Digital Accessibility Act

Digital accessibility is no longer a ‘nice-to-have’ – it’s becoming mandatory. Starting June 28, 2025, the Accessibility Enhancement Act (Barrierefreiheitsstärkungsgesetz – BFSG) will require many companies to implement accessible digital products and services.

This law, which transposes EU Directive 2019/882 (European Accessibility Act) into German legislation, aims to ensure equal and non-discriminatory access to digital offerings for everyone. For both B2B and B2C companies, this means concrete obligations – but also opportunities, such as broader reach and improved usability.

What is the Accessibility Enhancement Act (BFSG)?

The BFSG is a German law that implements EU Directive 2019/882 (European Accessibility Act) into national law. It obliges private companies to make their digital products and services accessible in order to enable people with disabilities to use them equally.

The law primarily targets digital offerings (websites, apps, software) and technical consumer products used by the general public.

The aim is to remove existing barriers and promote social inclusion. Millions of people with visual, auditory, motor, or cognitive impairments depend on accessible digital offerings.

Harmonized requirements across the EU also establish clear standards, strengthen the internal market, and drive innovation in digital accessibility. While previously only public bodies were obligated to ensure web accessibility (under the BITV 2.0 regulation), the BFSG now extends this requirement to large parts of the private sector.

Which companies, products & services are affected?

In principle, all providers of consumer products and services fall under the BFSG. The law addresses five types of economic actors: manufacturers, importers, distributors, authorized representatives, and service providers.

In practice, this means that both producers and distributors of the relevant devices, as well as operators of digital services, must meet the new requirements. B2B companies may also be affected, for instance if they provide software or platforms that are integrated into consumer solutions.

Affected services (examples):

• Telecommunications services (e.g. telephony, SMS, messenger services)

• Online communication services (e.g. email, chat)

• Passenger transport services – digital elements (websites, apps, e-ticketing for train or flight bookings)

• Banking services (online banking, banking apps, payment systems)

• E-book services (sales platforms for e-books, reading apps)

• E-commerce services (online shops, shopping apps, online appointment booking, etc.)

Affected products (examples):

• Computer hardware and operating systems (e.g. PCs, laptops, tablets with their OS)

• Telecommunication devices (e.g. smartphones, landline phones)

• Interactive consumer devices with internet access (e.g. smart TVs, streaming devices)

• Self-service terminals (e.g. ATMs, ticket machines, check-in kiosks)

• E-book readers (e.g. e-readers for digital books)

Important: E-commerce is almost entirely covered by the BFSG. Virtually every online shop or booking platform for consumers must be made accessible. Excluded are purely informational web offerings without transactional functionality (e.g. blogs or company websites without a shop), as they do not involve product sales or service bookings.

Microenterprises (fewer than 10 employees and ≤ €2 million annual turnover or balance sheet total) are exempt from BFSG obligations provided they only offer services. A small startup offering a web service to consumers would therefore not fall under the law.

Note: Microenterprises that place products on the market are not exempt – the requirements also apply to them (with simplified documentation obligations).

Deadlines: When do the requirements apply?

The Accessibility Enhancement Act enters into force on June 28, 2025. From that date, all new products and services must be accessible – i.e. any offering launched after that must meet the requirements.

Transition periods:

• 5-year transition period (until June 28, 2030): For services based on systems or products already in use before the effective date. (Example: A Software-as-a-Service platform launched in 2024 must be updated for compliance by 2030.)

• 15-year transition period (until June 28, 2040): For already deployed self-service terminals (e.g. older ATMs or ticket machines).

However, for all new websites, apps, devices, etc., 2025 is a firm deadline. Companies should begin implementing changes early. Online retailers, in particular, should ensure full compliance by June 2025 to avoid legal action or penalties.

What happens in case of non-compliance?

Violations of the BFSG can have costly consequences. Market surveillance authorities of the German federal states may prohibit the sale of non-compliant products or impose fines of up to €100,000.

In addition:

• Competitors may issue warnings under competition law

• Associations are authorized to report violations

In short: Strict enforcement of the new regulations is to be expected starting on the effective date.

Technical requirements & guidelines

When is a digital offering considered “accessible”? The BFSG broadly defines accessibility as the ability to access and use a product or service “in the customary manner, without undue difficulty and essentially without the need for assistance” for people with disabilities.

The EU Directive 2019/882 and the BFSG are based on existing standards. The harmonized European standard EN 301 549 defines in detail which technical requirements products and services must meet – from websites and apps to ATMs and ticket machines.

This standard is largely based on the Web Content Accessibility Guidelines (WCAG). The full set of criteria is listed in the BFSG statutory ordinance.

In practice, WCAG 2.1 (Level AA) is the benchmark for websites, webshops, and apps. Additional requirements for hardware, documents, and software go beyond WCAG and are addressed by EN 301 549.

Fundamentally, the digital accessibility criteria are based on four principles: Perceivable, Operable, Understandable, and Robust.

Quick Check: Key WCAG Principles

Perceivable

• Text alternatives: All non-text content must have meaningful alt text or descriptions.

• Color & contrast: Information must not be conveyed through color alone. Contrast ratio: minimum 4.5:1.

Operable

• Keyboard access: All elements must be usable without a mouse.

• Sufficient time: No automatic redirects or short timeouts.

• Clear navigation: Consistent, logical structure. Focus order must be correct.

Understandable

• Plain language: Clear, comprehensible wording. No complex sentence structures.

• Error feedback: Clear guidance when input errors occur, with suggested corrections.

Robust

• Compatibility: Content must work with assistive technologies.

• Clean code: Standards-compliant HTML/CSS code, properly validated.

Benefits of Accessibility

• Legal certainty: Fulfillment of legal obligations, avoidance of penalties

• Expanded target group: Access for more people (including seniors and people with disabilities)

• Improved user experience (UX): Intuitive usability, higher conversion rates

• Brand image & customer loyalty: Demonstrate social responsibility, build trust

Implementation & Consulting: How we support you

Implementation may seem complex – but with the right partner, it can be done step by step. Consulteer supports you with a proven approach:

1. Context consulting & kick-off workshop: Status analysis and initial actions

2. Analysis & action plan: Accessibility audit, WCAG testing, practical recommendations

3. Implementation: Optimization of design, code, UI/UX, and compliance

Tip: Unsure whether your offerings are affected? We’ll be happy to advise you.