Starting 28 June 2025, the Ac­cess­ib­il­ity Re­in­force­ment Act (BFSG) will be legally binding for many digital products and services in Germany. What legal found­a­tions apply, how can one assess the ac­cess­ib­il­ity of a website, and which tools fa­cil­it­ate efficient im­ple­ment­a­tion?

Legal found­a­tion: EU Directive becomes German law

The origin of the Ac­cess­ib­il­ity Re­in­force­ment Act (or the BFSG in German) lies at EU level. With Directive (EU) 2019/882, known as the European Ac­cess­ib­il­ity Act (EAA), the European Union es­tab­lished a unified legal framework to reduce digital barriers in products and services. The goal is a uniform minimum standard for ac­cess­ib­il­ity within the EU internal market.

This directive was adopted on 17 April 2019 and had to be trans­posed into national law by 28 June 2022, at the latest. Germany did so with the Ac­cess­ib­il­ity Re­in­force­ment Act (BFSG), published in the Federal Law Gazette on 22 July 2021. The practical com­pli­ance deadline for affected busi­nesses is 28 June 2025.

For UK companies operating in or targeting the EU market, com­pli­ance with EAA reg­u­la­tions is essential. It is important to note that whilst the Equality Act 2010 and Public Sector Bodies (Websites and Mobile Ap­plic­a­tions) Ac­cess­ib­il­ity Reg­u­la­tions 2018 govern ac­cess­ib­il­ity in the UK, the EAA in­tro­duces ad­di­tion­al re­quire­ments for products and services offered within the EU. Therefore, UK busi­nesses should assess their digital offerings to ensure they meet both UK ac­cess­ib­il­ity standards and EAA re­quire­ments when operating in or targeting the EU.

Who is affected?

The Ac­cess­ib­il­ity Re­in­force­ment Act (BFSG) applies to a wide range of products and services, including:

  • E-commerce websites and online stores
  • Digital booking systems and banking apps
  • Self-service kiosks (e.g., cash­points)
  • Digital devices such as smart­phones, routers, or e-book readers
  • Software with end-user in­ter­faces (e.g., login-based apps)

Mi­croen­ter­prises are exempt only if they ex­clus­ively provide services - once they man­u­fac­ture or sell products, the law applies to them.

Tip

Even if your website is not legally required to comply - ac­cess­ib­il­ity is always worth it! Many of the ex­emp­tions are only formal. In practice, every website benefits from improved ac­cess­ib­il­ity, higher usability and stronger SEO.

What exactly does the Law require?

The Ac­cess­ib­il­ity Re­in­force­ment Act (BFSG) requires many busi­nesses to make their digital offerings ac­cess­ible starting 28 June 2025. The re­quire­ments are based on several levels - in­ter­na­tion­al, European, and national:

  • The WCAG (Web Content Ac­cess­ib­il­ity Guidelines) were developed by the W3C and have long served as the in­ter­na­tion­al standard for ac­cess­ible web design. They define specific success criteria for ac­cess­ible content and user in­ter­ac­tions.
  • Building on the WCAG, the European Ac­cess­ib­il­ity Act (EAA) was adopted in 2019 as an EU directive. It mandates that certain digital products and services within the EU must be ac­cess­ible.
  • In 2021, the EAA was trans­posed into German national law through the Ac­cess­ib­il­ity Re­in­force­ment Act (BFSG). This law defines which busi­nesses are affected, what penalties may apply in case of vi­ol­a­tions and what specific re­quire­ments must be im­ple­men­ted.
  • In practice, com­pli­ance is guided by EN 301 549. This har­mon­ised European technical standard trans­lates the re­quire­ments of the EAA and WCAG into concrete terms - for example, regarding colour contrast, keyboard nav­ig­a­tion or al­tern­at­ive text.
Note

Law, directive and standard - how it all fits together

The legal re­quire­ments for digital ac­cess­ib­il­ity are struc­tured on three levels:

  1. The European Ac­cess­ib­il­ity Act (EAA) is the EU directive that mandates ac­cess­ib­il­ity for certain digital products and services.
  2. The Ac­cess­ib­il­ity Re­in­force­ment Act (BSFG) is the German law that im­ple­ments the EAA and specifies who must comply and how.
  3. EN 301 549 is the cor­res­pond­ing technical standard, which provides detailed guidance on how digital ac­cess­ib­il­ity must be im­ple­men­ted.

Based on the WCAG 2.2 guidelines, the standard includes criteria at Levels A, AA, and AAA. Levels A and AA are mandatory in practice.

Check: does your website comply with the Ac­cess­ib­il­ity Re­in­force­ment Act (BFSG)?

If your company is affected, take the following steps:

  1. Analysis & audit: use tools like Light­house, axe DevTools, WAVE, or the BITV-Test.
  2. Follow standards: ensure com­pli­ance with WCAG 2.2 and EN 301 549.
  3. Publish an ac­cess­ib­il­ity statement: promote trans­par­ency and gather user feedback.
  4. Ongoing testing & main­ten­ance: ac­cess­ib­il­ity is not a one-time project.
Tip

Combine automated testing with real user testing. Only this reveals real-world barriers that tools often miss - such as unclear error messages or in­con­sist­ent nav­ig­a­tion.

Tools and plugins for support

When reviewing ac­cess­ib­il­ity, tools like Google Light­house can be extremely helpful. Each of the following tools offers specific benefits:

Tool Function Type
Google Light­house Automated analysis via Chrome DevTools Open Source
Deque axe Developer extension with issue dia­gnostics Free
PAC 3 Ac­cess­ib­il­ity checker for PDFs Free
Eye-Able Frontend widget for user cus­tom­isa­tion Licence-based
Siteim­prove / Monsido Website mon­it­or­ing incl. SEO & ac­cess­ib­il­ity Sub­scrip­tion

Main­ten­ance and updates

Im­ple­ment­ing ac­cess­ib­il­ity re­quire­ments is not a one-time project. Instead, the Ac­cess­ib­il­ity Re­in­force­ment Act (BFSG) mandates that ac­cess­ib­il­ity must be con­tinu­ously ensured, even as digital offerings are updated or modified.

In practice, this means that whenever you make technical or content-related changes to your website - whether through new features, a website relaunch or a design update - these changes must be re-tested for ac­cess­ib­il­ity and im­ple­men­ted in com­pli­ance with current standards.

This is es­pe­cially important for:

  • New or revised pages, forms or nav­ig­a­tion elements
  • New mul­ti­me­dia content such as videos, PDFs, or graphics
  • System changes, e.g., switching CMS or web hosting provider
  • In­teg­ra­tion of third-party com­pon­ents (e.g., booking tools)

Even existing content should be reviewed regularly to ensure ongoing com­pli­ance.

Re­com­mend­a­tion

To ensure long-term com­pli­ance with legal re­quire­ments, companies should establish ac­cess­ib­il­ity as an integral part of their digital main­ten­ance processes. A struc­tured main­ten­ance plan helps to regularly review technical and editorial changes and identify barriers at an early stage. This includes:

  • Regular manual and automated audits (e.g., every six months)
  • Training for web teams and content editors
  • Feedback mech­an­isms to allow users to report ac­cess­ib­il­ity issues
  • Updating the ac­cess­ib­il­ity statement whenever content or func­tion­al­ity changes

What are the risks of non-com­pli­ance?

Starting 28 June 2025, vi­ol­a­tions of the Ac­cess­ib­il­ity Re­in­force­ment Act (BFSG) will be subject to legal penalties. Potential con­sequences include:

  • Fines of up to €100,000 (around £85,000) in EU markets
  • Cease and desist orders and legal actions under com­pet­i­tion law
  • Loss of public funding or subsidies
  • Repu­ta­tion­al damage
  • Lower search engine rankings
Note

Beginning in June 2025, vi­ol­a­tions of the Ac­cess­ib­il­ity Re­in­force­ment Act (BFSG) could result in fines of up to €100,000 (around £85,000). Beyond financial penalties, your business also risks repu­ta­tion­al harm, SEO setbacks and even website takedowns. Acting now will help you avoid costly re­medi­ation later.

Checklist: how to achieve digital ac­cess­ib­il­ity

This overview sum­mar­ises the key re­quire­ments for ac­cess­ible websites based on the WCAG and EN 301 549 standards:

Category Re­quire­ments
Per­ceiv­ab­il­ity Alt text for images, captions for videos, suf­fi­cient colour contrast
Op­er­ab­il­ity Full keyboard nav­ig­a­tion available, no flashing content, avoiding time-based lim­it­a­tions
Un­der­stand­ab­il­ity Clear structure, plain language, help text for forms
Ro­bust­ness Semantic HTML, screen reader support, assistive tech com­pat­ib­il­ity

The Ac­cess­ib­il­ity Re­in­force­ment Act (BSFG) is more than just a reg­u­lat­ory ob­lig­a­tion - it’s a call for greater inclusion in the digital space. It also presents an op­por­tun­ity for busi­nesses to expand their reach, tap into new target audiences and remain com­pet­it­ive in the long term.

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