With the new Accessibility Strengthening Act 2025, the legislator is sending a clear signal for inclusion and equal opportunities. The Accessibility Strengthening Act (BFSG) enters into force on 28 June 2025 and is intended to ensure the barrier-free use of digitally offered products and services. But what does this law mean concretely for companies and service providers?
In particular, small and medium-sized enterprises that offer services and products online are often uncertain whether they must comply with the requirements of the BFSG 2025 and how they can implement them in practice. In this guide you will learn whether your website is subject to the accessibility obligation from 2025 and what you need to do to meet the statutory requirements.
What is the Accessibility Strengthening Act (BFSG)?
The accessibility requirements for products and services will be regulated from 28 June 2025 by the BFSG Ordinance. The BFSG was passed in Germany in 2021 and aims to improve access to digital products and services for people with disabilities. It implements EU Directive 2019/882 on the accessibility requirements for products and services. Affected companies are therefore obliged to make their website accessible from mid-2025.
Who must implement the BFSG?
The Accessibility Strengthening Act (BFSG) affects all companies that offer digital products or services accessible to the general public. This means that a large number of companies and sectors may fall within the scope of the BFSG. Particularly affected are providers of online shops and online services such as online shops for consumer goods, booking portals, streaming services, banks & insurance companies, telecommunications companies or e-learning platforms.
Exceptions:
Not all companies are obliged to implement the BFSG 2025. Microenterprises with fewer than 10 employees and an annual turnover or annual balance sheet total of less than 2 million euros are exempt from the requirements of the BFSG. This exception is intended to prevent particularly small companies from being disproportionately burdened. Nevertheless, microenterprises can also voluntarily take measures to make their website accessible, as this often leads to a better user experience and a broader customer base.
What requirements does the BFSG impose on online shops and online services?
The requirements of the BFSG are based on the Web Content Accessibility Guidelines (WCAG) 2.1, in particular at conformance level AA. These guidelines provide concrete recommendations on how digital content can be made accessible. The most important requirements can be divided into four main categories:
1. Perceivability
Users must be able to see or hear content. This requires that all visual and acoustic elements are accessible.
Examples of measures:
- Alt texts for images: Every image should have an alternative text description so that people using screen readers can understand what is shown in the image. This is particularly important for product images in an online shop, where the image description can determine whether a customer makes a purchase or not.
- Subtitles and audio descriptions: If you offer videos on your website or in your app, these should be provided with subtitles for people with hearing impairments. For films or videos in which visual information is important (such as in product demos or tutorials), audio descriptions should be provided.
2. Operability
The operation of a website or application must be possible for all users, regardless of the technology or aids they use.
Examples of measures:
- Keyboard operability: All functions of a website or app must be usable with the keyboard without requiring a mouse. People with motor or visual impairments often rely on the keyboard or special input devices.
- Contrasts and visibility: Text should have sufficient contrast with the background to be easily readable. Low contrast ratios make it difficult for people with visual impairments to recognise content.
3. Understandability
Content must be easy to understand. This applies both to the content itself and to navigation on the website.
Examples of measures:
- Plain language: Content should be clearly and precisely formulated so that it can be understood by all users, including people with cognitive impairments.
- Consistent navigation: A consistent and logical structure helps users to navigate the website. Each page should be similarly structured and the same functions should be found in the same place.
4. Robustness
Content must be designed so that it remains accessible even with future technologies and aids. This requires that websites and apps are compatible with assistive technologies such as screen readers or speech recognition software.
Examples of measures:
- Standard-compliant HTML: Using clean, standard-compliant HTML code ensures that web pages can be correctly read and interpreted by different browsers and assistive technologies.
- ARIA labels for interactive elements: Complex interactive elements (such as buttons, forms or menus) should be provided with ARIA labels so that they are recognised and correctly interpreted by assistive technologies.
What penalties threaten if the accessibility obligation is not met?
If the requirements of the BFSG are not complied with and the accessibility obligation is not met, sanctions will threaten from 28 June 2025. These include:
- Complaints: users with disabilities can file complaints if they encounter barriers. Authorities and consumer protection organisations can also take action.
- Fines: significant fines can be imposed for violations. The exact amount depends on the severity of the violation and can generally be avoided if companies take accessibility measures.
How can the requirements of the BFSG 2025 be implemented in practice?
In order to meet the requirements of the BFSG 2025, you should consider the following steps:
- Audit your current website or app for accessibility: use online tools such as WAVE or AXE to carry out an initial analysis. These tools will show you where there are still deficiencies.
- Implement accessible design and programming practices: work with web designers and developers who are familiar with WCAG standards. Pay particular attention to contrast ratios, the use of alternative texts and keyboard operability.
- Offer alternatives: if certain content cannot be made fully accessible (e.g. very complex graphics or interactive content), you should offer alternative means of access, such as explanations in text form or audio descriptions.
- Train your employees: raise your employees' awareness of the topic of accessibility and train in particular those who work on the development and design of your online services.
- Create an accessibility statement: such a statement is mandatory and should be easily accessible on your website. In it, you set out how you are implementing the requirements of the BFSG and what measures you are taking to minimise barriers.
Conclusion on the Accessibility Strengthening Act
Those affected should act in good time!
The implementation of the Accessibility Strengthening Act requires early planning, as many technical and design aspects must be taken into account. The deadline until June 2025 may seem far away, but the earlier you begin implementation, the easier it will be to meet the statutory requirements on time. Companies that make their digital services accessible benefit not only from compliance with legal requirements, but also expand their potential customer base and improve their overall user-friendliness.
Legal support from ab&d Rechtsanwälte:
If you are unsure whether your online shop or service falls within the scope of the BFSG, or need support with implementation, we are happy to assist you as legal experts.
