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Accessibility Strengthening Act (BFSG) Guide

The BFSG makes digital accessibility a legal requirement for many businesses operating in Germany. It is no longer optional website hygiene.

This guide explains who is affected, what standards apply, what the risks are, and how to implement accessibility efficiently with an accessibility-by-design approach.

Ethel
Project & Communications Manager
Updated:

Practical compliance for digital products and services

From scope and exemptions to implementation: what teams need to do now to reduce legal risk and improve user experience.

Why BFSG Matters Now

The BFSG implements the European Accessibility Act in Germany and applies to many products and services offered to consumers. For affected companies, accessibility becomes a compliance topic with direct operational and legal consequences.

Compliance is typically demonstrated via harmonized standards, especially EN 301 549 and WCAG 2.1 Level AA. For most teams, this means upgrading design systems, frontends, forms, and critical transaction flows.

„Accessibility is not only a legal duty. It is product quality, risk management, and market access.” — Laramate GmbH
June 28, 2025
Main BFSG obligations apply for in-scope offerings to consumers in Germany.
WCAG 2.1 AA
Key technical benchmark used in practice via EN 301 549 for implementation and audits.
Up to EUR 100,000
Potential fine per violation, plus additional legal and reputational exposure.

The Four Accessibility Principles (POUR)

Perceivable

Users must be able to perceive content with different senses and assistive technologies (for example screen readers, captions, and sufficient contrast).

Operable

Interfaces must work without a mouse and support keyboard, focus management, and predictable interaction patterns.

Understandable

Language, navigation, and feedback should be clear and consistent so users can complete tasks without confusion.

Robust

Code should remain compatible across browsers, devices, and assistive technologies over time.

Who Is Typically Affected

E-commerce and booking

Online shops and booking platforms with consumer-facing checkout and account flows.

Financial services

Digital banking and related customer services with high reliance on accessible user journeys.

Mobility and transport

Ticketing, travel information, and connected digital services used by end consumers.

Media and digital products

Streaming and software-driven offerings where accessible interaction is required for core functions.

In practice, regulators and courts focus heavily on critical user paths: registration, login, checkout, and other high-impact flows.

Implementation Plan for Teams

  1. Run a focused accessibility audit to identify priority gaps against WCAG 2.1 AA on critical user paths.

  2. Fix design-system and frontend foundations (contrast, semantics, keyboard navigation, form errors, focus states).

  3. Embed accessibility into delivery with QA checks, review criteria, and editor/developer training.

Important note: this article is practical guidance and not legal advice. Assess your concrete obligations with legal counsel for your specific business model.

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