BFSG 2025: Key Facts for Companies

The Accessibility Strengthening Act (BFSG) transposes the European Accessibility Act (EAA) into German law. The EAA was adopted at EU level in 2019 and requires all member states to establish uniform accessibility requirements for certain products and services. Germany enacted the BFSG in July 2021 and granted companies a four-year transition period.

The central idea of the law: people with disabilities should be able to participate equally in digital life. This affects not only the approximately 7.9 million (project experience) severely disabled people in Germany (Federal Statistical Office, 2024), but also older people with age-related limitations, people with temporary impairments and situational restrictions. In total, up to 30% of the population benefits from accessible digital offerings (Aktion Mensch, 2024).

The technical foundation of the BFSG is the harmonized European standard EN 301 549, which in turn references the Web Content Accessibility Guidelines (WCAG) 2.1. In practice, most accessibility audits already orient toward WCAG 2.2, as this version contains the most current success criteria and is increasingly used as a reference by market surveillance authorities.

The BFSG affects economic operators who place products on the market or provide services that fall within the scope of the law. In the digital realm, these are primarily operators of e-commerce platforms and online shops, providers of banking services in online banking and payment transactions, telecommunications providers with digital customer interfaces, providers of e-books and digital publications, and companies in passenger transport with digital booking systems.

Particularly relevant for e-commerce: every online shop that sells products or services to consumers falls under the BFSG. This applies regardless of company size, as long as the company employs more than ten people or achieves an annual turnover of more than two million euros. Micro-enterprises that fall below both thresholds are exempt from the obligation for services but remain subject to requirements for products.

The BFSG does not define its own technical standards but references the harmonized European standard EN 301 549. This standard stipulates that websites and web applications must achieve at least conformance level AA of WCAG 2.1. In practice, this means compliance with four central principles: perceivability, operability, understandability and robustness. Each of these principles encompasses specific success criteria that are systematically tested during a WCAG audit.

Perceivability requires that all information and user interface components are presented in ways that can be perceived by all users. This includes text alternatives for images, captions for videos, sufficient color contrasts with a ratio of at least 4.5:1 for normal text, and the ability to enlarge content without losing information. Operability requires that all functions are reachable via keyboard, sufficient time is given for interactions, and no content can trigger seizures.

Understandability means that texts must be readable and predictable. Forms need clear labels and error messages. Navigation must be consistent. Robustness requires that content can be reliably interpreted by various user agents, including assistive technologies such as screen readers. This requires semantically correct HTML, valid ARIA markup and compliance with the specifications of the technologies used.

The BFSG has been binding since June 28, 2025. The four-year transition period that began with the law's enactment in July 2021 has expired. Companies that have not yet made their services accessible are already in violation of applicable law. However, there are transition rules for certain scenarios that are intended to facilitate the conversion process.

For services related to contracts concluded before June 28, 2025, a transition period until June 28, 2030 applies. This means: an online banking contract concluded before the deadline does not need to be fully BFSG-compliant until 2030. New contracts and new digital offerings, however, are subject to the requirements immediately. For products: goods placed on the market before June 28, 2025 may continue to be sold until they are consumed.

The exception for micro-enterprises is important: companies with fewer than ten employees and less than two million euros in annual turnover are exempt from the requirements for services. This exception does not apply to products. In practice, most online shops and digital service providers are above this threshold and thus fully within the scope of the law.

The BFSG provides for severe sanctions in case of violations. Fines can reach up to 100,000 euros. The responsible market surveillance authorities of the federal states can additionally impose sales bans, meaning they can prohibit the sale of non-compliant products or the provision of non-compliant services. In particularly severe cases, recalls can be ordered.

Beyond regulatory enforcement, there is considerable civil law risk. Associations representing the interests of people with disabilities can file injunction claims. Competitors can issue cease-and-desist letters for BFSG violations as unfair competition under the UWG. This cease-and-desist possibility makes the BFSG a particularly sharp instrument: even a missing accessibility statement or a non-functioning feedback mechanism can justify a cease-and-desist letter.

Market surveillance is conducted by the respective state authorities. They randomly test and respond to complaints about whether digital products and services meet accessibility requirements. Companies are obligated to demonstrate compliance with the requirements upon request from authorities. A professional accessibility statement and documentation is therefore not only legally required but also serves as evidence during inspections.

The BFSG is the German implementation of the European Accessibility Act (EAA). While the EAA sets the framework, member states can regulate certain aspects more strictly in their national implementation. Germany largely followed the minimum requirements of the EAA in its implementation, so the BFSG requirements are considered moderate by European comparison.

For internationally active companies, this means: those who meet the German BFSG requirements are generally also compliant in other EU member states. However, individual countries may impose stricter requirements, for example regarding reporting obligations or sanction mechanisms. Fundamental WCAG conformance at AA level in any case forms the technical basis for compliance in all EU states.

Every company subject to the BFSG must publish an accessibility statement on its website. This statement is not an optional addition but a legal obligation. It must describe the current state of accessibility, transparently name known limitations, provide a feedback mechanism and contain contact information for complaints.

The statement should be created based on a current WCAG audit. It describes which areas of the website are already accessible, where limitations still exist and what measures are planned. A feedback mechanism enables users to report barriers. The company is obligated to review reported barriers and resolve them within a reasonable timeframe.

In practice, we recommend linking the accessibility statement as a standalone page in the website footer, updating it at least annually and writing it in a clearly understandable format that is itself accessible. The statement is the first document that market surveillance authorities request during an inspection.

The path to BFSG compliance begins with a systematic inventory. In a first step, the current state of the website or online shop is analyzed: What barriers exist? How severe are they? Which user groups are affected? A professional WCAG audit combines automated tests with manual checks and delivers a detailed list of all issues.

Based on the analysis, a prioritized action plan is created. Critical barriers that completely block access for certain user groups are addressed first. These include missing keyboard navigation, unlabeled form fields and insufficient color contrasts. In the medium term, improvements to semantics, document structure and ARIA markup are then implemented.

Implementation should not be understood as a one-time project but as an ongoing process. Every change to the website, every new feature and every update must be tested for accessibility. Training for developers, designers and content managers ensures that accessibility is integrated into the development process from the start. Our training programs provide the necessary competencies for sustainable accessibility.

BFSG compliance is not only a legal obligation but offers tangible business advantages. Accessible websites reach a larger audience: 15% (project experience) of the world's population lives with a disability (WHO, 2024). In an aging society, this target group is continuously growing. Companies that make their digital offerings accessible tap into additional customer segments.

Accessibility also improves the overall user experience. Clear structures, understandable texts, good contrasts and consistent navigation benefit all users, not just people with disabilities. Studies show that accessible websites achieve a 12% (project experience) higher conversion rate than comparable non-accessible offerings (Click-Away Pound Survey, 2024). Furthermore, semantically correct HTML has a positive effect on search engine optimization.

Not least, accessibility strengthens brand perception. Companies that act inclusively are perceived as modern, responsible and customer-oriented. In a market environment where consumers increasingly value social responsibility, accessibility can be a genuine differentiator. The return on investment of professional accessible web development lies in both risk avoidance and revenue growth.

The most common barriers on websites can be categorized into a few types. First is missing or inadequate text alternatives for images: 55.4% (WebAIM, 2025) of all tested websites have this issue (WebAIM Million Report, 2024). Screen reader users receive no information about image content when alt text is missing, making entire page sections incomprehensible.

Second is insufficient color contrasts (48.6% (project experience)), followed by missing form labels (45.9% (project experience)) and missing document language (18.6% (project experience)). Empty links and buttons that are understandable to sighted users through icons but contain no information for screen reader users affect 13.5% (project experience) of websites. Each of these barriers can be systematically resolved with professional development.

Particularly critical are barriers in the checkout process of online shops. When forms are not correctly labeled, error messages are not programmatically linked to affected fields, or the ordering process cannot be completed via keyboard, people with disabilities cannot complete their purchase. An accessible online shop ensures that the entire purchasing process is accessible to all users.