The Barrierefreiheitsstärkungsgesetz (BFSG) comes into force in Germany on June 28, 2025. This implements EU Directive (EU) 2019/882, also known as the European Accessibility Act (EAA). The aim is to ensure the equal participation of people with disabilities in economic and social life by improving accessibility. In particular, the law obliges economic actors such as manufacturers, retailers and service providers to fulfill comprehensive accessibility requirements in digital products and services.
Accessible products and services
According to the definition in Section 3 (1) BFSG, products and services are "barrier-free" if they can be found, accessed and used by people with disabilities "in the usual way, without particular difficulty and generally without outside help".
The BFSG is mandatory for all manufacturers, distributors and importers of the products listed in § 1 Para. 2 BFSG as well as for the providers of the services listed in § 1 Para. 3 BFSG.
From the full entry into force of the BFSG on June 28, 2025, only products may be placed on the market that
- meet the prescribed accessibility requirements,
- have undergone the conformity assessment procedure,
- are provided with an EU Declaration of Conformity and
- have a CE marking.
From this date, the services listed in Section 1 para. 3 BFSG may only be offered if they meet the accessibility requirements of the BFSG. The services listed in § 38 BFSG are excluded.
Products and services covered by BFSG
Not all products and services for consumers are covered by the Accessibility Improvement Act. Which products and services fall within the scope of application is defined in Section 1 (2) and (3) BFSG.
The products covered by the BFSG include, among others:
- Computers, notebooks, tablets, smartphones and cell phones.
- Self-service terminals such as ATMs, ticket machines and check-in machines.
- Televisions with internet access.
- E-book readers.
Services that fall under the BFSG include:
- Services offered on mobile devices (including apps)
- Interregional passenger transport services
- Banking services
- Services in electronic commerce.
- Passenger transport services (for urban, suburban and regional transport services only interactive self-service terminals).
Important: The Accessibility Improvement Act regulates the accessibility of products and services, that are used by consumers. A consumer within the meaning of the Act is "any natural person who purchases or receives a product or service covered by this Act for purposes which are predominantly outside his trade, business or profession". Products and services that are used and offered exclusively in the B2B sector should not be affected by the BFSG.
Essential requirements for accessibility
The accessibility requirements are defined in Annex 1 BFSG and are based in particular on the technical standards of the harmonized European standard EN 301 549 and the international Web Content Accessibility Guidelines (WCAG) in version 2.1:
- PerceptibilityContent must be accessible through text alternatives, subtitles or a high-contrast presentation.
- Usability: User interfaces must be controllable via keyboard, voice input or touchscreen.
- Comprehensibility: Information must be presented clearly, simply and consistently.
- Robustness: Content and functionalities must be compatible with assistive technologies (e.g. screen readers).
The law also refers to technical standards such as EN 301 549, a harmonized European standard that sets out detailed requirements for accessible information and communication technologies. This standard regulates, for example, the design of hardware, software, web content and self-service terminals with regard to their accessibility for people with various disabilities.
In addition, the Web Content Accessibility Guidelines (WCAG 2.1) of the international Web Accessibility Initiative (WAI) of the W3C should be used as the basis for implementation. The WCAG 2.1 specify concrete criteria for the accessible design of digital content, which are structured according to the four principles of perceptibility, usability, comprehensibility and robustness (POUR). These standards form the basis for the technical implementation of the requirements specified in Annex 1 BFSG and also serve as a reference framework for test procedures and certifications.
What companies must implement according to BFSG
Companies that fall under the scope of the Accessibility Reinforcement Act are obliged to take extensive technical, organizational and documentary measures to implement the accessibility requirements.
First of all, products, especially hardware such as terminals or e-book readers, must be designed at the development stage in such a way that they comply with the principles of accessibility. This means that when designing products, attention must be paid to user-friendliness, alternative access routes and compatibility with assistive technologies ("Design for All").
Digital services, including websites, mobile applications, telecommunications services and online customer access, must be fully accessible by June 28, 2025 at the latest. The technical implementation is based on the requirements formulated in Annex 1 BFSG and in the EN 301 549 and WCAG 2.1 standards. Companies must ensure that their digital offerings can be perceived, operated, understood and technically processed by people with different disabilities.
In addition, there is a comprehensive documentation and verification obligation. You must apply suitable conformity assessment procedures and document in a comprehensible manner how the requirements have been met. This evidence must be available both as part of internal quality assurance and in the event of inquiries from market surveillance authorities or in the event of complaints.
Reading tip: Bureaucracy Relief Act in force since January 2025
Accessibility Reinforcement Act: Exceptions and transitional provisions
The Accessibility Reinforcement Act provides for exceptions and transitional regulations in certain cases, which are intended to comply with the principle of proportionality.
A key exception concerns existing products, i.e. products that were placed on the market before the law came into force on June 28, 2025. These are not retroactively subject to the new requirements and may continue to be offered and used without the need for subsequent adjustments.
More generous transition periods apply to existing self-service terminals such as ATMs or ticket machines: they only have to comply with the requirements of the BFSG by June 28, 2030. The extended deadline is intended to ensure that technically complex or cost-intensive conversions do not have to be implemented at disproportionately short notice.
In addition, companies can claim a disproportionate burden if the implementation of accessibility requirements would involve unreasonably high costs in a specific case. This can relate to both technical and economic reasons, for example if certain accessible technologies are not economically feasible for a niche product with a small number of units. However, this exception is subject to strict requirements. The reasons must be documented in detail and supported by objective evidence. In addition, the competent market surveillance authorities will examine these arguments as part of a case-by-case decision to determine whether the requirements are actually met.
According to Section 3 (3) BFSG, micro-enterprises with fewer than ten employees and an annual turnover of no more than two million euros that offer or provide services are exempt from the BFSG. This means that they do not have to make their services accessible. However, companies that place products on the market are subject to the BFSG and must make the products listed in Section 1 (2) accessible.
Important: The exceptions must not lead to the protective purpose of the law being undermined. The exemptions must therefore be interpreted narrowly and may only be used in justified cases. Companies are well advised to check at an early stage whether they fall under an exception and to systematically prepare the necessary documentation.
Consequences of violations of the Accessibility Improvement Act
Fines of up to 100,000 euros per individual case can be imposed for violations of the legal requirements - for example, by placing a non-accessible product on the market or providing a non-compliant digital service. Manufacturers as well as service providers or importers can be held liable, depending on the infringement. Companies should deal with their legal obligations at an early stage.
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