Accessibility Strengthening Act (BFSG): Does it apply to you?

07/20/2025

On June 28, 2025, the Accessibility Strengthening Act (BFSG) came into force.

Since it implements the EU Directive 2019/882 on the accessibility of websites into German law, many companies are now wondering whether they are affected. Here you can find out what the BFSG regulates — and whether you need to take action.

What does the BFSG require?

The BFSG aims to make websites more accessible for people with disabilities or older people. Even if your company is not directly obligated to do so, an accessible website can be a strong sign of inclusion and user-friendliness. Recommended measures include the following (non-exhaustive list):

Every image and graphic must be accompanied by meaningful alternative text so that screen reader users can understand the content.
Full keyboard accessibility of the website.
Sufficient contrast between text and background, as well as a legible and scalable font.
The website should have a clear structure and use simple language to facilitate navigation and information retrieval.

Who is affected?

According to §1 BFSG, the law applies to two categories:

1. Products (if they are sold on the EU market):

Hardware systems for universal consumer search (and operating systems)
Self-service terminals
Interactive terminal equipment for telecommunications or audiovisual services
E-book readers

2. Services:

Telecommunications services with the exception of transmission services for the provision of M2M communication services
Passenger transport services by air, bus, rail, and ship (except local transport)
Banking services for consumers
E-books, including related software
Services in electronic commerce

How do I find out which performance category I fall into?

First, ask yourself whether you offer the services or products listed above. However, difficulties may arise with services that involve electronic transport.

What counts as “electronic commerce”?

According to Section 2 (26) BFSG, services in electronic commerce refer to telemedia services via websites or mobile apps that lead to a consumer contract upon individual request.

Section 1 (3) No. 5 BFSG extends this category to any business website with digital reservation or booking tools for an individual, specific request.

Any company website that offers digital booking tools for the conclusion of a consumer contract – for example, an online shop – generally meets the above criteria. Purely informational websites that only provide general contact information (e.g., a contact section) or serve exclusively to inform consumers about the services offered by the company are generally not sufficient.

If you do not offer any of the above services or products and your website does not allow online purchases of products or services, you are probably not affected by the law.

I offer such services – does the law apply to me?

Not necessarily. Section 3 (3) BFSG excludes micro-enterprises, i.e. companies that:

have fewer than 10 employees and
have an annual turnover or balance sheet total of no more than €2 million

But PLEASE NOTE: This exception does not apply if you sell one of the above-mentioned products (e.g., e-book readers), regardless of the size of your company.

What are the risks if I don't comply with the BFSG even though I am affected?

If a company fails to comply with the Barrier-Free Access Act (BFSG), it risks fines and official orders. Specifically, fines of up to €100,000 can be imposed. In addition, orders to remedy accessibility deficiencies may be issued.