Since June 28, 2025, the German Accessibility Strengthening Act (Barrierefreiheitsstaerkungsgesetz, BFSG) has been in effect. For many businesses, this means their website must be accessible -- or face significant fines. But what exactly does the law require? Who is affected? And how do you implement the requirements technically and visually without rebuilding your entire web project? This guide gives you the answers.
What Is the BFSG and Why Does It Exist?
The BFSG transposes EU Directive 2019/882 (European Accessibility Act) into German law. It requires businesses to make digital products and services accessible. Specifically: websites and mobile applications must be usable by people with disabilities -- regardless of the type of impairment.
In Germany alone, this affects approximately 7.8 million people with severe disabilities and millions more with temporary or situational impairments. Accessibility is not a niche topic -- it concerns a significant portion of your potential customers.
Who Is Affected by the BFSG?
The law applies to businesses offering digital products or services. Specifically affected are:
- E-commerce: Online shops, booking platforms, comparison portals
- Services: Online forms, contact forms, appointment booking systems
- Banking: Online banking, payment services, financial apps
- Telecommunications: Websites of telecom providers
- Media: E-books, streaming platforms, digital media offerings
Who Is Exempt?
There are two important exceptions:
- Micro-enterprises: Fewer than 10 employees AND less than 2 million euros in annual revenue
- Disproportionate burden: If implementation demonstrably constitutes a disproportionate burden (though this is difficult to prove)
Note: Even if you fall under the exemption, we strongly recommend implementing accessibility. It improves the user experience for all visitors and strengthens your SEO position.
Which Standards Apply?
The BFSG references two central standards:
WCAG 2.2 (Web Content Accessibility Guidelines)
The W3C's WCAG 2.2 are the international gold standard for web accessibility. They define three conformance levels:
- Level A: Basic accessibility (minimum)
- Level AA: Standard accessibility (required by the BFSG)
- Level AAA: Highest accessibility (not legally required, but recommended)
EN 301 549
The European standard EN 301 549 specifies requirements for digital products and services. For web content, it largely references WCAG 2.2 Level AA but adds specific requirements for software, hardware, and documentation.
Practical Checklist: The Most Important Measures
Here are the concrete steps to make your website WCAG 2.2 Level AA compliant:
Perceivability
- Text alternatives: Every image needs a meaningful alt text. Decorative images receive an empty alt attribute
- Captions and audio description: Videos need captions, ideally also audio description
- Contrast: At least 4.5:1 for normal text, 3:1 for large text (18px bold or 24px regular and above)
- Zoomability: The page must be zoomable to 200% without information loss
Operability
- Keyboard navigation: All interactive elements must be reachable and operable via keyboard
- Focus management: Visible focus indicators for all interactive elements
- Sufficient time: Animations and automatic redirects must be pausable
- Skip links: A link at the top of the page that jumps directly to the main content
Understandability
- Declare language: The lang attribute in HTML must be correctly set
- Consistent navigation: Navigation must be structured identically on all pages
- Error messages: Forms must provide understandable error messages and correction suggestions
- Labels: Every form field needs a visible, associated label
Robustness
- Semantic HTML: Use native HTML elements instead of div soups with ARIA roles
- Use ARIA correctly: Use ARIA only as a supplement, never as a replacement for semantic HTML
- Validation: HTML code must be valid and free of parser errors
What Happens with Violations?
The market surveillance authorities of the federal states are responsible for enforcement. Violations can result in:
- Fines: Up to 100,000 euros per violation
- Cease-and-desist letters: Competitors and consumer protection organizations can issue warnings
- Injunctions: Courts can prohibit the operation of non-accessible offerings
The authorities have announced they will initially focus on education rather than punishment. But do not count on that lasting forever. Experience from other EU countries shows: enforcement becomes stricter over time.
The ROI of Accessibility
Accessibility is not just a legal obligation -- it is a business advantage:
- Larger audience: You reach millions of additional users
- Better SEO: Accessible websites demonstrably rank better. Google positively evaluates semantic HTML, alt texts, and page structure
- Higher conversion rates: Clearer structures and better usability lead to more completions
- Legal certainty: You avoid fines and warnings
- Brand image: You position yourself as an inclusive, responsible company
How to Approach Implementation
- Conduct an audit: Test your website with automated tools (Lighthouse, axe) and manual tests (keyboard navigation, screen readers)
- Set priorities: Fix the most severe barriers first -- missing alt texts, insufficient contrast, missing keyboard navigation
- Implement incrementally: You do not have to do everything at once. Start with the most visited pages
- Test with real users: Automated tests find only about 30% of barriers. Have people with disabilities test your website
- Publish an accessibility statement: The BFSG requires a public statement on the status of accessibility
Accessibility is not a one-time project but an ongoing process. Integrate it into your development workflows, train your team, and make it a fixed part of every deployment.
