In short and in plain language
This is about long-distance buses, trains, ships and flights. These trips have rules on accessibility. The rules cover the website, the app, the ticket and the travel news.
A rule book lists four kinds of facts. People should be able to read how easy the bus, station or ship is to use. They should also learn where they get help. They should be able to read how to book. On top of that come news on delays and on service at the stop. One example is a broken elevator.
City buses, trams and local trains are almost fully left out. There, only the ticket machines count. Ferries are not left out.
Very small firms do not have to follow these rules for services. Check if this is true for you. Write down what you found.
Anyone selling long-distance bus routes, intercity trains, ferries or flights to consumers usually falls under the German Accessibility Strengthening Act with their digital offering, namely for services provided after 28 June 2025 (BFSG, § 1 para. 3). Most operators know the part that requires the website, app and ticket purchase to be accessible. Less well known is § 15 of the ordinance to the BFSG. It additionally requires certain content to be available at all: information on the accessibility of vehicles, infrastructure and buildings including assistance, information on ticketing systems, real-time travel information and service information such as broken elevators (BFSGV, § 15). This article explains which transport services are covered, why ferries are treated differently from regional trains, where coach tours in occasional service remain an open question and how to test the four information duties on your website.
Key takeaways
- For air, bus, rail and waterborne passenger transport services, the BFSG covers five elements: websites, mobile services, e-tickets, real-time travel information and interactive terminals (BFSG, § 1 para. 3 no. 2).
- § 15 BFSGV requires four types of information: accessibility of vehicles, infrastructure and buildings including assistance, ticketing systems, real-time travel information and service information such as broken elevators (BFSGV, § 15).
- Urban, suburban and regional transport only has to meet element e, the terminals. The definition lists rail, bus, metro, tram and trolleybus but no ships: according to the wording, ferries do not fall under this exemption (BFSG, § 2 no. 32).
- Scheduled buses are covered via Art. 2(1) and (2) of Regulation (EU) No 181/2011; the BFSG does not refer to occasional services under Art. 2(3) (BFSG, § 2 no. 28). Whether coach tours are therefore entirely outside the scope has not been settled.
- Microenterprises with fewer than ten employees and no more than EUR 2 million annual turnover or balance sheet total are exempt for services (BFSG, § 3 para. 3). For violations by other operators, fines of up to EUR 100,000 are possible (BFSG, § 37 para. 2).
- Check each of the four types of information where passengers look for it: website, app, booking flow, e-ticket and confirmation email, each by keyboard, with a screen reader and at 200 percent text size (W3C, WCAG 2.2, SC 1.4.4).
What the BFSG covers for bus, rail, ship and air
The act does not treat passenger transport services as covered across the board, only certain elements of them. It applies to the following elements of air, bus, rail and waterborne passenger transport services (BFSG, § 1 para. 3 no. 2):
- a) websites of the carrier, meaning journey planner, booking flow, help pages and customer account.
- b) mobile device-based services, including mobile applications, such as the booking app or a mobile travel companion.
- c) electronic tickets and electronic ticketing services, from the ticket as a PDF to the travel pass in the app.
- d) the delivery of transport service information, including real-time travel information; for information screens this only applies to interactive screens in the EU (BFSG, § 1 para. 3 no. 2 letter d).
- e) interactive self-service terminals in the EU, except terminals installed as integrated parts of vehicles, aircraft, ships or rolling stock.
The terms are defined in the act. Electronic tickets are systems in which a travel entitlement is not printed on paper but stored electronically on a physical travel card or another device (BFSG, § 2 no. 39). Electronic ticketing services are systems through which travel entitlements are purchased online and transmitted to the buyer electronically so that they can be printed or displayed on a device during the journey (BFSG, § 2 no. 40). This means the booking flow falls under the act just as much as the ticket that ends up in the inbox or the app.
The statistics show how important this channel has become: 25.2 percent of people aged 16 to 74 in Germany bought a transport service online from a transport company in the three months before the survey in 2025 (Eurostat). In 2022 the share was 10.7 percent (Eurostat). For passengers with disabilities, the digital route is often not just more convenient but the only one that works without help from others, provided it is accessible.
The terminals under letter e are covered in detail in the article on self-service terminals and vending machines. This article focuses on letters a to d and on the content the ordinance additionally requires. Our overview of the BFSG requirements summarizes the general requirements for websites and apps.
What counts as a passenger transport service
The BFSG does not decide on its own which bus, train or ship is meant. It refers to the EU regulations on passenger rights. That is intentional: the scope with regard to air, bus, rail and waterborne passenger transport services should be determined on the basis of the existing sectoral legislation on passenger rights (Directive (EU) 2019/882, recital 34). Anyone who wants to know whether their offering is covered therefore has to read the relevant passenger rights regulation.
Bus: scheduled services under Regulation 181/2011
Passenger transport services by bus are the services covered by Article 2(1) and (2) of Regulation (EU) No 181/2011 (BFSG, § 2 no. 28). Paragraph 1 covers regular services for non-specified categories of passengers where the scheduled distance of the service is 250 km or more (Regulation (EU) No 181/2011, Art. 2(1)). Paragraph 2 concerns the same regular services with a scheduled distance shorter than 250 km (Regulation (EU) No 181/2011, Art. 2(2)). For the BFSG, a scheduled bus therefore counts regardless of route length, as long as it does not fall under the exemption for urban, suburban or regional transport.
Open question: coaches in occasional service
Rail: journeys under rail passenger rights
Passenger transport services by rail are all rail journeys and services within the meaning of Article 2(1) of Regulation (EC) No 1371/2007, except the services referred to in Article 2(2) (BFSG, § 2 no. 29). That regulation was repealed with effect from 7 June 2023 (Regulation (EU) 2021/782, Art. 40). References to it are to be read as references to the recast (Regulation (EU) 2021/782, Art. 40). For a long-distance rail operator this changes little in practice: it is covered with all five elements. Regional trains, on the other hand, fall under the regional transport exemption described further below.
Waterborne transport: ferries yes, excursions no
Passenger transport services by ship are all services for passengers within the meaning of Article 2(1) of Regulation (EU) No 1177/2010, except the services listed in Article 2(2) (BFSG, § 2 no. 30). Paragraph 1 covers, among others, passengers traveling on passenger services where the port of embarkation is situated in a Member State (Regulation (EU) No 1177/2010, Art. 2(1)). A passenger service means a commercial passenger transport service by sea or inland waterways operated according to a published timetable (Regulation (EU) No 1177/2010, Art. 3(f)).
The exceptions in paragraph 2 are decisive. Not covered are passengers on ships certified to carry up to twelve passengers (Regulation (EU) No 1177/2010, Art. 2(2)(a)), on ships with a crew responsible for operating the ship of no more than three persons or a total distance of less than 500 m one way (Regulation (EU) No 1177/2010, Art. 2(2)(b)), and passengers on excursion and sightseeing tours other than cruises (Regulation (EU) No 1177/2010, Art. 2(2)(c)). In addition, there are ships not propelled by mechanical means and historical passenger ships certified to carry up to 36 passengers (Regulation (EU) No 1177/2010, Art. 2(2)(d)). A harbor cruise or a sightseeing trip on a lake is therefore usually not a waterborne passenger transport service. Its online booking can still fall under the act as an e-commerce service.
Air: commercial passenger flights
For air transport, the BFSG refers to commercial passenger air services under Article 2(l) of Regulation (EC) No 1107/2006 when an airport in a Member State is used for departure, arrival or transit (BFSG, § 2 no. 27). This means scheduled and non-scheduled flights offered to the general public for valuable consideration, on their own or as part of a package (Regulation (EC) No 1107/2006, Art. 2(l)). There is no exemption for regional flights; the definition of regional transport only lists land-based modes.
| Mode | Covered by the BFSG | Not or only partly covered | Legal basis |
|---|---|---|---|
| Bus | Scheduled services under Art. 2(1) and (2) of the bus regulation, also below 250 km | Urban, suburban and regional buses only with terminals; occasional services open | BFSG § 2 no. 28, 31, 32; Regulation (EU) No 181/2011 |
| Rail | Rail journeys under rail passenger rights | Urban, suburban and regional services only with terminals | BFSG § 2 no. 29; Regulation (EU) 2021/782 |
| Ship, ferry | Timetabled passenger services, cruises with port of embarkation in the EU | Excursions, ships for up to twelve passengers, routes below 500 m | BFSG § 2 no. 30; Regulation (EU) No 1177/2010 |
| Air | Scheduled and non-scheduled flights with an airport in the EU | No exemption for regional flights | BFSG § 2 no. 27; Regulation (EC) No 1107/2006 |
| Metro, tram, trolleybus | Only interactive self-service terminals | Website, app, e-ticket, real-time information | BFSG § 1 para. 3 no. 2, § 2 no. 31, 32 |
The four information duties under § 15 BFSGV
Besides the general requirements for services, the ordinance contains additional duties for individual types of service. For passenger transport they are set out in § 15. For air, bus, rail and waterborne passenger transport services, except urban, suburban and regional transport services, the provision of four types of information must be ensured (BFSGV, § 15). The provision implements Annex I Section IV of Directive (EU) 2019/882, which lists the same types of information (Directive (EU) 2019/882, Annex I Section IV).
The difference from the other requirements is fundamental. Most rules describe how something must be designed: perceivable, operable, understandable and robust. § 15 describes that certain content must be present. A technically well-built website that says nothing about the accessibility of the vehicles does not meet the provision. Conversely, even good information is of little use if it sits in a format that a screen reader cannot read.
§ 15 no. 1: accessibility of vehicles, infrastructure and buildings
Required is information on the accessibility of vehicles, the surrounding infrastructure and buildings and on assistance for persons with disabilities (BFSGV, § 15 no. 1). For a long-distance bus operator this means, for example: is there a lift or a ramp, how many wheelchair spaces does the bus have, can the onboard toilet be used, are stops and bus stations reachable without steps. For a shipping company it is about gangways, elevators on board, accessible cabins and access at the terminal.
The passenger rights regulations often already require access conditions. In bus transport, carriers and terminal managing bodies make them publicly available physically or on the internet, in accessible formats on request (Regulation (EU) No 181/2011, Art. 11(2)). This only applies to routes with a scheduled distance of 250 km or more: for shorter routes, the bus regulation does not list Article 11 among the applicable provisions (Regulation (EU) No 181/2011, Art. 2(2)). In waterborne transport, all relevant information, including online booking and information, must be available in formats appropriate and accessible to disabled persons and persons with reduced mobility (Regulation (EU) No 1177/2010, Art. 9(4)). Anyone already publishing these access conditions has a good basis for no. 1. They then belong on the website as an easy-to-find HTML page rather than as a scanned PDF in the download section.
Assistance includes the question of how passengers request help. The deadlines differ by mode: in bus transport on routes of 250 km or more the need for assistance must be notified at least 36 hours in advance (Regulation (EU) No 181/2011, Art. 14(1)), in waterborne transport at least 48 hours in advance (Regulation (EU) No 1177/2010, Art. 11(1)), in rail transport at least 24 hours in advance (Regulation (EU) 2021/782, Art. 24) and in air transport at least 48 hours before the published departure time (Regulation (EC) No 1107/2006, Art. 7(1)). A page that states the deadline, channel and process of the request and whose request form can be completed accessibly covers a large part of no. 1.
§ 15 no. 2: information on smart ticketing systems
The second duty concerns information on smart ticketing systems, such as the electronic reservation and booking of tickets (BFSGV, § 15 no. 2). There is a notable difference between the language versions of the directive: the German version speaks of smart ticket terminals (Directive (EU) 2019/882, German version, Annex I Section IV), the English one of smart ticketing (Directive (EU) 2019/882, Annex I Section IV). With the word ticketing systems, the German ordinance follows the broader reading. What is meant is therefore not only the machine but the entire system of booking, reservation and ticket.
In practice this means: explain how booking works, which ticket types exist, how to reserve a wheelchair space or a seat for a companion and how to show the e-ticket at inspection. This explanation must itself be accessible, and so must the process it describes. The article accessible ticket shop shows how a ticket shop with seat map and companion seat becomes accessible; many of its patterns carry over to seat reservations on buses, trains and ferries.
§ 15 no. 3: real-time travel information
No. 3 requires real-time travel information such as timetables, information on traffic disruptions, connections and onward travel with other modes of transport (BFSGV, § 15 no. 3). Real-time data is technically demanding because it changes while someone is reading the page. A new delay that only lights up in color in the timetable does not reach blind passengers and may not reach people with color vision deficiency either.
Two WCAG success criteria help here. Status messages must be programmatically determinable so that assistive technologies can present them without receiving focus (W3C, WCAG 2.2, SC 4.1.3). And color must not be the only visual means of conveying information (W3C, WCAG 2.2, SC 1.4.1). For a departure board this means: delay and cancellation appear as text next to the time, relevant changes are announced via a status region but not the entire table on every refresh, and the board remains a real table with column headers.
<!-- Create the status region once in the page header -->
<div id="travel-status" role="status" aria-live="polite"></div>
<!-- Departure row: change as text, not just as color -->
<tr>
<th scope="row">14:32</th>
<td>to Hamburg ZOB</td>
<td><span class="delay">about 15 minutes late</span>, reason: traffic jam</td>
</tr>A script writes only changes that affect the selected stop into the status region, for example “Departure 14:32 to Hamburg ZOB: about 15 minutes late”. That way the person hears the message they need without the whole table being read out on every refresh. Interactive displays at stops follow the same logic; according to the wording, letter d does not apply to plain departure monitors that cannot be operated.
§ 15 no. 4: additional service information
The fourth duty concerns additional service information, such as service staff on duty at the station, broken elevators or services that are temporarily unavailable (BFSGV, § 15 no. 4). For wheelchair users, a broken elevator decides whether a journey is possible at all. For blind travelers it matters whether staff can be approached at the stop. Such notices belong where they are seen before the journey: in the journey planner, in the booking confirmation and in the app notification.
The examples in the ordinance come from station operations but can be applied accordingly to bus stations, ferry terminals and airports. Operators that do not run their own infrastructure but serve third-party stops should define where they get the information from and how up to date it is. If a piece of information is missing, a clear notice is better than silence: “We have no information on the elevator at this stop. Please ask us before you travel.”
One place for all four types of information
How § 15 interacts with the general requirements
§ 15 does not stand alone. The general requirements of § 12 BFSGV apply to every service first. Websites, online applications and mobile apps must be designed to be perceivable, operable, understandable and robust (BFSGV, § 12 no. 3). Information on how the service works must, among other things, be provided via more than one sensory channel (BFSGV, § 12 no. 2 letter a), and the information content must be available in text formats from which users can generate alternative formats (BFSGV, § 12 no. 2 letter e).
For the four types of information under § 15 this means: they do not just have to exist, they must be provided so that people with visual, hearing, motor or cognitive impairments can find and understand them. A route map as an image without a text alternative, a video on boarding assistance without captions or a PDF with access conditions without a text layer only meets the content duty on paper. Existing documents can be prepared as accessible PDFs if an HTML page is not an option.
If the operator offers a hotline, a contact form or a chat, § 12 no. 4 BFSGV applies as well: these support services must provide information on the accessibility of the service through accessible means of communication (BFSGV, § 12 no. 4). What this means for hotline, chat and answer templates is described in the article on accessible customer service. The same principles apply to apps as to the web; details on VoiceOver and TalkBack are in the article on accessible apps.
For maps, a closer look at the exceptions pays off. Online maps and mapping services are excluded from the act, provided that essential information for navigational maps is made available in an accessible digital form (BFSG, § 1 para. 4 no. 3). A site plan of the bus station therefore needs a text description of the routes: where the bus platform is, where the elevator is and how to get there without steps. The article on accessible maps and store locators shows what that looks like for location search.
As a benchmark for design, the act offers a presumption rule: products and services that conform to harmonized standards whose references have been published in the Official Journal of the EU are presumed to meet the requirements of the ordinance, insofar as those standards cover them (BFSG, § 4). The article on the standard behind the BFSG explains the role EN 301 549 plays here. For the content under § 15 there is no standard to tick off: whether the information on the elevator at the bus station is correct is something the operator has to ensure itself.
Urban, suburban and regional transport: what remains
For urban, suburban and regional transport services, only letter e of the five elements applies, the interactive self-service terminals (BFSG, § 1 para. 3 no. 2). § 15 BFSGV expressly excludes these services (BFSGV, § 15). The definitions are narrow: urban and suburban services as well as regional services are transport services using rail, bus, metro, tram and trolleybus (BFSG, § 2 no. 31 and 32).
Two things follow from this. First, according to the wording, ships do not fall under the exemption because the definitions do not mention them. A ferry to an island that runs to a timetable and does not fall under Article 2(2) of the waterborne regulation is therefore covered with all five elements and the four information duties, unless the operator is a microenterprise, even if it feels like regional transport in everyday life. Second, for buses the main purpose of the route matters: if it serves the transport needs of an urban area, a conurbation with its surroundings or a region, the exemption applies; a long-distance route between regions does not fall under it.
The directive explains why the legislator leaves a gap here. Public sector bodies providing transport services are already obliged under Directive (EU) 2016/2102 to make their websites accessible (Directive (EU) 2019/882, recital 35). And since the directive already obliges the large majority of private transport service providers to make their websites accessible when selling tickets online, further requirements for the websites of regional transport providers were not considered necessary (Directive (EU) 2019/882, recital 35). For municipal operators, disability equality law therefore often applies, and for the online shop of a private regional operator, the e-commerce rules may apply. This classification depends on the individual case and should be documented.
Microenterprises, transition periods and fines
Many bus and shipping operators are small. The BFSG exempts microenterprises that offer or provide services from the accessibility obligation (BFSG, § 3 para. 3). Microenterprises employ fewer than ten persons and have either an annual turnover of no more than EUR 2 million or an annual balance sheet total of no more than EUR 2 million (BFSG, § 2 no. 17). The Federal Ministry of Labour and Social Affairs confirms in its guidelines that microenterprises providing services are excluded from the scope of the act (BMAS, guidelines).
Two limitations matter. The exemption only applies to services, not to products. And it requires both: fewer than ten employees and at least one of the two financial thresholds. An operator with eight employees, EUR 2.5 million annual turnover and a EUR 2.3 million balance sheet total is no longer a microenterprise. The article on the microenterprise exemption describes how to check the thresholds properly.
There are transition rules for existing equipment. Service providers may continue to provide their services until 27 June 2030 using products they already lawfully used before 28 June 2025 (BFSG, § 38 para. 1). Self-service terminals may continue to be used until the end of their economically useful life, but no longer than fifteen years after they were put into service (BFSG, § 38 para. 2). For websites, apps and the information under § 15, § 38 does not provide a separate transition period.
Anyone who offers or provides a service that does not meet the requirements of the ordinance commits an administrative offense (BFSG, § 37 para. 1 no. 8). In these cases the fine can be up to EUR 100,000 (BFSG, § 37 para. 2). The competent body is the market surveillance authority designated under state law (BFSG, § 2 no. 22).
Do not forget the information under Annex 3
Besides the content under § 15, the act requires a description of how the service meets the accessibility requirements. The service provider may only offer its service if it has prepared this information and made it available to the public in an accessible form (BFSG, § 14 para. 1 no. 2). It provides the information in its general terms and conditions or in another clearly perceptible way (BFSG, Annex 3 no. 1). The mandatory details include the competent market surveillance authority (BFSG, Annex 3 no. 1 letter d).
For transport operators it makes sense to link this statement with the page on the four information duties. The statement describes how website, app and ticket are designed and where limits remain. The information page delivers the content passengers need for their journey. Our accessibility statement service shows how such a statement is structured.
A test plan for long-distance bus, ferry and intercity train
The four information duties can be translated into a test process that operator and agency can work through together. One possible process in six steps:
- Classify: record mode of transport, routes and company size. Does the service fall under § 2 no. 27 to 30 BFSG, and does an exemption for regional transport or for microenterprises apply?
- Inventory: list all places where passengers receive information: website, app, booking flow, e-ticket, confirmation email, app notifications, interactive screens and terminals.
- Content under § 15: for each of the four numbers, check whether the information exists, where it is and who updates it.
- Form under § 12: check every location by keyboard, with a screen reader and with enlarged text. Text must be resizable without assistive technology up to 200 percent without loss of content or functionality (W3C, WCAG 2.2, SC 1.4.4).
- Test real time: trigger a delay and a cancellation in the test system and check whether the message reaches the screen reader and is understandable without color.
- Document: record results, open issues and the classification regarding the exemptions in writing and carry them over into the information under Annex 3.
| § 15 BFSGV | Typical location | Common barrier | Test |
|---|---|---|---|
| No. 1 accessibility, assistance | Page “Accessible travel”, access conditions, assistance request | Information only as a scanned PDF, request form without labels | Screen reader, keyboard, PDF text layer |
| No. 2 ticketing systems | Booking flow, booking help, e-ticket | Seat selection by mouse only, ticket only as an image | Keyboard, zoom, ticket in the screen reader |
| No. 3 real-time travel information | Journey planner, app, interactive displays | Delay shown only in color, refresh without announcement | Status region, color, table structure |
| No. 4 service information | Disruption notices, stop pages, app notifications | Broken elevators not reported, notice only as a graphic | Content, timeliness, text alternative |
The test question for every connection
What an audit covers and what stays with operations
A WCAG audit tests website and booking flow view by view: journey planner, list of connections, seat selection, payment, confirmation page and the page with accessibility information. This shows whether delays are understandable without color, whether seat selection works by keyboard and whether a screen reader outputs the departure table sensibly. A dedicated screen reader test is worthwhile for screen reader output, because automated tools can only judge status messages and reading order to a limited extent.
What an audit cannot do is verify the factual accuracy of the content. Only the operator knows whether the elevator at the ferry terminal works today and whether the ramp on the long-distance bus is designed for a heavy power wheelchair. That requires an editorial process: who reports disruptions, who maintains vehicle data, who checks the page after a timetable change? So that new barriers after an update do not go unnoticed, accessibility monitoring can measure the website continuously.
Providers in the travel and excursion business that do not fall under passenger transport often still have obligations as e-commerce services. Our page on accessible tourism gives an overview of booking portals and travel offers, and the article on accessible hotel booking covers accommodation booking.
Sources and legal basis
Related Articles
Accessible ticket shop: seat map, companion seat, e-ticket
Ticket shops under the BFSG: seat map with an equivalent seat list, bookable wheelchair and companion seats, mark B, a fair time window and a readable e-ticket.
Select Menus Without Surprises: WCAG 3.2.2 On Input
WCAG 3.2.2 in online stores: why sort, language and variant menus must not reload on the first arrow key, and how an Apply button and a keyboard test fix that.
BFSG Self-Check: What Site Owners Can Test Without Tools
Eight browser checks with no extra software: keyboard, zoom, images, title, headings, contrast, forms and video, plus where a self-check reaches its limit.