Accessibility statement for the German market: what the BFSG requires from companies

You sell to German consumers, so Germany's accessibility law BFSG applies to your service, and part of that duty is publishing information about its accessibility. Search for a template and you will almost certainly find the official model for German public bodies. For a company, that document is wrong: it comes from a different law, addresses authorities, and still leaves your actual duty under § 14 BFSG unfulfilled. This guide explains what the law really requires from private providers, which extra details have proven their worth, where the statement belongs, and which mistakes make life easy for the German authority and for Abmahnungen, the formal warning letters German law firms send on behalf of competitors.

Public body or company: two different duties

Germany has two documents that both sound like an accessibility statement and legally have little in common. Public bodies have published an Erklärung zur Barrierefreiheit, the public sector accessibility declaration, for years. Its legal basis is § 12b of the Disability Equality Act (BGG), and for that document an official template really exists: EU Implementing Decision 2018/1523 lays down the model declaration that authorities must follow. That template is exactly what search engines serve up when you look for a sample.

Private companies play under a different rulebook. For them, the Barrierefreiheitsstärkungsgesetz (BFSG), Germany's implementation of the European Accessibility Act, applies, and its § 14 requires information on the accessibility of the service. No official template exists for it, and no hidden model in a legal annex either. Copy the public sector template and you answer a question nobody asked you, while your own duty stays open. Worse: the copied statement cites legal bases that do not apply to your company, and any inspector notices that within the first minute.

Whether your business falls under the BFSG at all, including the microenterprise exemption, is covered in our guide to Germany's BFSG. This article is about the step after that: the law applies to you, and now the statement needs writing. The good news first: the missing template is not a disadvantage. You can write the statement so it fits your website, instead of managing boilerplate built for ministries.

What § 14 BFSG actually requires

The legal text is surprisingly lean. Service providers must make information on the accessibility of their service available, either in their general terms and conditions (the German AGB) or in another clearly perceivable way. Two things are required in substance: a description of the service itself, and a description of how that service meets the accessibility requirements. You can read the original in the text of the BFSG, in German.

Two formal requirements come on top. First, the information must itself be accessible: a statement embedded as an image, or buried in an inaccessible PDF, formally misses its purpose. Second, it must be kept up to date. The duty does not end with publishing, it starts there.

• The service is described: what your website offers, such as sales, booking or a customer account
• It is described how the accessibility requirements are met
• The information sits in the terms and conditions or in another clearly perceivable place
• The information is itself accessible
• The information is kept up to date and adjusted when things change

How detailed should the description be? The law is silent, so the purpose helps: a consumer should be able to judge, before using the service, whether they can use it without outside help. For an online shop that means the text states that goods can be ordered through the website, and describes how product pages, cart and checkout are made accessible. Three honest paragraphs achieve more here than two pages of legal prose nobody reads.

A side note that saves confusion: in Germany the document is universally called Barrierefreiheitserklärung, accessibility statement, even though § 14 BFSG soberly speaks of information on accessibility. The catchier term has stuck, and we use it here too. What is meant is always your duty under § 14 BFSG, not the public sector document under § 12b BGG.

What belongs in beyond the law: the proven details

The lean legal duty leaves open questions every reader of your statement will ask: tested against which standard? When was it last checked? And what should visitors do who hit a barrier anyway? In practice, a catalogue of details has established itself that goes beyond the letter of the law. To be clear about their status: the following points are recommendations, not legal obligations for companies. But they are what makes the statement credible, and credibility is its whole point.

• State of conformance: fully or partially conformant, and against which standard. The yardstick is EN 301 549, which points to the WCAG at level AA for web content. Our guide to WCAG conformance levels explains what sits behind them.
• Known limitations: an honest list of the content that is not yet accessible, ideally with an outlook on when it will be fixed.
• Creation date and last review: two dates showing that the statement lives and is maintained.
• Feedback channel: an email address or a form through which visitors can report barriers.
• Reference to market surveillance and conciliation: where consumers can turn if their report goes unanswered.

The feedback channel deserves special attention. Whoever answers barrier reports quickly solves problems before they land as complaints at the German market surveillance authority. The statement turns from a compliance document into an early warning system: real users tell you where your website fails, before an authority does.

A structure that has proven itself

1. Description of the service: what the website offers, and for whom
2. State of conformance: tested against EN 301 549 and WCAG 2.2 AA, with the result
3. Non-accessible content: the known limitations, named concretely
4. Creation and last review: both dates visible
5. Feedback and contact: how visitors can report barriers
6. Market surveillance: whom consumers can additionally contact

Where the statement must live

In the terms and conditions or in another clearly perceivable way, says the law, deliberately leaving room. A paragraph in the AGB satisfies the wording. Practice has settled on something else: a dedicated page, linked in the footer of every page, right next to the legal notice and the privacy policy. That is where visitors look first, and where every inspector looks first too. A dedicated page is also easier to maintain, link and update than a clause deep inside your terms.

Clearly perceivable also means, read the other way: not on level three of a help section, not behind a login, and not exclusively as a download. And the page itself must deliver what it describes: clean heading structure, sufficient contrast, plain language, reachable by keyboard. An inaccessible accessibility statement is a punchline you do not want to explain to anyone.

The five most common mistakes

1. Copy-paste conformance: the statement claims conformance although no test ever took place. That surfaces the moment someone holds the website next to it.
2. Adopting the public sector template: the official model under EU Decision 2018/1523 cites legal bases that do not apply to companies. Copying it mainly documents that you do not know the difference.
3. Outdated details after a relaunch: the new design is live, the statement still describes the old website. A test result from 2025 says nothing about today.
4. Statement contradicts the website: claiming full conformance next to a shop full of unlabelled forms. That is the easiest attack surface of all, for the authority as for anyone drafting a warning letter.
5. Hidden or itself inaccessible: the statement exists, but nobody finds it. Or screen readers fail on precisely this page.

The fourth mistake deserves a second look, because it is checked for real. The German market surveillance authority MLBF has been testing actively since January 2026, partly with automated scans; how such an inspection works is covered in our guide to the MLBF. And whoever prepares an Abmahnung compares your statement with the state of your website first: every discrepancy delivers their argument free of charge. What to do when a letter from a German law firm arrives is covered in our guide to BFSG warning letters.

A typical scenario for the third mistake: in spring the shop gets a new theme, the agency delivers on time, everyone is happy. Only the statement in the footer still describes the state before the rebuild, complete with last year's test date. Put the statement on your relaunch checklist, right next to redirects and legal pages. The effort is minimal when it is planned.

Frequently asked questions about the accessibility statement

Of all BFSG duties, the accessibility statement is the quickest one to complete, provided the test behind it exists. Scan, document the state, name the gaps honestly, set the footer link: that is an afternoon, not a project. The statement generator takes the structure off your hands and builds on a real audit of your website, so the text says what is actually true.