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20.03.2025

New law:
Digital accessibility from June 2025

Around 20% of internet users in Germany have a mild to severe impairment – this not only affects people with a recognized severe disability, but also many with impaired vision, motor or cognitive challenges. However, the digital world should be accessible to everyone.

This is precisely where the Barrierefreiheitsstärkungsgesetz (BFSG), which comes into force on June 28, 2025, comes in. It transposes the EU directive of the European Accessibility Act (EAA) into German law and obliges companies to make their websites, apps and online stores accessible so that everyone can participate in online services. Very important: digital accessibility will soon not only be a legal obligation, but also a great opportunity for companies today. It improves the user experience for a broad target group, makes digital services accessible to everyone and can significantly increase reach and customer loyalty.

But what exactly does the BFSG entail? Which companies are affected? We help you to implement digital accessibility efficiently and in compliance with the law – from an initial brief check of your website to the complete implementation of accessible solutions or individual advice on funding opportunities. It’s best to make an appointment now.

 

Table of contents

 

The most important facts about the BFSG
Scope of application: The Accessibility Improvement Act (BFSG) applies to companies that offer products and services in Germany. In particular, manufacturers, importers and retailers of products such as smartphones, tablets, computers, vending machines and e-book readers as well as providers of services such as online stores, banking services, telecommunications services or ticket booking systems are affected. Companies must ensure that their products and digital services are designed to be accessible . For example, the ability to book an appointment on a website already counts as an electronic service and is therefore covered by the BFSG.

However, the law does not only affect German companies or websites based in Germany. Foreign companies that provide digital services in German and thus target the German market are also subject to the regulations of the BFSG. This means, for example, that an international online store or a provider of apps in German is also obliged to comply with the accessibility requirements.

Micro-enterprises with fewer than 10 employees and an annual turnover of no more than EUR 2 million are exempt, unless they offer directly affected products or services.

Accordingly, many medium-sized and larger companies are obliged to implement the BFSG for their websites, apps, products and services – it is therefore worth dealing with the requirements in good time.

 

Who checks?
The market surveillance authorities of the federal states check whether companies are complying with the requirements of the BFSG on a random basis or in the event of complaints. For Baden-Württemberg, this task is bundled in the Regional Council of Tübingen. It checks products and services, including digital offerings such as websites and apps, for their accessibility. If more in-depth analyses are required, it is supported by the Baden-Württemberg State Institute for the Environment (LUBW) for technical testing. At federal level, the state authorities work together in the Market Surveillance Working Committee (AAMÜ).

Caution: If companies do not comply with the requirements, it can be expensive. There is a risk of high fines and, in the worst case, the website can be taken offline.

 

Remember the declaration obligation
Companies that fall under the BFSG must publish an accessibility declaration on their website. This is because consumers who encounter barriers should be able to contact the company directly – ideally to the contact point specified in the accessibility statement. The statement should be clearly visible (e.g. in the footer) and updated regularly. It must indicate which parts of the website are accessible, where there are still restrictions, state the reasons for this and show alternative routes for users. It must also offer a contact option for reporting barriers or providing feedback. Information on the complaints procedure and the responsible enforcement body (see above) is also required. Important: The declaration itself must also be accessible.

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The requirements: WCAG standards
Websites must comply with the standards of the Web Content Accessibility Guidelines (WCAG) . These standards were published in October 2023 and are already in force. They are expected to be supplemented by further success criteria in the near future. Compliance with the European standard EN 301 549 is mandatory for technical implementation.

The current WCAG standards define four principles for accessible websites:

  1. Perceptibility
  1. Usability
  1. Comprehensibility
  1. Robustness

 

Good to know:
These four principles of the BFSG also improve the SEO performance of a website: A clear structure, good readability and optimized user guidance contribute to better visibility in search engines. Technical clarity and fast loading times also support the ranking. This is a great opportunity for companies!

 

Legal certainty: three levels of conformity

To ensure that digital services are accessible to everyone, there are three levels of accessibility (conformance levels):

Level A (basic): Meets basic requirements such as text descriptions for images and keyboard operability.

Level AA (medium): Goes beyond this and ensures that, for example, the color contrast is sufficient and texts can be enlarged.

Level AAA (High): Sets the highest standards – such as through simple language and detailed audio descriptions.

According to the BFSG, companies must at least meet the requirements of levels A and AA. Full implementation of level AAA is often difficult and is therefore not necessarily expected. Compliance with these standards not only provides legal certainty for companies, but also improves the user experience.

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Accessibility offers advantages for companies
Companies should not only view the implementation of digital accessibility as a legal obligation, but also as an opportunity to make digital content accessible to everyone. It is not just about the aspect of social responsibility, because an accessible website improves the user experience for everyone and strengthens the competitiveness of companies:

 

CheckUp, advice and implementation from Eberle
Implementing accessibility can be a challenge, as many technical and content-related aspects need to be taken into account. Although there are various tools such as the WAVE Checker, Google Lighthouse or the BITV test to get an initial assessment, full implementation requires specialist knowledge and experience. As an experienced agency, we support you in analyzing your website, planning the necessary measures and technical implementation in accordance with the current WCAG standards. We help you to meet legal requirements and at the same time create a better user experience for all visitors. We will also inform you about the funding opportunities available to you. Contact us for a no-obligation initial consultation in which we will check the current status of your website and show you the next steps.

 

Conclusion

Sources & further reading:

Federal Agency for Accessibility – Scope of application with list of products and services
Federal Agency for Accessibility – Summary of the requirements

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