digital transformation has fundamentally changed our business world. As companies increasingly rely on digital solutions, one aspect is coming into sharper focus: the digital accessibility. With the Accessibility Strengthening Act (BFSG), which came into effect on June 28, 2025, companies face new legal obligations that can have far-reaching consequences.
For managing directors, digital officers, and compliance officers, this means: act now or risk significant penalties. This article explains which companies are affected, what is specifically required, and how to ensure your company is legally compliant.
What is the Accessibility Strengthening Act (BFSG)?
The Accessibility Strengthening Act sets the EU directive „European Accessibility Act“ into German law and significantly expands the legal obligations for accessibility. While previous regulations primarily concerned public bodies, private companies are now also being held responsible.
Important: The BFSG does not apply universally to all companies or offerings, but only to specific products and services that are explicitly mentioned in the law and are directed at consumers. Therefore, it is particularly important to carefully check the applicability of the law.
Objective and purpose of the law
The BFSG aims to enable people with disabilities to have equal access to products and services. Specifically, this means: Digital offerings must be designed so that they can be used by all people, regardless of physical or mental limitations.
The implementation of the EU directive makes Germany a pioneer in digital inclusion, but also brings new compliance challenges for companies.
Who is affected by the BFSG?
Affected companies and economic sectors
The BFSG generally applies to companies that offer certain products or services named in the law to consumers. The law is particularly relevant for:
- E-Commerce businesses Online shops, marketplaces
- Software and App Developers
- Digital service provider (Banking, Insurance, Telecommunications)
- Web development agencies and IT service provider
- Media and streaming providers
Exceptions and Special Regulations
Small business Businesses with fewer than 10 employees and an annual turnover of less than 2 million euros are generally exempt from the obligations. However, this exception does not apply without restrictions – even small businesses can be affected if they offer specialized digital services.
Special features for digital offerings
For Online shops and digital services stricter requirements apply. Affected are in particular:
- E-commerce websites and mobile shopping apps
- Online banking and financial services
- Booking platforms and ticketing systems
- Digital forms and application processes
- Streaming Services and Media Players
What is specifically being demanded?
Central Requirements and Standards
The BFSG is based on the European standard EN 301 549, which in turn refers to the Web Content Accessibility Guidelines (WCAG) 2.2 Level AA. These define specific criteria for accessible web content
Minimum technical requirements (among others):
- Operability only via keyboard possible
- Sufficient color contrast (at least 4.5:1)
- Font size scalability up to 200%
- Alternative text for images and graphics
- Video Subtitling
- Logical structuring of content
What does „barrier-free“ mean in detail?
Accessibility means more than just technical compliance. An accessible digital offering is characterized by the following qualities:
- Perceptibility Content must be accessible to all senses
- Usability Navigation and interaction must be possible with various input devices
- Clarity Language and operating concepts must be clear and unambiguous.
- Robustness Compatibility with assistive technologies must be ensured
Documentation and review obligations
Companies must not only implement accessibility requirements, but also prove can. These include:
- Provide accessibility statements on the website
- Regular compliance reviews
- Documentation of all measures
- Setting up a feedback mechanism for users
Corporate obligations
Deadlines and transitional provisions
Critical Deadlines for Businesses:
- From June 28, 2025: Entry into force of the law - new products and services that fall within the scope of the law must be barrier-free from now on
- Existing products and services: A transition period applies to existing digital services until June 28, 2030
- Special regulations: For certain self-service terminals, longer transition periods of up to 15 years may apply.
Necessary implementation measures
Immediate measures for affected businesses:
- Gap Analysis Review of current digital offerings for accessibility
- Compliance Roadmap Development of an implementation plan with priorities and milestones
- Employee Training: Raising awareness among development and design teams
- Technical adjustments: Implementation of WCAG 2.2 AA standards
- Testing and Quality Assurance: Regular review
Special Requirements for Online Shops
Case study: A medium-sized online shop for electronics products must make the following adjustments:
- Enable keyboard navigation
- Add alternative text to product images
- Optimize checkout process for screen readers
- Make error messages clear and understandable
- Implement accessible search function
Implementation requires both technical expertise and ongoing maintenance and updates.
Consequences of non-compliance
Sanctions and monitoring
The responsible authorities Market surveillance authorities are authorized to penalize violations of the BFSG. Possible sanctions can include:
- Fines up to 100,000 Euros
- Arrangements for rework
- Sales bans for non-conforming products or services
- Public Announcement of violations
Legal and economic consequences
In addition to regulatory sanctions, there are further risks:
- Civil claims by those affected
- Reputational damage through negative media coverage
- Competitive disadvantages compared to compliance-compliant competitors
- Exclusion from public tenders
The economic consequences of non-compliance can far outweigh the investment costs for accessibility.
Practical Implementation: Your Guide to BFSG Compliance
Immediate measures for your company
First 30 Days Checklist:
- Checking your company's exposure
- Inventory of all digital offerings
- Budget planning for necessary adjustments
- Contacting Legal Counsel and Accessibility Experts
Long-term compliance strategy
Accessibility is not a one-time project, but an ongoing process. Successful companies integrate accessibility into their product development from the beginning and establish appropriate quality assurance processes.
Frequently Asked Questions (FAQ)
Does the BFSG also apply to our internal software? No, the BFSG primarily applies to products and services offered to consumers. Internal software is generally not covered by the regulations.
Is a disclaimer about limited accessibility sufficient? No, disclaimers do not replace the obligation for accessibility. Such notices can even be seen as an indication of intentional non-compliance.
3. What costs are incurred by the BFSG implementation? Costs vary widely depending on the complexity of the digital offering. Based on experience, companies should expect accessibility modifications to cost 10–30% of the original development costs.
Can we delegate the implementation to external service providers? Responsibility for compliance remains with the company, even when external service providers are engaged. Clear contractual regulation of liability is essential.
How often do we need to check accessibility? The law does not prescribe fixed intervals, but regular checks are recommended, at least for major updates or new features.
Your next steps: Professional advice ensures compliance
The Accessibility Strengthening Act presents companies with complex legal and technical challenges. Professional consulting helps to minimize risks and achieve compliance cost-effectively.
Our firm supports you with:
- Legal assessment of your affectedness
- Development of customized compliance strategies
- Contract Design with Service Providers and Developers
- Preparation for official inspections
- Crisis management for compliance violations
Have the legal implementation reviewed now.
Don't wait for the first sanctions. Contact us today for a no-obligation initial consultation on the Accessibility Strengthening Act. Together, we will develop a strategy that makes your company legally compliant and opens up new target groups.