The BFSG: what Germany's accessibility law means for your website

In short

• The BFSG has applied since 28 June 2025.
• It covers certain products and services for consumers, including online shops and other services where consumers enter into contracts online.
• Microenterprises that provide services are exempt.
• In practice, the yardstick for websites is the European standard EN 301 549. It refers to WCAG 2.1 at level AA.
• The market surveillance authorities can demand changes and impose fines.

What is the BFSG?

The Barrierefreiheitsstärkungsgesetz (Accessibility Strengthening Act) is Germany's law implementing EU Directive 2019/882, the European Accessibility Act. It was passed in 2021 and has applied since 28 June 2025. The detailed requirements are set out in a regulation that comes with it, the BFSGV.

The aim is that people with disabilities can use products and services in the same way as everyone else. That includes people who are blind and use a screen reader, people with low vision who enlarge text, and people who can only use a keyboard.

Who does it apply to?

The law applies to businesses that place certain products on the market or provide certain services to consumers. The services include:

• e-commerce services: websites and apps where consumers enter into contracts, such as online shops and booking portals
• consumer banking services
• electronic communications services
• parts of passenger transport services by air, bus, rail and water, such as websites, apps, e-tickets and travel information
• e-books and the software for them
• access to audiovisual media services

Services aimed only at businesses are not covered. If you also sell to consumers, assume the law applies to what you offer. It applies to businesses outside Germany too when they serve consumers there.

The exemption for microenterprises

Microenterprises that provide services do not have to meet the requirements. A microenterprise has fewer than ten employees and either an annual turnover or an annual balance sheet total of no more than €2 million.

The exemption does not apply to products. And even if you are exempt, every barrier costs you customers who cannot use your shop.

What does the law require of websites?

Websites and apps must be perceivable, operable, understandable and robust. In practice that means, for example:

• Images have a text alternative that says what they show.
• Text has enough contrast with its background.
• Everything works with the keyboard, and you can see where you are.
• Form fields have a visible label.
• The page works when enlarged and on a phone.
• Error messages say what is wrong and how to fix it.

In practice, the yardstick is the European standard EN 301 549. For websites, it refers to the success criteria of WCAG 2.1 at level AA. A version of the standard adapted to the European Accessibility Act is being prepared. Luentis checks against the newer WCAG 2.2 at level AA, which carries the 2.1 criteria forward and adds a few new ones.

Service providers must also explain how their service meets the requirements, in their terms or in another clearly visible way. Many do this with an accessibility statement on the website.

What happens if a website falls short?

The market surveillance authorities of the German states are responsible. They have set up a joint body for this, the MLBF in Magdeburg. It can require that shortcomings are fixed and, as a last resort, prohibit a service from being offered. Breaches can be fined up to €100,000.

Consumers and associations can ask the authority to act. Whether competitors can send cease-and-desist letters (Abmahnungen) under competition law is legally disputed. It cannot be ruled out.

Are there transition periods?

Yes, but they are narrow. Service providers may keep using products they lawfully used before 28 June 2025 until 27 June 2030, and contracts from before that date run until they end, at the latest until then. Self-service terminals have a longer period.

Whether an existing website counts as such a product is disputed. It is safer not to rely on it.

What you can do now

1. Find out whether your service is covered and whether the microenterprise exemption applies.
2. Find the errors that can be measured automatically. Our free scan shows the most important ones on your homepage in under a minute.
3. Check what a machine cannot judge: whether alt texts make sense, whether everything works with the keyboard, and whether videos have captions.
4. Fix the errors, preferably in the templates, so they disappear from every page.
5. Publish the accessibility information for your service and keep it up to date.

Sources

• Barrierefreiheitsstärkungsgesetz (BFSG), in German
• Regulation to the BFSG (BFSGV), in German
• Directive (EU) 2019/882 on the accessibility requirements for products and services
• Bundesfachstelle Barrierefreiheit, the federal accessibility office, in German