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16
May 2025

The Act to Strengthen Accessibility

Digital Participation and Inclusion

What is the Accessibility Enhancement Act (BFSG) about?

The Accessibility Act (BFG) is a German law that implements the EU Directive on accessibility requirements for products and services (European Accessibility Act). Its goal is to improve the participation of people with disabilities in digital and public life.

It requires companies to make certain products and services accessible starting June 28, 2025—especially in the digital realm.

The BFG is intended to ensure that people with disabilities have equal access to certain products and services. It requires providers to take accessibility into account in the design and delivery of their offerings, particularly with regard to websites, mobile apps, and e-commerce platforms (online stores).

The BFG also applies to certain hardware products —particularly those with user interfaces or related to digital services. This includes, for example, smartphones, tablets, computers, and e-book readers. However, it also applies to self-service terminals such as ATMs, ticket machines, or check-in kiosks, as well as payment terminals. These must be designed so that they can be used by people with various disabilities—for example, through keyboard accessibility or voice and on-screen assistance.

 

What is the goal of the BFG?

The Accessibility Act aims to ensure that digital products and services can be used on an equal basis by all people, regardless of any limitations they may have. Specifically, this means that disabilities should be accommodated through alternative technological solutions or interfaces.

What should be done?

Thekey measures for accessibility are therefore those that enable so-called alternative sensory perception.

This includes, for example, converting text to audio for blind or visually impaired people (e.g., through screen readers). Another option is subtitles or sign language videos for deaf people.Visual feedback instead of audible signals is also possible for people with hearing impairments (e.g., visual cues instead of warning tones).

Another accessibility feature is font size adjustment or contrast adjustment. This means that content must be scalable without losing information or rendering the navigation unusable. In addition, color adjustments (e.g., high contrast) should be considered. These help users with visual impairments or color blindness.

An important alternative is using a keyboard instead of a touchscreen. People with motor impairments may be unable to use touchscreens or may have limited ability to do so. Full operability via a keyboard or external input devices is therefore essential. Voice control or switch control (for people with severely limited mobility) can also be considered.

It is also important that websites have a clear, easy-to-follow structure . Structured content also helps people with cognitive limitations. Simple language, clear structures, and minimal distractions help people with learning or concentration difficulties. Pictograms or symbols can supplement or replace text.

People with disabilities should not have to rely on assistants, but should be able to use digital content independently and on their own terms —in the way that works best for them.

What should be done?

Companies subject to the BFG must:

  • Make your websites, mobile apps, digital services, and certain hardware products accessible—in accordance with the EU standard EN 301 549.
  • Publish an accessibility statement.
  • Provide a feedback mechanism (e.g., "Report a barrier").
  • Review and document the requirements on a regular basis.

What, in particular, do online store operators need to keep in mind?

Online store owners are particularly affected and must:

  • Make your online stores fully accessible (e.g., keyboard navigation, screen reader compatibility, high contrast, simple language).
  • In addition to standard mouse navigation, an online store also offers full keyboard navigation: You can use the Tab key to navigate through all the controls.
  • Product images include alternative text that a screen reader, for example, can read aloud.
  • During the payment process, complex CAPTCHAs are avoided, or an accessible alternative is provided (e.g., via audio).
  • Integrate payment systems in an accessible way.
  • Make customer information—such as product descriptions, prices, shipping terms, etc.— clear, understandable, and accessible.
  • Must be compliant by June 28, 2025, at the latest. Please note that there are no transition periods for online stores.
  • Exception: Microenterprises with fewer than 10 employees and annual revenue of less than €2 million (however, this does not apply to products that may fall under the BFSG).

What are the consequences of non-compliance?

Failure to comply may result in fines, warnings from competitors or industry associations, damage to one’s reputation, or even exclusion from public sector bidding processes.

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Dr. Julian Oberndörfer
Attorney
EMOJIS in Legal Context: emoji and Justitia EMOJIS in Legal Context: emoji and Justitia

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