BFSG: what the accessibility requirement means for your website

Who the law applies to

The German Accessibility Strengthening Act (BFSG) implements an EU directive and has applied since June 28, 2025 to products and services offered after that date.

Affected are, among others:

Online stores and e-commerce of any size. Banking and payment services. Telecommunications services. Websites of passenger transport services. Booking systems for hotels, travel and appointments. In general: services in electronic commerce with consumers.

Not affected are:

Purely B2B offers, provided it is clear that they are not aimed at consumers. Purely informational websites without contract conclusion. And micro-enterprises for services, more on that in a moment.

The line is not always clear-cut in individual cases. A website where you can book an appointment is something different from one that only has a contact form. If in doubt, a specialist lawyer can clarify this. This article is not legal advice.

The distinction in one sentence

The German Accessibility Strengthening Act (BFSG) implements an EU directive and has applied since June 28, 2025 to products and services offered after that date.

Affected are, among others:

Online stores and e-commerce of any size. Banking and payment services. Telecommunications services. Websites of passenger transport services. Booking systems for hotels, travel and appointments. In general: services in electronic commerce with consumers.

Not affected are:

Purely B2B offers, provided it is clear that they are not aimed at consumers. Purely informational websites without contract conclusion. And micro-enterprises for services, more on that in a moment.

The line is not always clear-cut in individual cases. A website where you can book an appointment is something different from one that only has a contact form. If in doubt, a specialist lawyer can clarify this. This article is not legal advice.

The exemption for micro-enterprises

For services, there is an exemption if both conditions apply:

Fewer than ten employees (calculated in annual work units) and an annual turnover or annual balance sheet total of no more than two million euros.

Important: this exemption applies only to services, not to products. If you manufacture physical products that fall under the law, you can't rely on it.

Just as important: the threshold is crossed faster than many people assume. Ten employees are quickly reached in a growing company, and then the exemption no longer applies.

A practical note: even if you are exempt, you should know the requirements. A company that is below the threshold today and above it in two years will otherwise build its website twice.

What is technically required

The law refers to the European standard EN 301 549, which for digital offerings refers to the Web Content Accessibility Guidelines at levels A and AA. Currently that is WCAG 2.1, future versions will refer to 2.2.

The most important requirements in practice:

Contrast. Body text at least 4.5:1 against the background, large text and controls at least 3:1. This is where most websites fail: light gray text on white is very common.

Keyboard navigation. Everything must be reachable and usable without a mouse, with a visible focus indicator.

Alt texts for all images that carry information.

Forms with linked labels and understandable error messages.

Structure. A meaningful heading hierarchy, regions marked up correctly.

Scalability. Up to 200 percent text enlargement without loss of information.

Videos with subtitles.

What is required in addition

Besides the technology, there are formal obligations that are easily overlooked.

An accessibility statement. It describes how the offering meets the requirements, which parts may not be accessible and why. It belongs on the website, reachable like the legal notice and privacy policy.

A feedback channel. Users must be able to report barriers, with a named point of contact.

Documentation. How the requirements were implemented will be requested in an inspection by the market surveillance authority.

On enforcement: the market surveillance authorities of the federal states are responsible and can impose fines. In addition, there is the risk of cease-and-desist letters under competition law from competitors or associations.

How the practice of such letters will develop can't be seriously predicted at the moment. If you are affected, you shouldn't rely on nothing happening.

What to do if you are affected

Step 1: Inventory. An automated test uncovers about thirty to forty percent of the problems: missing alt texts, contrast that is too weak, missing labels. There are free tools for this.

Step 2: Manual review. The larger part can only be checked by hand. The three most important tests: navigate the entire website using only the Tab key. Fill out and submit all forms without a mouse. Enlarge the text to 200 percent and see whether everything is still readable.

Step 3: Prioritize. First the paths through which transactions are concluded: product page, cart, checkout, form, booking. Then the rest.

Step 4: Fix. Contrast and alt texts are usually done in hours. Keyboard navigation and forms can mean development effort.

Step 5: Publish the statement and set up the feedback channel.

Why it pays off even without an obligation

A large share of companies is not affected: purely B2B providers, informational websites, micro-enterprises. For them, some of the measures still pay off.

Contrast improves readability for everyone, especially on smartphones in sunlight. That is not a niche topic.

Keyboard navigation and clean form labels improve usability in general and reduce drop-offs.

Alt texts help image search and are evaluated by generative systems.

A clear heading structure is an SEO foundation at the same time.

Then there is the audience itself: about one in ten people has an impairment that makes use more difficult. The share rises with age, and decision-makers in B2B are, on average, not young.

The overlap with good implementation is so large that most points pay off anyway.