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16
May, 2025

The Accessibility Reinforcement Act

Digital participation and inclusion

What is the Accessibility Improvement Act (BFSG) about?

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

It obliges companies to offer certain products and services without barriers from June 28, 2025- especially in the digital sector.

The BFG is intended to ensure that people with disabilities have equal access to certain products and services. It obliges providers to take accessibility into account when designing and providing products and services, particularly websites and mobile apps as well as e-commerce offers (online stores)

The BFG also applies to certain hardware products - in particular those with user interfaces or in connection with digital services. For example, smartphones, tablets and computer e-book readers are affected. However, it also affects self-service terminals such as ATMs, ticket machines or check-in terminals, as well as payment terminals. These must be designed in such a way that they can also be operated by people with various disabilities - e.g. through: Keyboard operability or voice and screen support

 

What does the BFG aim to achieve?

The Accessibility Act aims to ensure that digital products and services can be used equally by all people, regardless of their disabilities. In concrete terms, this means that disabilities should be compensated for by alternative technological solutions or interfaces.

What needs to be done?

Thecentral measures for accessibility are therefore so-called alternative sensory perception.

This includes, for example, outputting texts as audio for blind or visually impaired people (e.g. using screen readers). Another option is subtitles or sign language videos for deaf people. It is also possible to providevisual feedback instead of acoustic signals for people with hearing impairments (e.g. visual cues instead of warning sounds).

Another customization option is font enlargement or contrast adjustment. This means that content must be scalable without information being lost or navigation becoming unusable. Color adjustments (e.g. high contrast) should also be considered. These help with visual impairments or color blindness.

One important alternative is to use a keyboard instead of a touchscreen . People with motor impairments cannot operate touchscreens or can only do so to a limited extent. Full operability via keyboard or external input devices is therefore essential. Voice control or switch control (for people with severely restricted mobility) can also be taken into consideration.

It is also important that the websites have a clear, comprehensible structure . Structured content also helps with cognitive impairments. Simple language, clear structures and reduced distraction 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 in a self-determined way - in the way that works best for them.

What needs to be done?

Companies that fall under 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 barrier).
  • Regularly check and document the requirements.

What do online store operators in particular need to be aware of?

Online store owners are particularly affected and must:

  • Design your web stores to be fully accessible (e.g. keyboard navigation, screen reader compatibility, good contrasts, simple language).
  • In addition to normal mouse operation, an online store also offers full keyboard navigation: you can use the tab key to jump through all the operating elements.
  • Images of products are provided with alternative texts that can be read aloud by a screen reader, for example.
  • Complex CAPTCHAs are not used for the payment process or an accessible alternative is offered (e.g. via audio).
  • Integrate payment systems without barriers.
  • Make customer information such as product descriptions, prices, delivery conditions, etc. clear, understandable and accessible.
  • Be compliant by June 28, 2025 at the latest. It should be noted that there are no transitional periods for online stores.
  • Exception: Micro-enterprises with fewer than 10 employees and an annual turnover of less than €2 million (however, this does not apply to products that may fall under the BFSG).

What is the threat of non-implementation?

Failure to do so may result in fines, warnings from competitors or associations, reputational damage and even exclusion from public tenders.

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Dr. Julian Oberndörfer
Lawyer
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