BFSG from 28 June 2025: who is affected and how to implement WCAG 2.2 AA

The German Accessibility Strengthening Act (BFSG) came into force on 28 June 2025 — Germany's implementation of EU Directive 2019/882 (European Accessibility Act). Since then B2C websites, apps, e-commerce, online banking and e-books must be accessible. Fines: up to EUR 100,000 per violation plus distribution bans. Anyone not yet compliant in 2026 is at risk. This article clarifies: who is affected, what is mandatory, how to implement it technically.

Who is affected?

The BFSG applies to companies offering digital products to consumers — depending on two thresholds:

• More than 10 employees OR
• More than EUR 2 million turnover per year.

If just one of the two values is over the threshold, the duty applies. If both are below, there is an exemption — but: certain industries are always covered, regardless of size:

• E-commerce (online shops, marketplaces)
• Online banking
• Passenger transport (rail booking, flight tickets)
• ePayment services

Pure B2B software is not covered — anyone selling exclusively to business customers can put the BFSG aside for now. But: many cases are mixed forms (B2B software that also reaches end customers), and supervisory authorities tend to interpret the rule broadly when in doubt.

What's mandatory? WCAG 2.2 Level AA

The BFSG references the standard WCAG 2.2 Level AA in conjunction with the European norm EN 301 549. In concrete terms:

1. Keyboard operation

Every function must be operable without a mouse. Buttons, links, forms, modals, tabs — everything via Tab and Enter. Simple test: put the mouse away, complete a typical user task (e.g. checkout) entirely with the keyboard. If that doesn't work, the site is not WCAG-compliant.

2. Screen reader compatibility

Semantic HTML is the foundation: `` instead of `

`, `