BFSG 2025: Does My Website Have to Be Accessible?

Since 28 June 2025, Germany's Accessibility Strengthening Act (Barrierefreiheitsstaerkungsgesetz, BFSG) has been in force. It transposes the European Accessibility Act (EAA) into German law. Ever since, half-truths have been doing the rounds: some claim every website now has to be accessible, others insist nobody is checking anyway. Both are wrong. Here you'll find an honest assessment of whether the obligation applies to you, by when, and what you should actually do about it.

What is the BFSG actually about?

The BFSG requires providers of certain products and services to offer them in an accessible form. Unlike the longer-standing rules for public bodies (BITV 2.0), the BFSG is aimed primarily at private companies. Under the law, a website or app counts as accessible when it is perceivable, operable, understandable and robust - in other words, when it remains usable for people with visual, hearing, motor or cognitive impairments too.

Who is affected - and who isn't?

The BFSG doesn't apply across the board to every website. You're mainly affected if you offer electronic services in consumer business (B2C). This includes, for example:

• Online shops and e-commerce with ordering and payment functions
• Banking and payment services, account opening, online banking
• Booking and ticketing systems for passenger transport (rail, bus, air)
• Telecommunications services and messengers
• certain e-book offerings and streaming services

A plain company brochure website with no shop, no online contract conclusion and no interactive service often does not fall directly under the BFSG. That's the honest answer you rarely hear: if your website only presents what you do and has a contact form, you're frequently not strictly obliged to act.

The exemption for micro-enterprises

Important: for services, there is an exemption for micro-enterprises. These are businesses with fewer than 10 employees and an annual turnover or annual balance sheet total of no more than 2 million euros. If you provide a service and stay below these thresholds, you are exempt from the obligation.

But beware a common misconception: this exemption applies only to services, not to products. Anyone who manufactures or places physical or digital products on the market cannot invoke the micro-enterprise rule. When in doubt, you should have it checked carefully whether your offering qualifies legally as a product or a service.

What deadlines apply?

The key date was 28 June 2025 - the law has been in force since then. For service contracts concluded before that cut-off, there is a transition period until 28 June 2030. So anyone with existing contracts covering self-service terminals or similar systems gets a little breathing room. But there is no such grace period for new websites and services. If you're affected, the obligation applies now.

What happens if you breach it?

Market surveillance falls to the federal states. Breaches can lead to orders to make corrections and, in the worst case, a ban on the service and fines of up to 100,000 euros. At least as relevant is what happens in practice: associations and competitors can issue warnings, and a website that isn't accessible simply costs you customers who can't place an order.

What do you actually have to do?

The practical benchmark is WCAG 2.1 at Level AA, technically anchored in the EN 301 549 standard. That sounds dry, but it boils down to clear, tangible points:

• Sufficient contrast between text and background
• Alt text for images and meaningful labels for form fields
• Full keyboard operability - everything must be reachable without a mouse
• Clean HTML semantics and a correct heading structure so that screen readers work
• an accessibility statement with a way to give feedback

An honest note: so-called overlay tools (an embedded script that supposedly makes everything accessible automatically) usually don't solve the problem and are heavily criticised by experts. Genuine accessibility is built into the code and the design, not bolted on afterwards as a plugin.

How to check your status

Before you pour money into a rebuild, an honest stocktake pays off. An automated scan already uncovers some of the issues - missing alt text, weak contrast or broken structures, for instance. That's exactly why we run an accessibility scanner ourselves, as one of seven of our own brands in production. A scan is no substitute for a full manual review, but it gives you a solid basis for deciding whether and how urgently you need to act.

The honest summary

Not every website has to become accessible because of the BFSG. You're mainly affected if you run B2C online shops and digital services - unless you qualify as a micro-enterprise under the services exemption. If you are affected, the obligation has applied since 28 June 2025 with no grace period. And even if you're formally not required to: an accessible website is technically cleaner, easier to find on Google and usable by more people. That pays off regardless of the law.