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Accessibility Strengthening Act - BFSG

The Accessibility Strengthening Act (BFSG) requires companies to gradually make products and services accessible. Its goal is to provide people with disabilities equal access to digital and physical offerings. The Act transposes the requirements of the European Accessibility Act (EAA) into German law.

Relevance & Scope (“Use Cases”)

Main Application Areas

  • E-Commerce / Online Shops (§ 1 para. 3 no. 5)
    Online retail, booking platforms, comparison portals — in short, all web-based services through which consumer contracts are concluded.
  • Banking / Financial Services (§ 1 para. 3 no. 3)
    Online banking, payment apps, financial apps, consumer payment services.
  • Mobile Apps
    Apps for the above-mentioned services — both web and native apps are included.
  • Ticketing / Passenger Transport (§ 1 para. 3 no. 2)
    Digital components of transport and ticketing services: websites of transport operators, apps, booking/ticketing portals, travel information systems.
    Important: The Act refers to digital services, not necessarily physical terminals (unless they fall under the definition of a regulated product).
  • E-Books & Related Software (§ 1 para. 3 no. 4)
    E-book shops, web-based reading platforms, reader software.

Not Primarily Affected by Overlay Tools

  • Hardware devices such as computers, e-readers, or terminals — although covered by the BFSG, JavaScript-based overlays are not relevant, as these are physical products.

Fundamentals & Legislative Purpose

Purpose (§ 1 para. 1)

  • Ensuring accessibility of certain products and services

  • Promoting participation of people with disabilities

  • Harmonization within the EU internal market, especially implementation of Directive (EU) 2019/882 (“European Accessibility Act”, EAA)

Entry into Force / Key Date

  • From 28 June 2025, new or newly supplied products and services must comply with accessibility requirements

  • Transition periods exist for certain services and devices (§ 38 BFSG)

Covered Products & Services

Products (§ 1 para. 2)

Regulated products include:

  • Computers, laptops, tablets, smartphones, operating systems
  • Self-service terminals: e.g. ATMs, payment terminals, check-in or ticket machines
  • Telecommunications equipment with interactive features (e.g. routers)
  • Audiovisual equipment with internet/digital services (e.g. smart TVs)
  • E-book readers (hardware)

Services (§ 1 para. 3)

Relevant services include:

  • Electronic commerce services (webshops, booking platforms, comparison portals)
  • Consumer banking services (online banking, payment services)
  • E-book services & software (shops, reading platforms)
  • Passenger transport services (digital components such as apps, booking portals)
  • Telecommunications services (provider websites, customer portals, apps)

Definition of Accessibility & Target Groups

Definition of Accessibility (§ 3 para. 1)

Products and services are accessible if they are:

  • perceivable,
  • operable,
  • usable

by people with disabilities in a customary way, without undue difficulty, and generally without external assistance.

People with Disabilities (§ 2 no. 1)

Long-term (more than 6 months) physical, mental, emotional, or sensory impairments.

Exemptions & Special Provisions

Micro-Enterprises (§ 3 para. 3)

  • Micro-enterprises (fewer than 10 employees and turnover or balance sheet total ≤ €2 million) are exempt from accessibility requirements for services
  • They are not exempt when manufacturing or placing products on the market
  • Micro-enterprises are entitled to free consultation by the Federal Accessibility Office

Fundamental Alteration (§ 16)

If fulfilling accessibility requirements would fundamentally alter a product or service (loss of essential characteristics), an exemption may apply.

Disproportionate Burden (§ 17)

If accessibility would impose a disproportionate burden, an exemption may be granted.
  • Important: Companies that received public funding for digitization or accessibility cannot invoke this exemption.
  • Invoking § 17 requires notifying the responsible market surveillance authority.

Obligations for Service Providers (§ 14 ff.)

Accessible Provision (§ 14 para. 1)

Service providers must ensure that their services meet the accessibility requirements — through technical and organizational measures.

Information Obligations (§ 14 para. 1 no. 2 + Annex 3)

Providers must publicly supply specific mandatory accessibility information:

  • Description of the service
  • Explanation of how the service is provided
  • How accessibility requirements are fulfilled (norms, technical specifications)
  • Identification of the competent market surveillance authority
  • Information must itself be accessible: perceivable, operable, understandable, robust.
  • Language should be clear, well-structured, ideally in easy-to-understand language.
  • Special rule for banking services: maximum language level B2.

Publication

Information must be easily discoverable, e.g. via an “Accessibility” link in the website/app header or footer.

Continuous Compliance Monitoring (§ 14 para. 3)

  • Ongoing obligation to ensure compliance
  • Updates (e.g. to apps or websites) must be reviewed and adjusted if necessary
  • In case of non-compliance: corrective actions + notification of the market surveillance authority

Duty to Provide Information (§ 14 para. 5)

Service providers must provide proof of accessibility upon request and cooperate during inspections.

Product-Related Obligations (Manufacturers, Importers, Distributors — §§ 6–13)

Manufacturers (§ 6)

  • Ensure accessibility during product design
  • Prepare technical documentation
  • Issue EU Declaration of Conformity
  • Affix CE marking
  • Retain documentation for 5 years
  • In case of non-compliance: corrective actions + authority notification

Labelling Requirements (§ 7)

  • Product identification: serial, type, or batch number
  • Manufacturer details (name, address)
  • User instructions: in German, clear, safe, and comprehensible

Importers (§ 9)

  • May only place compliant products on the EU market
  • Check CE marking
  • Provide their own contact details on the product/packaging (traceability)
  • Ensure German-language user instructions
  • Retain documentation for 5 years

Distributors (§ 11)

  • Distribute only products with valid CE marking
  • Verify accompanying documents
  • Inform manufacturers/importers/authorities if issues arise
  • Ensure storage/transport does not compromise accessibility features

Transition Periods (§ 38)

Services

Service providers may operate under existing contracts until 27 June 2030 if these contracts were concluded before 28 June 2025.

Self-Service Terminals

Devices already in use before 28 June 2025 may remain in operation until the end of their economic lifetime, but no longer than 15 years (§ 38 para. 2).

Market Surveillance & Enforcement

Authorities (§§ 20–31)

Market surveillance authorities inspect compliance through sampling, monitoring, and handling complaints.

EU Level

Cooperation and exchange with EU bodies regarding conformity and sanctions.

Consumer Rights & Procedures

Right to Information (§ 21 para. 4)

Consumers may request accessible information about a product’s/service’s conformity — including in easy language or other supported formats.

Communication Assistance (§ 21 para. 5)

People with hearing or speech impairments have a right to communication assistance (e.g. German Sign Language, sign-supported speech). Costs may be covered by the authority.

Administrative Procedure (§ 32)

Consumers may initiate administrative proceedings against a company, directly or via recognized associations (collective action capability).

Legal Remedies (§ 33)

Legal action before administrative courts is possible, including collective legal actions.

Mediation (§ 34)

Alternative/complimentary procedure involving the market surveillance authority (based on the Disability Equality Act).

Sanctions & Risks

Fines (§ 37)

  • Up to €100,000 for non-compliance with accessibility requirements (products/services)
  • Up to €10,000 for violations of information, documentation, or labelling obligations

Additional Risks

  • Administrative proceedings and related costs
  • Public disclosure of violations (reputational damage)
  • Competitive disadvantages
  • Collective actions by advocacy groups

Support & Consultation

Federal Accessibility Office (§ 15)

  • Provides consultation, especially for micro-enterprises
  • Publishes guidelines, webinars, and practical implementation aids

Guidelines

The Federal Ministry of Labour and Social Affairs (BMAS) has published application guidelines for the BFSG with practical and technical guidance, especially for small businesses.

Technical Standards / Norms

The BFSG refers to:

  • Harmonised standards (§ 4)
  • Technical specifications (§ 2 no. 20)

Key standards:

  • EN 301 549 — central standard for ICT products (web, software, operating systems)
  • PDF/UA (ISO 14289-1) — for accessible PDF documents

Compliance with these standards establishes a presumption of conformity (§§ 4, 5 BFSG) and simplifies demonstrating accessibility.