Accessibility: BFSG since 28.06.2025
The German Accessibility Strengthening Act (BFSG) implements EU Directive 2019/882 (European Accessibility Act). B2C websites, apps, e-commerce, e-books and online banking must be accessible since 28.06.2025. Violations: up to EUR 100,000 in fines plus distribution bans.
What it's about
The BFSG has been in force since 28.06.2025. It obliges companies to offer certain digital products and services in an accessible way — so they can be used by people with disabilities. The international WCAG 2.2 Level AA standard is the usual yardstick, defining technical requirements (keyboard operation, screen-reader compatibility, sufficient colour contrast, scalable text).
In scope: all companies with more than 10 employees OR more than EUR 2m annual turnover — either criterion is enough. On top of that, some industries are in scope regardless of size: e-commerce, online banking, passenger transport (bookings, tickets), e-books, e-readers, ePayment and telecommunications services. Pure B2B software is exempt — but only as long as no private customers are actually reached.
Non-compliance is expensive and reputationally damaging: fines up to EUR 100,000, plus the supervisory authority can ban the distribution of the affected product until the defect is fixed. A 'statement of accessibility' on the website is also mandatory — even if not everything is met yet. Transparency about the current state matters more than perfection on day one.
Who is affected
- Online shops (B2C) — regardless of company size, because e-commerce is its own mandatory category.
- Banks and financial services with online banking, trading platforms, credit/account applications.
- Transport companies and travel providers with online booking, tickets, live departure times.
- Providers of e-books, e-readers and digital reading devices.
- Payment providers (ePayment, wallet apps, pay buttons).
- Telecommunications companies with consumer portals (contracts, hotline booking).
- All other companies with a B2C website or app once they hit >10 employees OR >EUR 2m turnover.
What is mandatory
- Keyboard operation: every function reachable without a mouse, logical tab order, no 'keyboard trap' effect.
- Screen-reader compatibility: semantic HTML (heading hierarchy, landmarks), ARIA roles only where HTML alone isn't enough.
- Colour contrast: at least 4.5:1 for body text, 3:1 for large text (from 18pt) and UI components/graphics.
- Scalable text up to 200% without loss of function and without horizontal scrolling.
- Focus indicators visible and consistent (no 'outline:none' without a replacement), with sufficient contrast.
- Touch targets at least 24×24 CSS pixels (WCAG 2.2 SC 2.5.8) — important on mobile.
- Alt text for every informative image, captions for video, transcripts for audio.
- Form labels clearly associated, error messages understandable and with a hint how to fix.
- Animations reducible (`prefers-reduced-motion`), no auto-play longer than 5 seconds.
- Statement of accessibility on the site: state (fully/partially/not), exceptions with reasons, contact, conciliation body.
- Feedback mechanism for users (email or form) with a response-time promise.
What I take care of
- WCAG 2.2 AA audit: automated scan (Lighthouse + axe-core) plus manual review plus screen-reader test with NVDA (Windows) and VoiceOver (Mac/iOS).
- Written audit report with priority (blocker / critical / optimisation) and concrete code pointers, not just 'problem here'.
- Semantic HTML refactoring where components aren't accessible — from buttons to navigation menus, modals, tabs.
- Component library audit: existing UI components (buttons, inputs, cards) checked against BFSG and brought up to standard.
- Accessibility panel for end users: font-size slider, high-contrast mode, reduced motion, read-aloud — not a pseudo-toolbar, but real CSS classes the components actually react to.
- Statement page with the legally required content (date, contact, feedback address, conciliation body) — DE and EN, synced automatically with the audit history.
- Feedback form with categories, file upload and a response-time promise (typically: 5 business days for first reply).
- Team training for developers and content editors: 2-3 hour workshop on WCAG basics, screen-reader demo, definition of done.
- Continuous review on new features (a11y as standard in the definition of done, CI tests with axe-core, manual smoke tests before release).
Legal basis
German Accessibility Strengthening Act (BFSG, in force since 28.06.2025) · BFSGV (regulation implementing the BFSG) · EU Directive 2019/882 (European Accessibility Act, EAA) · EU Directive 2016/2102 (public sector) · BITV 2.0 (federal/state/local government) · Harmonised standard EN 301 549 V3.2.1 · WCAG 2.2 Level AA as technical benchmark
Frequently asked
- My shop has 8 employees and EUR 1m turnover — am I affected?
- It depends. Both thresholds must be BELOW the line to use the exemption: fewer than 10 employees AND less than EUR 2m turnover. With 8 staff and EUR 1m you'd already be out. BUT: e-commerce is its own mandatory category without thresholds — if you sell B2C, BFSG always applies.
- Is a 'toolbar' with font size + contrast that many sites embed enough?
- No, that's window dressing. Most toolbars set DOM classes without the components reacting — so click OK, effect zero. Real accessibility is the site itself: semantic HTML, keyboard operation, sufficient contrast, correct ARIA roles. A toolbar can be a comfort layer, but replaces nothing.
- What is the 'statement of accessibility'?
- Mandatory site content: state of conformity (full / partial / none), areas not yet accessible (with reason), contact for issues, conciliation body. Format: a dedicated page, usually linked in the footer. Even if not everything is fulfilled — transparency is required.
- What concretely happens if I don't meet the BFSG?
- Three stages: first the competent market-surveillance authority (Federal Accessibility Centre via the state-level bodies) can raise objections and demand remediation. Second, fines up to EUR 100,000. Third, the authority can prohibit distribution of the product or provision of the service until the defect is fixed — for online shops that effectively means a shutdown. On top of that come consumer-association warning letters and reputational damage.
- What does a WCAG 2.2 AA audit cost, and how long does it take?
- Depends on page count and complexity. Rule of thumb: a simple 5-10-page site with contact form and products — 1-2 days of audit plus report (about EUR 1,500-3,000). A complex portal with login, booking, checkout — 4-8 days (about EUR 6,000-12,000). Purely automated tools (Lighthouse, axe-core) only catch 25-40% of issues — the truly blocking ones (keyboard trap, wrong heading hierarchy, bad screen-reader experience) can only be found manually.
- How do I keep accessibility going long-term, not just once?
- Three building blocks: first, automated tests in CI (axe-core in Playwright tests, blocks pull requests on new violations). Second, extend the 'definition of done' for new features with a11y items (keyboard tested, screen-reader test, contrasts checked). Third, annual re-audit with real users and onboarding training for new team members. Anyone who doesn't bake this into the process is back at ~40% conformance after 12 months.
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