BFSG 2025: Who Is Affected, What's at Stake – and Which Exemptions Apply

Since June 28, 2025, Germany’s Accessibility Strengthening Act – the Barrierefreiheitsstärkungsgesetz (BFSG) – has been in force. It requires providers of certain consumer-facing products and services to make their digital offerings accessible – the benchmark being WCAG 2.1 Level AA and the European standard EN 301 549. If you run an online shop, a booking platform, or a banking feature for end customers and don’t qualify as an exempt micro-enterprise, your website or app must be accessible. Otherwise you face regulatory orders, fines, and cease-and-desist letters.

TL;DR

• The BFSG transposes the EU’s European Accessibility Act (EAA, 2019/882) into German law and has applied since June 28, 2025.
• It primarily affects B2C providers in categories such as e-commerce, banking/payments, telecommunications, passenger transport booking, e-books, and certain hardware.
• Micro-enterprises (fewer than 10 employees and no more than €2 million annual turnover) are exempt for services – but not for products.
• The benchmark is WCAG 2.1 AA / EN 301 549; violations can mean fines of up to €100,000, an outright ban of the offering, and cease-and-desist letters.
• Accessibility is both an obligation and an advantage: better UX, wider reach, and a cleaner, faster, more discoverable web presence.

What is the BFSG, exactly?

The Accessibility Strengthening Act is Germany’s implementation of the European Accessibility Act, an EU-wide directive. The goal: people with disabilities should be able to use the same digital offerings as everyone else – independently, without outside help. In practice that means a website must be operable with the keyboard, readable by a screen reader, offer sufficient contrast, and remain usable when zoomed in.

One important distinction: don’t confuse the BFSG with the BITV, Germany’s longstanding accessibility ordinance for public-sector bodies. The BFSG is the first law to impose broad accessibility obligations on private companies.

Who is affected?

The law targets products and services aimed at consumers (B2C). The most important affected categories:

• Online shops and e-commerce (selling goods or services to end customers)
• Consumer banking and payment services
• Telecommunications services
• Passenger transport with digital booking/ticketing (rail, bus, air, ferry)
• E-books and the software to read them
• Certain hardware: computers, smartphones, payment and self-service terminals, ATMs, ticket machines

If your digital offering falls into one of these categories and is aimed at end customers, it’s in scope – regardless of whether you see yourself as a “tech company” or “just run a shop.”

Which exemptions apply?

This is where it gets important, because this is where most misunderstandings arise.

1. Micro-enterprises – but only for services. Companies with fewer than 10 employees and no more than €2 million in annual turnover (or balance sheet total) are exempt from the obligations if they provide services. That’s the famous “micro-enterprise exemption.” Careful: the threshold is an and, not an or – you must meet both criteria to count as a micro-enterprise.

2. The exemption does not apply to products. If you manufacture or distribute physical products covered by the law (e.g. devices, terminals), you’re in scope even as a very small company. The micro-enterprise exemption explicitly applies to services only.

3. Pure B2B is usually out of scope. If your offering is aimed exclusively at businesses and not at consumers, it’s generally not covered by the BFSG. But as soon as end customers can buy or book too, you’re in scope.

4. Disproportionate burden / fundamental alteration. The law provides narrowly defined exceptions where accessibility would impose a disproportionate burden or fundamentally alter the product. This is not a free pass, though: you have to document and justify it, and the bar is high.

When in doubt: making your site accessible is almost always cheaper than litigating over whether you should have.

Which standard applies – and what does it mean technically?

The benchmark is WCAG 2.1 Level AA and the harmonized European standard EN 301 549. Meet those, and you’re considered accessible within the meaning of the law. In practice, that comes down to:

• Keyboard operability: everything reachable and usable without a mouse, with a visible focus indicator.
• Screen reader compatibility: semantic HTML, meaningful headings, text alternatives for images.
• Contrast: at least 4.5:1 for normal text; meaning never conveyed by color alone.
• Scalability: usable at up to 200% zoom without content being cut off.
• Forms: real labels, clear error messages, helpful guidance.

We’ve condensed these points into a compact BFSG/WCAG checklist you can work through item by item.

What happens in case of violations?

Market surveillance is handled by Germany’s federal states. The authorities can act on complaints, order remediation, and in extreme cases ban the offering altogether. Fines of up to €100,000 are possible. At least as relevant in practice: cease-and-desist letters from competitors and consumer associations. The first waves have been rolling since the law took effect – and a cease-and-desist letter costs time and money even if all you end up doing is “just” fixing the issues.

What should you do now?

1. Determine whether you’re in scope. Is your offering aimed at consumers? Does it fall into a BFSG category? Are you an exempt micro-enterprise? Our free BFSG quick check gives you an initial assessment in four questions.
2. Audit your status. An audit combining automated tests (e.g. axe-core) with a manual keyboard and screen reader walkthrough shows where you stand.
3. Fix by priority. The highest-impact fixes first: keyboard, contrast, forms, structure.
4. Document compliance. Re-test and publish an accessibility statement.
5. Stay on it. New content and features must remain compliant – ideally with checks built into your development workflow.

An obligation – and a genuine advantage

Accessibility is more than risk avoidance. Accessible sites are technically cleaner, faster, and easier to parse for search engines and AI answer engines alike. You reach more people, lower your bounce rate, and improve conversion. Get it right now, and you don’t just comply with the law – you build a better product.

Not sure whether or how much the BFSG applies to you? Take the quick check or email us at info@rocket-monkeys.com for a no-obligation initial consultation.

This article is for general information purposes and is not legal advice. Whether the law applies to you depends on your specific circumstances.