Digital accessibility becomes law: Starting in 2025, the BFSG (Accessibility Strengthening Act) will require digital products and services to be accessible to all. Many companies are uncertain: Who exactly is affected by the BFSG? What are the specific requirements of the law? In this article, we address some of the most frequently asked questions about the BFSG and what it means for websites, online shops, and other digital services.
The article provides only a general overview of the law – for legal advice, please consult your attorney.
Content
- What is the Accessibility Strengthening Act (BFSG)?
- Who is affected by the law?
- When does the BFSG take effect?
- What requirements does it impose on web content?
- Is there financial support for implementation?
- What penalties apply for non-compliance?
- Conclusion
What is the Accessibility Strengthening Act (BFSG)?
The BFSG is the national implementation of the European Accessibility Act (EAA) and aims to ensure that digital products and services are accessible to everyone – especially people with physical, sensory, or cognitive impairments. This includes websites, apps, self-service terminals, online shops, and banking services.
The goal of the law is to establish uniform accessibility standards and strengthen the right of people with disabilities to participate fully in society.
Who is affected by the BFSG?
The BFSG applies to companies across all industries that provide certain digital services or products, particularly those aimed at consumers (B2C). B2B companies are generally exempt, except in specific cases (see here).
Examples of affected businesses and their products or services include:
- Banks: ATMs, financial services
- Passenger transport services: Ticket machines, online timetable information
- Telecommunications providers: Telephone services, routers
- Technology companies: Computers, laptops, tablets, smartphones
- E-commerce businesses: B2C online shops
- And many more
Which products and services are affected by the BFSG?
As mentioned, the BFSG is not limited to specific industries. Whether it applies depends primarily on the products or services offered.
Products that must be accessible under the BFSG include: computers, laptops, tablets, smartphones, routers, payment terminals, ATMs, ticket and check-in machines, and e-book readers.
For services, the law covers: telecommunication services (e.g., telephone and messenger services), e-books, passenger transport services, banking services, and e-commerce.
Note: Electronic commerce
"Electronic commerce" essentially includes all digital platforms where consumers conduct transactions or enter into contractual agreements. This covers online shops, booking platforms, online banking, online marketplaces, and generally all websites or apps that allow consumers to conclude contracts.
Are there any exceptions?
Purely business-related B2B offerings are generally not covered by the BFSG. However, caution is advised: companies that develop software for public institutions, large platforms, or B2C interfaces may still be required to comply with the regulations.
Another exception applies to micro-enterprises, meaning businesses with fewer than 10 employees and an annual turnover of less than 2 million euros. For these companies, the effort required for full BFSG compliance is often considered disproportionately high.
In both cases, those who want to be sure should consult a lawyer.
When does the BFSG take effect?
The Accessibility Strengthening Act (BFSG) officially comes into force on June 28, 2025. Websites, apps, online shops, and other digital services must be fully accessible by this deadline to comply with legal requirements. To avoid legal consequences, businesses that have not yet started preparing should begin planning and implementing accessibility measures as soon as possible.
Are there transition periods?
Certain digital products that were already on the market before June 28, 2025, may benefit from transition periods, allowing companies more time to adapt. In some cases, these products may have until 2030 to implement the necessary accessibility adjustments. However, this transition period does not apply to updates—new versions or significant changes may require compliance earlier.
Important: Transition periods do not apply to websites, mobile apps, and digital services. These must be fully accessible by June 28, 2025, to avoid fines or other legal consequences.
What are the BFSG requirements for web content?
To ensure the accessibility of websites, online shops, apps, and other digital services, businesses must comply with a comprehensive set of guidelines. These requirements are based on the Web Content Accessibility Guidelines (WCAG), the international standard for accessible web content.
WCAG compliance levels
The WCAG define three compliance levels for digital accessibility. These levels indicate how well a website, app, or other digital platform is adapted to the needs of people with disabilities.
- Level A ensures the minimum accessibility requirements. For example, content must be accessible to screen readers, fully operable via keyboard navigation, and free of flashing effects that could trigger seizures. However, Level A only removes the most severe barriers and does not meet the BFSG’s legal requirements.
- Level AA expands on Level A and ensures that digital content is accessible to most people with disabilities. Businesses must implement sufficient color contrast, captioned videos, consistent navigation, and clearly worded error messages. The BFSG mandates compliance with Level AA of WCAG 2.1 as the minimum standard for businesses.
- Level AAA represents the highest level of accessibility, making content fully accessible to nearly all users. It includes very high contrast ratios, live audio descriptions for videos, and simplified language versions of texts. While not legally required, Level AAA is recommended for public institutions.
Accessibility requirements according to WCAG – examples
The WCAG guidelines include an extensive list of requirements, which would go beyond the scope of this blog post. Therefore, we focus on a few key examples, categorized according to the four WCAG principles of accessibility: perceivability, operability, understandability, and robustness.
Perceivability
Digital content must be designed so that users can perceive it, regardless of their sensory abilities. Examples:
- Alternative text for visual elements allows visually impaired users to understand images or photos using a screen reader.
- Flexible font sizes enable users to adjust text to their needs without disrupting the website layout.
- Strong color contrast, especially between text and background, improves readability.
Operability
Users must be able to navigate a website or app, regardless of their motor or cognitive abilities. Examples:
- Platforms must be fully operable via keyboard (without a mouse), ensuring accessibility for people with motor impairments.
- A visible focus indicator for active elements is essential, especially for keyboard navigation, to help users identify their position on a webpage.
- Blinking or flashing effects should be avoided, as they can trigger epileptic seizures or cause discomfort for users with sensory sensitivities.
Understandability
Users must be able to understand digital content, regardless of their cognitive abilities or language skills. Examples:
- Simple and clear language ensures that content is accessible to everyone. Complex technical terms and long sentence structures should be avoided.
- Helpful error messages in forms allow users to quickly identify and fix mistakes. Instead of a generic error like "Error," a specific instruction such as "Please enter a valid email address" should be provided.
- Visual support through icons and pictograms helps users understand content, especially those with learning disabilities or limited language proficiency.
Robustness
Digital content must be compatible with various devices, browsers, and assistive technologies. Examples:
- Valid HTML code and semantic structures are essential for screen readers to correctly interpret and present content in an accessible way.
- ARIA attributes for dynamic content help screen readers recognize and read interactive elements, such as pop-ups or expandable menus.
- Avoiding outdated technologies is crucial, as they often do not meet accessibility standards. Flash content and Java applets, for example, are incompatible with screen readers and should be replaced with modern, accessible web technologies.
Are there grants or financial support?
Financial support: Non-profit organizations can apply for funding from Aktion Mensch to implement accessible websites and other digital services. The state of Schleswig-Holstein has established an accessibility fund, which supports, among others, medical institutions in implementing accessibility measures with external service providers. At the European level, initiatives such as "Digital Europe" may provide funding for accessibility projects. Additionally, small and medium-sized enterprises (SMEs) can benefit from tax incentives. Further funding programs from the EU, federal government, and individual states can be found in the funding database of the Federal Ministry for Economic Affairs.
Resources & knowledge: Further information on the BFSG, such as guides, webinars, and FAQs, is provided by the Federal Accessibility Office, the Federal Government Commissioner for Information Technology, and local Chambers of Commerce and Industry (IHK, e. g. IHK Cologne).
Consulting & support: The Federal Accessibility Office offers initial consultations and answers individual questions. However, the website notes that due to staff shortages, response times may currently be delayed. Companies also have the option to contact the state accessibility offices. For quick support on accessibility, we are happy to assist you.
What penalties apply for non-compliance with the BFSG?
If companies fail to comply with the Accessibility Strengthening Act (BFSG), they risk warnings, fines, and legal action. The severity of the penalty depends on the extent of the violation. Possible consequences include:
- Payment of fines: Companies that do not meet BFSG requirements may face significant financial penalties. Authorities in the respective federal state can impose fines of up to €100,000 if digital products or services are not accessible. Both consumer protection organizations, as well as consumers and competitors, are authorized to report violations.
- Exclusion from public tenders: Non-compliant businesses may be excluded from government or municipal tenders, potentially resulting in substantial revenue losses.
- Reputational damage and customer loss: Beyond legal consequences, violations can also lead to reputational harm. Possible effects include negative reviews, bad press, and customers switching to accessible alternatives.
Companies should act proactively to avoid financial penalties, legal consequences, and damage to their reputation.
Conclusion
The implementation of the BFSG in 2025 marks a significant milestone for equality and inclusion, but it also presents challenges for many businesses. Companies that have not yet addressed the accessibility of their digital services should take action as soon as possible—otherwise, they risk legal consequences.
If you need assistance with accessible websites, apps, online shops, or other digital platforms, feel free to contact us. We offer accessibility audits and take care of the implementation – fully compliant with BFSG requirements. Schedule a free initial consultation today!
