Germany's BFSG explained: who the law affects and what to do now

Germany's Accessibility Improvement Act, the Barrierefreiheitsstärkungsgesetz (BFSG), has been in force since 28 June 2025, and since early 2026 it is no paper tiger: the responsible market surveillance authority has started work and actively checks whether websites, shops and apps meet the requirements. One point matters especially for readers outside Germany: the law covers everyone offering services to German consumers, including companies selling into Germany from abroad. This guide answers the three deciding questions: who must act, what exactly is required, and what happens when nothing happens.

What the BFSG is and where it comes from

The BFSG is Germany's implementation of the European Accessibility Act, the EU directive of 2019. Its goal: products and services that consumers use in everyday life must also be accessible to people with disabilities. What is new is the addressee. Accessibility used to be a public sector topic in Germany. With the BFSG, the legislator obliges the private sector across the board for the first time.

For websites and apps this means concretely: they must meet the European standard EN 301 549, which points to WCAG conformance level AA. What those levels mean and how to reach them is covered in our dedicated guide. Here we focus on the legal side: scope, exemptions, deadlines and consequences.

Who the BFSG affects

The law lists the covered products and services exhaustively. For the digital world, the most relevant category is e-commerce services, and it is far bigger than it sounds:

• Online shops and booking systems: every website where consumers can buy goods or services, reserve or book appointments. By far the most common case.
• Consumer banking services: online banking, credit applications, payment services.
• Telecommunications: tariffs, contract sign-ups and customer portals.
• Passenger transport: websites and apps for rail, bus, flight and coach tickets.
• E-books and their reading devices plus reading software.
• Self-service terminals: ATMs, ticket machines, check-in kiosks.

The key term is consumer: the BFSG applies as soon as an offer addresses private individuals in Germany. That includes cross-border sales: a French or Italian shop that ships to German consumers falls under the law for that business, no German subsidiary required. A pure B2B manufacturer without any ordering option for private individuals does not fall under it, nor does a plain company business card site without shop, booking or contract closing.

The classic: “but we are B2B”

We hear this often, and it carries less than many hope. As soon as an online shop is technically open to private individuals, meaning there is no effective restriction to business customers, a lot speaks for the law applying. A small-print note saying “trade customers only” hardly suffices when anyone can order with a name and address. Whoever relies on B2B should implement the restriction properly, for example through a mandatory trade credential check.

What the BFSG concretely requires

The technical yardstick is EN 301 549 and with it the WCAG at level AA: perceivable, operable, understandable and robust content, from sufficient contrast and keyboard operation to labelled forms. On top come duties beyond the technology:

• Website or app meets the requirements of EN 301 549 (WCAG 2.1 AA, soon 2.2 AA)
• An accessibility statement publicly documents the state of conformance
• The statement describes the service and how the requirements are met
• Consumers can report barriers through a reachable channel
• Conformance is maintained through changes, not just established once

The accessibility statement is more than a formality: it is the first document an authority or a competitor opens. If it is missing, or obviously contradicts the state of the website, that is the easiest attack surface of all.

Deadlines and transition rules at a glance

The most important takeaway from this table: for websites there is no general grace period until 2030. The transition rule protects old contracts and old machines, not your web presence. Whoever runs a shop open to German consumers must be conformant today.

Who checks, and what violations cost

Responsible is the market surveillance authority of the German states for the accessibility of products and services (MLBF), based in Magdeburg and run jointly by all 16 German states. It works on two tracks: reactive, following up complaints from consumers and associations, and active, testing systematically on its own initiative, partly with automated scans. That is exactly why the common strategy of “we wait until someone complains” has become risky: the authority does not wait for complaints.

The sanctions escalate in stages. It usually starts with a demand to fix within a deadline. If that lapses, the authority can order measures, impose fines of up to 100,000 euros and, in the extreme case, enforce the shutdown of the service in Germany. In parallel runs the civil-law risk: competitors and associations can pursue violations with cease-and-desist letters, and that route is often faster than any authority. Our guide shows what to do after a warning letter (Abmahnung). Plus the quietest damage of all: visitors who fail at barriers simply buy elsewhere.

Five steps to the safe side

1. Clarify coverage: check honestly whether your offer falls under the BFSG: do you sell or broker to German consumers? Does the microenterprise exemption really apply, with both conditions? The BFSG check above takes this assessment off your hands.
2. Measure the status quo: have your website tested automatically against WCAG. The scan shows violations with code locations and produces the work list for the next step.
3. Fix the violations: work through the list by severity, blockers like broken keyboard operation first, then the bulk of contrast, alternative texts and form fields. Think in templates, that repairs many pages at once.
4. Publish the accessibility statement: document the state, name known gaps honestly and offer a reporting channel. Link the statement in the footer, that is where it is expected.
5. Keep at it: every update can introduce new barriers. A regular automated check makes sure the state you reached is the state that stays.

Frequently asked questions about the BFSG

The BFSG has been binding law since 2025 and actively enforced since 2026. The question is no longer whether accessibility becomes mandatory for the German market, only whether you act before or after the first inspection. The check above takes two minutes, the answer is yours.