Accessibility has been mandatory since June 28, 2025

Since June 28, 2025, digital accessibility has been a legal requirement in Germany. The Accessibility Strengthening Act (BFSG) mandates that companies design digital products and services in a way that everyone can use them. For decision-makers, this raises a concrete question: Which BFSG requirements apply to their own offerings, and by when must they be met?

The law implements the European Directive (EU) 2019/882, the European Accessibility Act (EAA). It defines the characteristics that digital offerings must possess. Technical implementation is guided by the Web Content Accessibility Guidelines (WCAG) and the EN 301 549 standard. Both sets of rules describe how content and applications can be made usable for people with disabilities.

This article outlines these obligations. It explains who is affected by the law, which deadlines apply, and the potential consequences of non-compliance. It concludes with an overview of initial implementation steps. Companies should have specific legal questions reviewed on a case-by-case basis.

Who is affected by the BFSG?

The BFSG applies to digital products and services aimed at consumers. The focus is therefore on the B2C sector. Pure B2B offerings do not fall under the law. Those affected include online shops, apps, banking services, as well as ticket and ATM machines.

Classification depends on the specific offering. Companies considered to be affected by the BFSG should first inventory their own products and services. Exemptions exist for micro-enterprises, but not in every case. In summary, the following applies:

• Micro-enterprises with fewer than ten employees and an annual turnover of no more than 2 million euros are exempt regarding services.
• Micro-enterprises that bring products to market are subject to the BFSG.
• Companies should check on a case-by-case basis whether an exemption applies.

The distinction is not always clear-cut. An offering may contain both product and service components. In such cases, it is worth examining the individual components separately.

An example illustrates the difference. A web shop selling to private individuals falls under the law. Internal software used only by employees does not address consumers and, according to this logic, is not covered. Nevertheless, the classification should be documented based on the specific offering.

What deadlines apply?

The BFSG has been in effect since June 28, 2025. Products brought to market after this date must meet the requirements. Services provided after the deadline are also subject to these regulations. There is no transition period for new offerings. June 28, 2025, is the critical date for the BFSG deadline.

The BFSG obligation therefore applies from the deadline for all new offerings within its scope. Anyone planning or revising an offering should incorporate this date into their project planning early on. An offering brought to market after the deadline must already meet the requirements at that time. Retroactive corrections are often more expensive than an assessment during the design phase.

Transitional rules for existing offerings

Transitional rules apply to existing offerings. Which of these apply depends on when a product was brought to market and when service contracts were concluded. This classification should be legally reviewed. Implementation is also not yet complete at the European level. In March 2026, the EU Commission submitted supplementary comments to Germany. Therefore, it is worth keeping a regular eye on the current legal status.

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Benefits for providers

Digital accessibility affects many people. According to the Federal Government, around 13 million people in Germany are affected by disability or age. An offering that makes usage difficult for them loses potential users. Conversely, an accessible offering expands the reachable target group.

This benefit goes beyond legal requirements. However, it does not guarantee economic success. Whether investments pay off depends on the offering, the market, and the specific implementation. This impact should therefore not be presented as a certainty, but rather verified on a case-by-case basis.

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What exactly does the BFSG require?

The BFSG requirements translate European standards into verifiable features. The WCAG categorizes these requirements into the principles of perceivable, operable, understandable, and robust. Typical examples for digital offerings include:

• Screen reader support for people with visual impairments
• Full keyboard operability without a mouse
• Subtitles and audio descriptions for videos
• High color contrast and alternative text for images
• Compatibility with assistive technology such as braille displays
• Avoidance of flashing content that may pose health risks

This list provides examples. It does not replace an audit of a specific offering. The EN 301 549 standard specifies the technical requirements applicable to products and services. Both sets of regulations form the basis for a verifiable audit.

Key terms explained

A screen reader reads content aloud via speech output or a braille display. For this to work, every button and form field requires a clear label. Alternative text describes an image for people who cannot see it. Keyboard operability means that all functions can be accessed without a mouse, for example, using the Tab key. These terms appear in every audit and can be understood without prior technical knowledge.

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What are the consequences of non-compliance?

Market surveillance authorities monitor compliance with the law. They can take various measures:

• Request for remediation
• Restriction or prohibition of availability
• Recall from the market
• Fines of up to 100,000 euros

The responsible state market surveillance authority handles consumer complaints. They review the complaint and may take action as a result. This means that reports from individual users can trigger an audit process.

Additionally, associations can file lawsuits on behalf of entire user groups. Accessibility therefore concerns not only the quality of an offering but also legal risk. Those who check requirements early can plan for improvements instead of acting under pressure.

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Getting started with implementation

Getting started is a straightforward process. First, companies should identify all digital offerings for consumers. Next, they should check which requirements apply and where gaps exist. Finally, they implement the necessary measures and document their progress. The following sequence provides a helpful guide:

1. Identify offerings: Which digital products and services are aimed at consumers?
2. Check scope: Does the offering fall under the BFSG, and do any exemptions apply?
3. Analyze gaps: Where does the offering deviate from WCAG and EN 301 549 standards?
4. Test with users: How does the offering perform in practice when using assistive technology?
5. Implement and document measures: Who is responsible, and by when?

Documentation helps to track the status of an offering in a transparent way. It shows which requirements have been checked, which gaps remain, and what measures are planned. Companies should consult the text of the law to determine the specific information required by the BFSG.

Responsibilities should be clarified early on. Product managers, developers, designers, and content creators all work on different aspects of the same offering. Without clear accountability, gaps often remain unaddressed. Depending on the offering, individual steps may be shorter or more extensive.

UseTree GmbH supports companies in achieving BFSG compliance. Our range of services extends from consulting and expert reviews to testing with people with disabilities. Additionally, UseTree provides support with conceptualization, implementation, and documentation. You can find an overview on our page Accessibility.

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Conclusion

As of June 28, 2025, the BFSG makes digital accessibility mandatory for many digital offerings aimed at consumers. Whether you are affected depends on the nature of the offering and the size of your company. Deadlines differ for new versus existing offerings. A structured assessment based on WCAG and EN 301 549 is the first step toward implementation. Would you like to have your offering assessed? Request an audit.