Accessibility will become mandatory: What the Accessibility Empowerment Act means for digital services from 2025
From 28 June 2025, the German Accessibility Empowerment Act (BFSG) will come into effect bildungsserver.de . This law obliges private companies for the first time to offer certain digital products and services in an accessible format visionbites.de. But who does this affect specifically, what does "accessible" mean in this context – and how can you implement this without the costs skyrocketing? In this blog article, we would like to shed some light on the new requirements.
Reading duration: approx. 15 minutes
Who does the law affect? – Scope of application from July 2025
The BFSG implements the EU directive on accessibility requirements (European Accessibility Act, EAA) into German law. It comes into force on 28 June 2025
bildungsserver.de
. From then on, the products and services mentioned therein must be provided barrier-free for consumers. However, not every web presence is automatically included! The law conclusively specifies the affected areas (§1 para. 2 and 3 BFSG)bundesfachstelle-barrierefreiheit.de. From now on, the following digital services are subject to mandatory accessibility:
- Electronic commerce – in other words, online services that facilitate the conclusion of consumer contracts, e.g., online shops hwk-dresden.de. (B2B shops, which serve only business customers, are not covered by the mandatory requirement hwk-dresden.de.)
- Consumer banking services – in particular, online banking websites and banking apps.
- Telecommunication services – for example, phone and messaging apps.
- E-books and their respective distribution platforms.
- Passenger transport services – for instance, digital ticket machines in public transport.
- Mobile apps in passenger transport – such as apps from railway or airline companies.
Also, various products must be barrier-free from 2025, including computers, smartphones, ticket and cash machines, or smart TVs bundesfachstelle-barrierefreiheit.de. For most of our customers (SMEs with web applications), it is especially crucial to understand that your consumer-facing online service must be barrier-free by July 2025, provided it falls into one of the above categories.
However, there is an exception for micro-enterprises! Companies with fewer than 10 employees and a maximum €2 million annual turnover are exempt from the BFSG requirements if they provide servicesbundesfachstelle-barrierefreiheit.de. A mini start-up that operates an online shop does not necessarily have to retrofit formally hwk-dresden.de. Caution: This exception applies only to services! Micro-enterprises that introduce products (e.g., hardware such as special reading devices) onto the market, still fall under the BFSGbundesfachstelle-barrierefreiheit.dehwk-dresden.de.
And let's be honest – even if you are narrowly exempt from the requirement, it still pays off to implement accessibility voluntarily to rule out excluding potential customers and to be prepared for future requirements.
What exactly does "barrier-free" mean?
According to the common definition, offers are barrier-free if they are findable, accessible, and usable for people with disabilities in the usual way, without particular difficulty, and basically without the help of others hwk-dresden.de. In the web area, this specifically means: for example, a website must also be operable via a screen reader (reading software) or solely with the keyboard; there must be no hurdles for visually impaired, hearing-impaired, motor or cognitively challenged people. Technically, the requirements in the BFSG are based on the European Standard EN 301 549, which in turn refers to the Web Content Accessibility Guidelines (WCAG) 2.1 at level AA.
This means, if you fulfill the success criteria of WCAG 2.1 AA, you are safe. Public bodies are already familiar with these standards from the BITV 2.0 (Barrierefreie-Informationstechnik-Verordnung), which has been applicable to public authority websites since 2018 – there, additional content in easy language and sign language is also required. For private providers, the BFSG essentially calls for WCAG 2.1 AA.
What deadlines and consequences apply? - Transition periods and penalties
Key date 28.06.2025: From this date, new products and services must be compliant. However, the law provides for a few transition periods. It is important to know that existing contracts and systems are given partial extensions:
- Ongoing services: If a long-term contract was concluded before 28.06.2025 and it is continued without changes, the provider has until 27.06.2030 to make the service accessible
bfsg-barrierefreiheitsstaerkungsgesetz.de
Example: An online banking system that has been in operation for years and is used by existing customers should be converted by 2030 at the latest – but new offers must be accessible immediately from 2025. - Older technology in use: If a service uses a product that was already in use before June 2025 (e.g., an existing self-service terminal), the deadline until 2030 also applies bfsg-barrierefreiheitsstaerkungsgesetz.de.
- Self-Service Terminals: The law allows 15
years transition time for ATMs, ticket machines & similar that already exist. These may continue to be used until 2040 before they must be replaced or retrofitted
bundesfachstelle-barrierefreiheit.de
Important: However, as soon as a provider significantly revises an existing service or closes a new contract with a consumer after June 2025, the current parts must be accessible – so you can't demand another 5 years extension for updates bfsg-barrierefreiheitsstaerkungsgesetz.de. The transition periods are intended as a grace period for old stocks, not as a loophole for prolongation.
Control and Sanctions
Compliance is checked by market supervision authorities. In the event of violations, there are first warnings to improve and finally severe measures. In extreme cases, the authority can order that a non-accessible online service is taken off the market or shut down bundesfachstelle-barrierefreiheit.de!
Additionally, fines can be levied – the BFSG proposes amounts up to 100,000 Euros depending on the violation bundesfachstelle-barrierefreiheit.de. Also, consumers and associations have rights - they can criticize deficiencies and (similar to AGG violations) exert legal pressure if necessary. Therefore, the issue should be taken seriously. Those who continue as before from 2025 risk damage to their image, complaints, and in the worst case loss of sales.
In addition to the duty of accessibility, the law also requires companies to produce bureaucratic proofs. For each product or service, a declaration of conformity or technical documentation must be created, describing how the requirements are met
bfsg-barrierefreiheitsstaerkungsgesetz.de.
Service providers must also easily provide information (e.g. on the website or in terms and conditions) and indicate which market surveillance authority is responsible
bfsg-barrierefreiheitsstaerkungsgesetz.de.
In practice, this should run analogously to the official accessibility statement which is already known from public websites – a section "Accessibility Statement" with information about the implementation status, contact options for feedback and a reference to the enforcement office.
Plan for accessibility early vs. implement it later - the cost comparison
A frequently heard concern is: "Will it not become incredibly expensive?"
The good news is, if you consider accessibility from the start, the additional effort is significantly reduced.
A study on Barrier-free Building found that a building planned to be barrier-free from the beginning only causes about 1% additional costs
bundesfachstelle-barrierefreiheit.de
– and the same is true for software projects. Designing control functions to be barrier-free from the start is basically no more complex than developing them with barriers
aktion-mensch.de.
Whether a developer codes a contact form to be accessible or with unnecessary barriers hardly makes a difference, as long as the end goal is known!
The right mindset in the team is key. If UX designers, developers, and editors are trained and know from the start what matters, barrier-free websites will almost develop themselves. Many measures don't cost extra. For example, using well-planned heading structures and alternative texts from the start only requires a bit of attention but no additional budget!
Accessibility usually becomes expensive when it has to be added afterwards.
Suddenly, you discover that adjustments are needed in multiple places: images without alt text, poor color combinations in the design, interactive components that only work with a mouse, videos without subtitles, PDF documents without tags, etc. Each of these barriers requires analysis, design changes, further development, and testing – in short: additional project iterations which could have been avoided. The later in the development process these changes are made, the higher the cost. Experiences in IT (also from our own projects) show that fixing mistakes later on is multiple times more expensive than preventing them. It's the same with accessibility: "Shift Left" is the motto – start early in the process.
If accessibility is an integral part of the project, the additional effort remains nominal – but maintaining and retrofitting afterward can become quite expensive.
An example from practice: A medium-sized company had its existing online shop checked for accessibility. More than 50 individual problems were found, from missing form labels to unusable dropdown menus. The fixes required several developer sprints and sometimes major frontend restructuring – the cost: high four-digit figures. If these standards had been complied with from the start, almost none of these points would have arisen. Additionally, there were opportunity costs, i.e., other features could not be developed during the revision.
Our tip: Plan for accessibility from the beginning in new projects! The costs are manageable and contribute to a better user experience for everyone!
How to make it barrier-free: Tests and Support for Companies
If you're now thinking “All well and good, but how do I actually determine if my website is accessible – and who will help me?” - don't worry, you don't have to reinvent the wheel. There are tried and tested testing procedures and many experts, who assist companies on the path to accessibility.
1. Self-check with tools: A good first step is a simple self-test. There are free testing tools available, with which you can identify typical problems. Popular ones are, for example, the WAVE Accessibility Checker (browser extension) or axe DevTools, as well as Google Lighthouse (integrated in the Chrome browser). These tools analyze the website code and report, for example, missing alt texts, insufficient contrasts or forms without labels. It's important to know, however, that while automated tests find many technical barriers, they don't find everything and not everything they find is meaningful. Some criteria - such as whether alt texts make logical sense or whether the operation sequence is logical - can only be assessed by human testers. Nevertheless, such a tool check is worth it. Within a few minutes, you can get a rough overview of quite obvious problem areas.
2. Expert Audit (BITV-Test): For a reliable result, a manual inspection report by specialists is recommended. In Germany, the BITV-Test has been established as the standard procedure. This test currently includes around 60 test steps, which are adapted to the WCAG 2.1 AA and the legal requirements (EN 301 549). It is carried out by trained auditors – many of them offer this service. The result is a detailed report that shows the strengths and weaknesses of the website and provides a percentage rating. For small websites, the effort is often in the range of a few person-days. According to Aktion Mensch, the cost for a complete expert analysis varies between 2,500 and 10,000 Euros, depending on the volume (from simple page to complex online store) aktion-mensch.de. This is money well spent as you receive a clear to-do list to become legally compliant.
3. User Feedback: Nothing replaces the practical test with real users. Ideally, a barrier-free site should be tried out by people with different disabilities – e.g. a blind user with a screen reader, someone with visual impairment and magnification software, someone with a motor impairment only using a keyboard, etc. These tests can be organized through specialized service providers or you can ask volunteers from your own environment. The findings are incredibly valuable. For instance, you can see where operation is difficult or confusing. Often this also reveals a general benefit for all (keyword Usability). For example, if a senior with tremor cannot tap the small dropdown, it is probably not optimally solved for many others as well – here, a simplified UI can make a huge difference.
4. Support from agencies and consultants: If the know-how is lacking in-house, do not hesitate to engage external professionals. There are consulting firms and agencies (like ours) with expertise in the field or even a focus on digital accessibility. Look for experience and qualification when choosing. Good service providers will prioritize with you what needs to be done, and they can also train your developers to ensure accessibility is sustainably anchored in the process.
Our tip: Start with a simple self-test to get a feel. Then, if necessary, get offers for a professional audit. The Knappschaft-Bahn-See or the Federal Specialist Agency for Accessibility (a governmental agency, supported by KBS), offers a lot of information and webinars, which especially make it easier for e-commerce companies to get started bundesfachstelle-barrierefreiheit.de.
Misunderstandings, special cases and “myths” about the BFSG
Several theories and uncertainties are circulating ahead of the coming into force that we would like to address here:
- "By 2025, all websites have to be accessible." – Not exactly. It is true that the BFSG will cover many private web offers, but only certain categories. A purely informational company website without an online shop, for instance, that does not conclude contracts with consumers, is not directly covered by the law bundesfachstelle-barrierefreiheit.de. But that doesn't mean you should ignore it! Accessibility can bring competitive advantages and the legislature may expand its scope in the future. For public websites of authorities, there has been an obligation (BITV 2.0) for years - the BFSG now closes the big gap in the private sector for consumer offers. Our advice: If your website is not currently covered by BFSG, take this opportunity to voluntarily implement accessibility. This will improve your image and prepare you in case all websites should be covered soon.
- "Small businesses are exempted – this will not affect us." – Beware: The micro-enterprise rule (less than 10 employees, <2 Mio € turnover) applies only to service providersbundesfachstelle-barrierefreiheit.de. As soon as your company exceeds this threshold - as many small medium-sized companies do - you must comply with the BFSG if you operate relevant offers. An online retailer with 15 employees, for example, is definitely obligated. The BFSG also applies if you formally qualify as a micro-enterprise, but have a physical sales channel (product) in the BFSG area, then the exception does not applyhwk-dresden.de. So check accurately if you are really exempted. In most cases, more micro-enterprises like one-man online shops are exempted. For growth-oriented start-ups and SMEs, this issue is indeed relevant.
- "We would like to, but it's not economically viable." – The law includes a clause on disproportionate burden! If meeting the requirements poses an unbearable financial risk, you can refer to this in exceptional cases bundesfachstelle-barrierefreiheit.de. But be careful – the hurdles are high. You need to prepare a detailed documentation according to certain criteria and review it regularly (at least every 5 years). In addition, you need to inform the market surveillance authority and provide all facts upon request. For the vast majority of companies, however, accessibility is likely to be reasonable, as it also opens up additional customer groups in the long term.
Conclusion: Understand accessibility as an opportunity
Instead of seeing the BFSG only as a burdensome obligation, it is worth recognizing the potentials: About 10 million people in Germany live with a recognized disability – a huge market segment. This includes many older people with dwindling sensory abilities, temporarily restricted persons (broken arm, etc.) and users with situational handicaps (blinding sunlight on the mobile phone, loud surroundings, …). An accessible offer reaches more customers and is often more comfortable for all users. Many accessibility principles are simply best practices for good web design (clear structure, meaningful links, sufficient contrast, etc.). Companies that lead the way here, can profile themselves with an inclusive image and simultaneously minimize legal risks.
The Accessibility Strengthening Act may initially appear to be another compliance hurdle. However, with the right partner and approach, it can be managed – without your budget exploding or your team getting desperate. We are happy to support you in setting the course early so that your web project is not only legally compliant, but provides a real added value for all users!
Note: This article was also generated with the support of AI (model: GPT-4).
