BFSG: Who is affected?

Who is affected by the German BFSG?

The German Barrierefreiheitsstärkungsgesetz (BFSG) is the national implementation of the European Accessibility Act (EU Directive 2019/882). The goal is to enable people with disabilities to participate on an equal footing in economic life by establishing mandatory accessibility requirements for specific products and services.

The Act extends the obligation for accessibility to private businesses that manufacture, import, or distribute specific products, or that provide services to consumers.

B2C businesses (online shops, banks, insurance, telecommunications)

Since 28 June 2025, the digital products and digital services affected by the Act, which are newly placed on the market or provided, must meet the digital accessibility requirements.

The BFSG targets the B2C sector. Affected businesses are those that offer digital services or physical products directly to end consumers. These include:

• Online shops and e-commerce platforms

• Providers of banking services for consumers

• Telecommunication services (e.g., internet access, messenger services)

• Providers of passenger transport services (websites, apps, electronic tickets)

• Distributors of certain digital products such as computers, smartphones, tablets, e-book readers, and interactive self-service terminals (ATMs, ticket machines).

Important transition periods

• Existing products: Products that were already lawfully placed on the market before 28 June 2025 may continue to be made available until 27 June 2030, even if they do not meet the new requirements.

• Service contracts: This transition period also applies to ongoing contracts (e.g., telecommunications, online banking) that were already concluded with consumers before 28 June 2025. After this date, however, these existing contracts must also fulfil the new accessibility requirements with respect to digital access (e.g., the login area, contract management within the app).

• Self-service terminals (like ATMs) that were already in use before the deadline have a longer period. They may continue to be operated until the end of their economic useful life, but no later than 15 years after their commissioning.

B2B providers (software, cloud services, business customer portals)

Services aimed purely at business customers (B2B) are exempt from the BFSG, as long as it is demonstrably not directed at consumers. This applies, for example, to specialised software solutions or business customer portals.

Attention: If a B2B provider, however, distributes products that are named in the BFSG list (e.g., hardware systems), they are obliged as a manufacturer, importer, or dealer to place these products on the market in an accessible way—regardless of whether they sell them to B2B or B2C customers.

Municipalities and public bodies (websites, citizen portals, administrative apps)

For federal public bodies (and through state laws, also for the states and municipalities), the Disability Equality Act (BGG) and the BITV (Accessible Information Technology Ordinance) already apply. The BFSG primarily regulates the duties of private sector actors. Public bodies are therefore obliged to ensure the accessibility of their digital services via other laws.

Associations with digital services (e.g., ticket sales, merchandising)

Associations are generally not directly affected, as long as they do not offer commercial services in electronic commerce with regard to a consumer contract that fall under the named categories.

However, if a sports club operates an online shop for merchandising or a commercial ticket sale via its websites or apps, these offerings count as "services in electronic commerce" and fall under the BFSG—unless the association is a micro-enterprise in the service sector.

Which websites must be accessible?

The obligation for accessibility for websites and mobile apps results under the BFSG from the scope of "services in electronic commerce." This refers to digital services that lead to the conclusion of a consumer contract.

Online shops (product sales, order processes, shopping cart, checkout)

Accessibility in e-commerce covers the entire chain of use that leads to a purchase:

• Product catalogues and displays

• Shopping cart and ordering processes

• Login area and customer portals

• Payment procedures and digital invoices

Service websites (banks, insurance, telecommunications)

Websites of banks, insurance companies, and telecommunication service providers through which customers use digital services (e.g., online banking, contract management, claim reporting) must meet the accessibility standards.

Apps and mobile applications (digital services, administrative apps)

Mobile apps that offer these services or electronic commerce are also affected. This includes, for example, banking apps or the apps of transport providers.

The difference: private sector providers vs. public bodies

While private sector providers are bound by the BFSG to the harmonised European standards such as EN 301 549, based on the Web Content Accessibility Guidelines (WCAG), federal public bodies are bound to the BITV (which is also based on WCAG). As a result, the technical accessibility requirements are very similar, but the BFSG significantly extends the circle of obligated parties to the private sector.

Exemptions and special regulations

The BFSG provides for some exemptions, but these are narrowly defined and only waive the obligation for accessibility in specific cases.

Micro-enterprises in the service sector

The most important exemption concerns micro-enterprises that provide services. A micro-enterprise is defined as a business with fewer than 10 employees and an annual turnover or balance sheet total of no more than 2 million euros.

Disproportionate burden as a reason for exemption

The obligation for accessibility lapses if compliance with the accessibility requirements would lead to a disproportionate burden for the business. This is only the case, however, if the costs would existentially threaten the business or if it is technically impossible.

The hurdles for these exemptions are very high and must be documented in detail by the manufacturer or service provider and reported to the competent market surveillance authority.

Internal systems with no public use

Systems that are used exclusively for the internal processes of the business and have no contact with end consumers (e.g., internal HR software) are not affected by the BFSG.

Why most offerings are still affected

Despite the exemptions, the BFSG affects a large proportion of digital offerings for consumers. The exceptions are narrowly defined. Many adjustments to achieve accessibility according to the common standards (WCAG) are considered proportionate according to the current state of technology and are not regarded as a disproportionate burden. Therefore, most businesses must take action to avoid fines and legal consequences by the market surveillance authorities.

Act now: Accessibility as a strategic opportunity

The BFSG is a huge win for society and the market. It marks an effective step towards the comprehensive inclusion of people with disabilities while simultaneously strengthening consumer protection for everyone.

Conformity with the BFSG is more than just a legal requirement: it’s a strategic opportunity. By making your offerings accessible, you unlock new, attractive customer groups and optimise the user experience for everyone—whether they are seniors, people with temporary limitations, or digital novices. For online retailers, this means specifically: more visibility, fewer abandoned purchases, and higher turnover in the long run.

Accessible websites and apps also improve your SEO ranking and solidify your image as a responsible and innovative business.

Take advantage of this head start: Check your digital offerings for conformity now to fully exploit this enormous potential and secure your competitive advantage!

FAQ

What are the consequences of not implementing the BFSG?

The market surveillance authorities can restrict or prohibit the provision of the product or service. Fines are a threat. Furthermore, consumer protection organisations or competitors can take civil action against breaches.

What benefits does accessibility bring beyond the legal obligation?

You reach a larger target group (people with disabilities, seniors, digital novices), improve user experience (usability), strengthen your brand as a responsible company, and benefit from better Search Engine Optimisation (SEO) by complying with WCAG standards.

Does the Act only apply in Germany or across Europe?

The BFSG implements the European EU Directive (European Accessibility Act, EAA) in Germany. The requirements are thus harmonised across Europe, which creates a more uniform market for traders.

Do micro-enterprises also have to be accessible?

Micro-enterprises (under 10 employees and ≤€2 million turnover/balance sheet total) that provide services (e.g., an online shop) in electronic commerce are exempt from the obligations. However, if they place digital products or consumer devices on the market that fall under the BFSG, they are obliged to comply.

Does the Accessibility Strengthening Act apply to associations?

Yes, but only if an association offers services in electronic commerce (e.g., ticket portals or commercial online shops) with regard to a consumer contract and is not a micro-enterprise.

Are municipalities affected by the BFSG?

Municipalities and public bodies are primarily obliged to ensure accessibility via other laws (BGG, BITV), whose technical standards largely align with those of the BFSG. The BFSG focuses on private economic actors.