Accessible website: what the BFSG means for companies.
Since 28 June 2025, digital accessibility under the BFSG is mandatory for many companies. Who is affected, the micro-enterprise exemption, what WCAG 2.1 AA concretely means, a checklist, fines, and why overlay tools do not solve the problem. As orientation, not legal advice.

Since 28 June 2025, the Barrierefreiheitsstärkungsgesetz (BFSG) applies in Germany. It implements the European Accessibility Act and makes digital accessibility mandatory for many companies - with fines for violations.
Many are unsure: does this affect me? What exactly do I have to do? This article explains who is affected, what accessibility means technically, and why it pays off even where it is not strictly required.
Key takeaways
- The German Accessibility Reinforcement Act (BFSG) applies since 28 June 2025. It transposes the EU European Accessibility Act (EAA) into German law.
- Affected are websites with services in electronic commerce: online shops, but also sites with booking, cart, or a direct contract. Pure presentation pages without interaction usually do not fall under it.
- Micro-enterprises with fewer than 10 employees and at most 2 million euros in annual turnover or balance sheet total are exempt. This is orientation, not legal advice.
- The technical benchmark is WCAG 2.1 at level AA, via the EN 301 549 standard. Four principles: perceivable, operable, understandable, robust (POUR).
- Violations can trigger fines of up to 100,000 euros and competition-law warnings. According to authorities, overlay tools do not create legally sound accessibility. The cheapest path is to build accessibility in from the start instead of retrofitting it.
What does an accessible website mean?
A website is accessible when people with disabilities can use it just like everyone else: navigate, read, fill out forms, book appointments, buy. Nobody may be excluded because of a disability. Concretely this affects people with visual or hearing impairments, motor or cognitive limitations, but also older people and situations like bright sunlight or an injured hand. Accessibility ends up helping everyone.
In Germany around 7.8 million people have a severe disability, about 9.4 percent of the population. Add lighter and temporary limitations and the share is significantly higher. For you as a company that means two things: there is a growing legal obligation, and there is a large user group you otherwise lose before they even reach you.
What is the BFSG and since when does it apply?
The Accessibility Reinforcement Act (BFSG) has been in force since 28 June 2025. It transposes the European Accessibility Act (EAA, EU Directive 2019/882) into German law. The technical detail sits in the BFSG ordinance (BFSGV), which points to the European standard EN 301 549 and thereby to the WCAG. In short: the EAA sets the European goal, the BFSG turns it into a German obligation, the BFSGV and EN 301 549 say how it has to look technically.
Two dates matter. Since 28 June 2025, newly provided services must be accessible. For certain existing contracts and products there are transition periods: services provided with products deployed before the cutoff may continue at most until 27 June 2030, self-service terminals even until 2040 at the latest. For your website itself the core rule is: it should be accessible now.
Honestly placed: the BFSG is deliberately open in some spots. Where exactly the line runs and how strictly it is checked will only become clear through administrative and court decisions. Treat this article as well-founded orientation, not legal advice. When in doubt, a specialized lawyer reviews your specific case.
Who is affected and who is not?
The decisive term is service in electronic commerce. You are affected when consumers can conclude a contract on your website or take essential steps toward one. A classic online shop is clearly covered. But even without a shop system your site can be affected as soon as it is more than a pure business card.
What matters is interaction. This table shows the typical cases:
Is your website affected by the BFSG?
| Case | BFSG affected? |
|---|---|
| Online shop, cart, purchase | Yes, clear case |
| Online booking or reservation | Yes, essential step toward a contract |
| Pure presentation page (info only, no conclusion) | Usually no |
| Blog without interaction or purchase option | Usually no |
| Newsletter sign-up without e-commerce | As a rule no |
| Careers / application page | No, no consumer contract |
| Micro-enterprise (under 10 staff and max. 2 million euros) | Exempt |
The micro-enterprise exemption
Micro-enterprises are exempt from the BFSG. You count as a micro-enterprise if you employ fewer than 10 people and have an annual turnover or balance sheet total of at most 2 million euros. Both conditions must be met together: if you employ 10 or more people, the exemption does not apply, no matter how small the turnover.
An important addition that is often overlooked: the exemption applies to services. For products (such as selling certain hardware) the situation can differ. And even those who are not obliged benefit from accessibility, through more reachable customers, better usability, and a stronger SEO foundation. The obligation is the trigger, the benefit remains even without it.
What does accessible mean technically? The four WCAG principles
The technical benchmark is WCAG 2.1 (Web Content Accessibility Guidelines) at conformance level AA. The WCAG is published by the World Wide Web Consortium (W3C) and is the international standard. There are three levels: A (foundation), AA (the level required by most legal rules), and AAA (highest level, often impractical). For the BFSG, AA is the relevant target.
Behind it stand four principles, POUR in English: perceivable, operable, understandable, robust. Every concrete measure maps to one of these four.
Perceivable
All information must be perceivable, no matter through which sense. Concretely: alternative text (alt text) for all informative images so screen readers can read out the content. Captions for videos and audio description where needed. Sufficient color contrast, at least 4.5:1 for normal text and 3:1 for large text. And: color must never be the only information, an error for instance must be recognizable without red too. Text must zoom to 200 percent without content getting lost.
Operable
The entire website must be operable with the keyboard alone, without a mouse. This is the single most important check there is: can you get through all links, buttons, and form fields with the Tab key and back out again? It must always be visible which element currently has focus. Avoid time limits that pressure users, and avoid blinking or flickering effects that can trigger epileptic seizures.
Understandable
Content and operation must be understandable. Use clear, plain language, explain technical terms, and avoid nested sentences. A clean heading hierarchy (one H1, then H2, H3 in the right order) helps not only screen readers but also SEO. Form fields need clear, linked labels and understandable error messages that say what to do. Navigation should be the same and predictable across all pages.
Robust
The website must be robust enough that it is reliably interpreted by different browsers, devices, and assistive technologies. The foundation is clean, semantic HTML: real buttons instead of clicked divs, correct lists and tables, ARIA attributes used sensibly where HTML alone is not enough. That lets screen readers and braille displays read out your content without errors, today and with future assistive tools.
Measures and checks at a glance
This checklist bundles the concrete measures from the four principles with the quick tests you can use to roughly check them yourself. It does not replace a full BITV test, but it gives you a realistic picture fast.
Accessibility checklist with quick test
| Measure | How you check it |
|---|---|
| Alt text for all informative images | Check with WAVE or axe DevTools; decorative images get an empty alt attribute |
| Keyboard operability | Tab through the whole page only; focus must always be visible |
| Color contrast 4.5:1 (normal) / 3:1 (large) | Colour Contrast Analyzer or WAVE |
| 200 percent zoom without content loss | Zoom in the browser and check the layout |
| Clean heading hierarchy (one H1, then H2/H3) | Browser devtools or WAVE structure view |
| Linked form labels and clear error messages | axe DevTools; fill fields without a mouse |
| Meaningful link text (no "here", "more") | Read link texts one by one: clear without context? |
| Captions for videos | Check every video for captions |
| Accessible mandatory info per BFSG | Provide the Annex 3 info e.g. in the footer |
Overlay tools: why they do not solve the problem
Overlay tools are widgets loaded onto a website via script that offer users a toolbar to adjust contrast, font size, or a read-aloud function. They are often sold as a quick one-click solution. The reality is more sobering.
The federal and state monitoring bodies for accessibility (BFIT-Bund) are clear: such software solutions are currently not able to render a web presence fully accessible. Worse, overlays can even create new barriers and clash with assistive technologies like screen readers. An overlay masks symptoms but does not fix the causes in the code.
Hence our clear stance: an overlay is not a legally sound substitute for real accessibility. Whoever just installs a widget spends money and stays vulnerable anyway. The only reliable path runs through the code itself.
What happens in case of violations?
Enforcement lies with the market surveillance authorities of the federal states. They can check websites, flag defects, and impose fines. Depending on the severity, these range up to 10,000 euros (for example for missing information or documentation gaps) and up to 100,000 euros for serious violations.
On top comes a second risk that is often underestimated: competitors can issue a warning over missing accessibility as an unfair-competition violation under the UWG. That can get expensive faster than an official fine. For 2026 it is emerging that the initial restraint is fading and both checks and warnings are increasing. Whoever acts now is on the safe side.
Why you should build accessibility in from the start
The most expensive route to accessibility is the retrofit. When structure, contrast, focus order, and semantic HTML are only fixed at the end, every correction becomes a special project, and the result often stays patchwork. If accessibility is thought about from the first concept sketch instead, it costs almost no premium and falls out almost by itself.
That is exactly how we work at INSYNC. Accessibility is not an afterthought checkbox for us but part of the build method: semantic HTML, clean heading structure, sufficient contrast, full keyboard operability, and tested forms are standard, not an add-on package. The nice side effect: the same measures that make your site accessible also strengthen performance, usability, and your SEO and GEO foundation, because both search engines and AI systems prefer cleanly structured content.
And if you rebuild an existing site: a relaunch is the ideal moment to bring accessibility in properly, without losing your rankings. That is not a contradiction but good sequencing.
Frequently asked questions
A website is accessible when people with disabilities can use it just like everyone else: navigate, read, fill out forms, book, and buy. The technical benchmark is WCAG 2.1 at level AA with the four principles perceivable, operable, understandable, and robust.
The Accessibility Reinforcement Act applies since 28 June 2025. It transposes the European Accessibility Act (EAA) into German law. For certain existing contracts and products there are transition periods until 27 June 2030 at the latest, and for self-service terminals until 2040 at most.
Affected are providers of services in electronic commerce, meaning online shops and pages with booking, cart, or direct contract conclusion. Pure presentation pages without interaction usually do not fall under it. Micro-enterprises with fewer than 10 employees and at most 2 million euros in turnover or balance sheet total are exempt. This is orientation, not legal advice.
Depending on the severity, fines range up to 10,000 euros or up to 100,000 euros. On top come possible competition-law warnings from competitors under the UWG, which can quickly get expensive on their own.
No. The federal and state monitoring bodies make clear that overlay tools currently do not make a website fully accessible and can even create new barriers. Real accessibility comes from the code, not from a bolted-on widget.
For a first impression, free tools like WAVE, axe DevTools, and the Colour Contrast Analyzer help, along with manual tests: operate the page with the keyboard only and zoom to 200 percent. For a robust, law-compliant assessment, the free BIK-BITV test maps the checks from EN 301 549 and WCAG.
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