessible PDF.
Contact form. Forms fail at the familiar points: fields without programmatically associated labels, error messages shown only in red, picture puzzles without an alternative, sessions that expire while someone is typing. Because the form is part of the website, the requirements for websites apply directly (BFSGV, § 12 No. 3). What makes a form accessible in detail is covered in our article on labels and validation. For the information duty there is one small addition: offer a separate "Accessibility" option when users choose their topic. That way the question reaches the right team and can be evaluated later.
Chat and chatbot. Chat windows are often third-party scripts with their own barriers: the window cannot be opened by keyboard, new messages are not announced to the screen reader, the session ends after a short time without warning. How a chat window announces new messages and manages focus is covered in our article on accessible AI chatbots. For support there is one further point: a bot that does not understand questions about accessibility must be able to hand over to a person or to another accessible channel.
Training, webinars and tutorial videos. Training services are named explicitly in the list (BFSGV, § 12 No. 4). Anyone who introduces customers to software, a customer account or a device by webinar or video needs captions: WCAG requires them at level A for all prerecorded audio content in synchronised media (W3C, WCAG 2.2, SC 1.2.2). Accompanying materials belong in an accessible format. For deaf people whose first language is German Sign Language, sign language videos can be useful; how to embed them is shown in our article on DGS videos on the website.
Help centre and frequently asked questions. Self-help pages are not a support service in the narrow sense, but they are often the first place where someone looks for accessibility information. WCAG 2.2 has a dedicated criterion for this: where help mechanisms such as contact details, a contact form, self-help or an automated contact option are repeated on several pages, they appear there in the same order (W3C, WCAG 2.2, SC 3.2.6). Placing the contact link in the header of one page and the footer of the next sends people who are searching round in circles.
| Contact channel | Typical barrier | Accessible route | Basis |
|---|---|---|---|
| Phone, hotline | voice only, voice menu with short time window | equivalent text channel, accept relayed calls | BFSGV § 21 para. 2 and 3, TKG § 51 para. 4 |
| reply as scan or image, internal abbreviations | reply in the message body, accessible attachments | EN 301 549 V4.1.1, 12.2 | |
| Contact form | missing labels, picture puzzles, timeouts | labelled fields, errors in text, alternative to the puzzle | BFSGV § 12 No. 3 |
| Chat, chatbot | not keyboard operable, new messages silent | keyboard operation, announced messages, handover to a person | BFSGV § 12 No. 3 |
| Training, video | no captions, materials as images | captions, materials in an accessible format | WCAG 2.2, SC 1.2.2 |
| Help centre, FAQ | help in changing places | help in the same order on all pages | WCAG 2.2, SC 3.2.6 |
What belongs in the answer module
In practice the information duty depends less on will than on knowledge. Support staff know the return deadlines by heart, but not the screen reader support of the customer account. The remedy is a checked answer module kept ready in every channel. It is based on the information you have to prepare under the Act anyway: a description of how the service meets the accessibility requirements and the name of the competent market surveillance authority (BFSG, Annex 3). This information is usually found in the accessibility statement.
- What works: keyboard operation, magnification, screen reader support, captions, texts in easy-to-read language, where available.
- What it was tested with: which assistive technologies the key processes have been checked with, for example screen readers on desktop and smartphone.
- What does not work yet: known limitations together with the alternative that applies until they are fixed.
- Where it is documented: the link to the accessibility statement and to the way barriers can be reported.
- Who is responsible: the market surveillance authority that consumers can turn to.
- What happens next: another contact channel if the chosen one does not suit, and the reply in the channel of the enquiry.
Subject: Your question about accessibility
Hello,
thank you for your question. [Name of the offering] can be operated
by keyboard and supports screen readers on desktop and smartphone.
Text can be enlarged without loss of content.
Known limitation: [location]
Alternative until it is fixed: [route]
You will find all details in our accessibility statement:
[link to the accessibility statement]
Competent market surveillance authority: [as stated in the statement]
You can also reach us via [other contact channels].
We reply through the channel you have chosen.The module does not replace testing. It is only as accurate as the statement it comes from, and it goes out of date with every major update of the website. Decide who adapts it after a change to the shop, app or customer account. How to receive and evaluate feedback about barriers is described in the article on the feedback mechanism of the accessibility statement. For the wording, the rules of easy-to-read language help: short sentences, one idea per sentence, no internal abbreviations.
Organisation: referral, briefing, records
Version V3.2.1 of EN 301 549 explicitly allowed a support service to meet communication needs through a point to which it refers (EN 301 549 V3.2.1, 12.2.3). That is the realistic route for smaller teams: not everyone on the hotline needs to answer every accessibility question, but everyone needs to know where to refer it, and that point must be reachable. Record the referral in writing, with the name of the point, the channel and the usual response time.
- Inventory: list all contact channels, including those that only appear in order confirmations, apps or invoices.
- Responsibility: name a point that answers accessibility questions or refers them on in a binding way.
- Answer module: derive it from the accessibility statement, approve it and store it in all channels.
- Briefing: familiarise the team with relayed calls, text channels and the module.
- Tagging: mark accessibility enquiries in the ticket system so that they can be evaluated.
- Records: file the process, the module and changes with a date.
The last point has a legal reason. On a reasoned request, the service provider must give the market surveillance authority all information needed to demonstrate conformity (BFSG, § 14 para. 5). Since 26 September 2025, the competent body has been the joint market surveillance agency of the federal states (MLBF) in Magdeburg (Bundesfachstelle Barrierefreiheit). It monitors services by random sampling (Bundesfachstelle Barrierefreiheit). How such an inspection runs is described in our article on BFSG market surveillance.
Anyone offering a service that does not meet the requirements of the ordinance commits an administrative offence, which can be punished with a fine of up to 100,000 euros (BFSG, § 37). For information to the authority that is not given, not correct or not complete, the range is up to 10,000 euros (BFSG, § 37). Before a fine, the authority usually first requests that conformity be established (Bundesfachstelle Barrierefreiheit). Anyone who can document the process and the answer module can respond to such a request faster.
Outsourcing does not shift the duty
What an audit covers and what you settle yourself
Part of the duty is technical and can be measured, part of it is organisational. In a WCAG audit we test the digital contact channels of your website like any other view: the contact form including its error messages, an embedded chat window, help and FAQ pages, the accessibility statement and whether repeated help appears in the same order on every page. This includes keyboard operation and screen reader output, not just an automated scan.
What no website audit can do: call the hotline, measure response times in the mailbox, replace briefing the team. You check these parts yourself with the list in this article, ideally before the Christmas season and then at a fixed interval. For teams that write help pages, frequently asked questions and answer texts, the content and editorial module of our training courses is the right next step: clear language, accessible PDF and a lasting review routine.
Accessibility does not end at the checkout. Anyone who has a question must be able to ask it and receive an answer they can perceive.
Sources and legal basis
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