The Barrierefreiheitsstärkungsgesetz (BFSG) is Germany's national implementation of the European Accessibility Act, and it has applied since 28 June 2025. If you sell to consumers in Germany, BFSG compliance is now a market-access requirement, not a nice-to-have. The law moves accessibility out of the public sector and squarely onto private businesses, including e-commerce, banking, e-books, and self-service hardware.
This guide explains who must comply, what the BFSG actually covers, and the precise technical baseline you are measured against, WCAG 2.2 Level AA via EN 301 549, so you can scope the work realistically rather than guessing.
How the BFSG fits into the European Accessibility Act
The EU does not regulate accessibility for businesses through a single directly applicable rulebook. Directive (EU) 2019/882, the European Accessibility Act (EAA), sets common obligations, and each member state passes its own law to enforce them. Germany did this through the Barrierefreiheitsstärkungsgesetz. These national laws share the same application date, 28 June 2025, and the same underlying technical standard.
This matters if you sell across borders. The BFSG is Germany's version, but France enforces the EAA through the RGAA and Italy through the Legge Stanca with AgID guidelines. Because these national frameworks all reference EN 301 549 and WCAG, building to one consistent standard covers you across the EU rather than forcing country-by-country rebuilds. For the wider picture, see our overview of the European Accessibility Act.
Who must comply from 28 June 2025
The BFSG applies to economic operators, manufacturers, importers, distributors, and service providers, that place certain products or services on the German market for consumers. Crucially, scope follows the customer, not your address. A retailer in London or New York selling to German consumers is in scope just as much as a company in Munich.
Covered products and services include:
- E-commerce and consumer-facing online services (webshops, booking flows, account areas)
- Consumer banking and payment services
- E-books, e-readers, and e-reading software
- Electronic communications services
- Access services for audiovisual media
- Passenger transport services (websites, apps, and ticketing)
- Self-service terminals: ATMs, ticketing and check-in machines, and similar kiosks
There is a narrow exemption: microenterprises (fewer than 10 employees and up to 2 million euro annual turnover) are exempt from the obligations that apply to services, but not from those that apply to products. Most established sellers will not qualify, and the threshold is easy to outgrow, so plan to comply rather than rely on it.
The technical baseline: WCAG 2.2 AA via EN 301 549
Conformance is demonstrated through EN 301 549, the harmonised European standard, which incorporates WCAG 2.2 at Levels A and AA. In practice, for any website or app, meeting WCAG 2.2 Level AA is your working target. EN 301 549 then adds hardware and documentation clauses on top for physical products like terminals. Our breakdown of EN 301 549 explains how the standard maps to the web criteria.
WCAG 2.2 brought changes worth knowing if your team last audited against 2.1. It added 2.4.11 Focus Not Obscured (Minimum, AA), 2.5.7 Dragging Movements (AA), 2.5.8 Target Size (Minimum, AA, a 24 by 24 CSS pixel minimum for interactive targets), 3.2.6 Consistent Help (A), 3.3.7 Redundant Entry (A), and 3.3.8 Accessible Authentication (Minimum, AA). It also removed the old 4.1.1 Parsing criterion, which modern browsers made obsolete.
Beneath the version differences sit the criteria that catch most real sites. These are the ones to verify first:
- Contrast: text must meet 4.5:1, and 3:1 for large text and user-interface components.
- 1.4.10 Reflow and 1.4.4 Resize Text: content must work at 200% zoom and reflow to a narrow viewport without horizontal scrolling.
- 1.4.12 Text Spacing: layouts must not break when users override spacing.
- 2.4.7 Focus Visible and 2.4.11 Focus Not Obscured: keyboard focus must be visible and never hidden behind sticky headers.
- 4.1.3 Status Messages: dynamic updates such as cart totals and form errors must be announced to screen readers.
- 1.2.x: captions and audio description for media.
Where compliance usually breaks in practice
For a typical webshop, the highest-impact failures cluster in a few places. The checkout funnel is the one that costs you sales directly: a date picker that only works with a mouse fails 2.5.7 Dragging Movements, a CAPTCHA with no accessible alternative fails 3.3.8 Accessible Authentication, and inputs without programmatic labels lock out screen-reader users entirely.
Other recurring offenders: product images with missing or unhelpful alt text, custom dropdowns and modals built without correct ARIA and keyboard support, low-contrast sale badges and placeholder text, and focus that vanishes inside single-page-app route changes. None of these are exotic; they are the everyday cost of components shipped without an accessibility pass.
A practical path to BFSG readiness
Start by establishing where you actually stand, then close gaps in priority order rather than trying to fix everything at once.
- Scan your key flows (home, category, product, cart, checkout, account) for automated failures with a free accessibility scan.
- Manually test the full purchase journey with a keyboard only and with a screen reader, since automated tools catch only a portion of issues on their own.
- Work through a structured checklist mapped to WCAG 2.2 AA so nothing slips.
- Publish a real accessibility statement, generated with our accessibility statement generator, describing your conformance status and a contact route for users who hit barriers.
- Bake accessibility checks into your release process so new features do not reintroduce regressions.
Automated scanning will not prove full conformance on its own, but it is the fastest way to find the obvious blockers, quantify the work, and show measurable progress before the next audit. Treat the BFSG as the floor your German customers expect, then keep it from drifting.