ACCESSIBILITY STRENGTHENING ACT

Businesses: Web Accessibility For All

The Accessibility Strengthening Act (BFSG) is now here!

Germany is at a turning point in the digital economy. The law, which transposes the European Accessibility Act (EAA) into national law, defines access to digital products and services as a legal obligation and sets clear requirements for the accessible design of products and services. In principle, this applies to all companies that offer digital products and services to consumers in Germany – not limited to German companies, but also foreign organizations and institutions with business activities in Germany. 

Constraint? Not at all!

In essence, the BFSG strengthens the rights of 7.8 million people with disabilities, and at the same time, offers companies the opportunity to expand their addressable market, secure their future viability and improve user experience.

What is the legal basis for BFSG?

The BFSG is the national implementation of the European Directive EAA 2019. It creates binding minimum requirements for all economic operators in Germany based on internationally established technical standards that companies must demonstrate compliance with. Compliance in this case with the harmonised standard EN 301 549 is mandatory. This entails guidelines under the Web Content Accessibility Guidelines (WCAG 2.1), in particular, conformity level AA – decisive for technical implementation. EN 301 549 is essentially based on these World Wide Web Consortium (W3C) guidelines, making the WCAG the gold standard for compliance with BFSG requirements worldwide.

So, what are these general accessibility binding requirements?

Per the guidelines, digital content must be designed with the following guidelines in mind.

Scope of application: Products, services and compliance obligations

As of June 28, 2025, the BFSG applies to all economic operators offering products or services to end consumers on the German market.

Affected products (hardware & software)

• Everyday hardware: computers, notebooks, tablets, smartphones, routers and modems.

• Specialized devices: smart TVs with internet access and e-book readers.

• End customer terminals: cash machines, ticket machines and check-in terminals.

• Software and content: operating systems, application software and digital content such as e-books.

• New categories: modern consumer technology such as voice assistants and certain wearables are also covered by the obligation if they meet the criteria of the BFSG.

Affected services (digital offerings)

• E-commerce & booking: online shops and digital booking platforms.

• Financial services: banking services, especially online banking.

• Communication: telecommunications services and related apps.

• Mobility: Transport services, including ticket booking and timetable information.

• Media: Streaming platforms and other media services with audiovisual content.

When implementing accessibility, the main focus is on critical user paths. These are the essential processes that are indispensable for the primary purpose of the application. Companies must ensure that processes such as purchasing, registration and login are completely accessible in order to minimize legal risk.

Exceptions and borderline cases: When the BFSG does not apply

Although compliance with the BFSG is far-reaching, the law defines clear exemptions depending on company size or business model.

1. Micro-businesses that offer services are exempt if the following two criteria are cumulatively met:

• The company employs fewer than 10 employees (full-time equivalents), and

• The company has either an annual turnover or an annual balance sheet total of less than  € 2 million.

Important: This exemption applies exclusively to services. Products must always be BFSG-compliant.

2. B2B services & internal tools

Offers that are not intended for end consumers are exempt from the regulations:

• Pure B2B services: All services that are exclusively aimed at other companies.

• Internal applications: Internal IT tools, intranets or management software that are not publicly accessible.

Non-compliance risks: What happens if the BFSG is disregarded?

Disregarding the BFSG poses three key risks for companies:

1. Fines and sanctions: In the event of a violation, fines of up to €100,000 per violation may be imposed. In the case of serious deficiencies, a ban on marketing may be imposed.

2. Risk of civil law warnings: Recognized disability associations are granted the right to take collective action. Similar to the wave of warnings following the introduction of the GDPR, this creates an immediate legal target, resulting in high legal and court costs.

3. Reputational damage and market loss: Businesses that ignore digital inclusion risk reputational damage. Public lawsuits for discrimination lead to a massive loss of trust and deny access to the purchasing power of people with disabilities.

Experience shows that retrofitting is always more expensive and time-consuming than correct initial development.

Through the consistent application of the ‘accessibility by design’ principle, accessibility should be systematically taken into account as early as the conception and design phase.

This minimizes the effort required for subsequent code adjustments and reduces development costs over the product's life cycle.

As a business operating in Germany, what should you do? 

Comply, or be compelled!

Accessibility is future-proof in your company's long-term market positioning and competitiveness. Hence, a clearly structured plan is crucial for achieving compliance quickly and efficiently. At Laramate GmbH, we support you with a three-step process:

• Assessment (quick audit): We start with a gap analysis of your digital offerings based on WCAG 2.1 (Level AA) to identify the most significant and urgent deficiencies (alt text, contrast, focus states).

• Process change (‘shift left’): Next we integrate accessibility into your development from the outset (accessibility by design) instead of just retrofitting it at great expense.

• Organization and training: We assign internal responsibilities and train your editors and development teams for long-term compliance with the BFSG.