Accessible websites: what the BFSG requires from 2025

What the BFSG actually is

Germany’s Accessibility Strengthening Act (BFSG) implements the European Accessibility Act in German law.^[1] It has applied since 28. Juni 2025 and, for the first time, requires private-sector businesses to make certain digital products and services accessible. Until then, online accessibility requirements mainly applied to public bodies.

The principle is simple: if you sell something to consumers online or deliver a service digitally, people with disabilities must be able to use it. Without assistance, with a screen reader, using a keyboard, with enlarged text.

Who is affected, and who is not

The distinction comes down to two questions.

Question 1: Is your offering aimed at consumers? The BFSG applies to consumer services. Online shops, appointment booking systems, customer portals, ticket sales, banking access, e-books, telephony and messaging services, passenger transport. Purely B2B offerings are not covered. This is particularly relevant for law firms and financial service providers, as discussed in Websites for tax advisers, law firms and financial service providers.

Question 2: Are you a microenterprise? Businesses with fewer than 10 employees and annual turnover or an annual balance sheet total of no more than 2 Mio. Euro are exempt from the requirements for services. This exemption does not apply to products.

Our practical advice: do not rely on the exemption. As soon as a business grows or adds a booking tool, its status can change. And even where there is no legal obligation, an unusable website loses revenue.

The technical benchmark: EN 301 549 and WCAG 2.1 AA

The law itself does not specify CSS values. It refers to harmonised standards, specifically the European standard EN 301 549, which adopts WCAG 2.1 Level AA for web content.^[2] So when you read “WCAG 2.1 AA", that is the assessment benchmark that determines compliance.

The four underlying principles:

1. Perceivable – content must be visible or audible: contrast, alternative text, captions.
2. Operable – everything accessible by keyboard, enough time, no flashing effects.
3. Understandable – clear language, predictable navigation, helpful error messages.
4. Robust – clean HTML that screen readers and assistive tools interpret correctly.

Accessibility costs least when it is part of the design and development process from the outset. See The web design process: from screen design to implementation.

What an authority checks

The market surveillance authorities of Germany’s federal states are responsible. They will not crawl every website, but will act in response to specific triggers: a consumer complaint, a report from an association or spot checks.

The typical process:

1. A complaint is received or a spot check is initiated.
2. The authority requests documentation, usually the accessibility statement and technical information.
3. The function in question is then assessed, usually with assistive technology and automated tools.
4. If shortcomings are found, a request for remediation is issued with a deadline.
5. If the business does not respond, enforcement orders, including a prohibition on providing the service, and fines are possible.

An often overlooked point: the requirements include a publicly available accessibility statement. It explains how the offering meets the requirements, which parts are not yet accessible and how users can report barriers. If this statement is missing, the first check has already failed – regardless of how technically sound the website is.

A 10-point self-test for your website

You can work through this test yourself in about an hour. It does not replace an audit, but reliably indicates whether you have a problem.

1. Keyboard only. Navigate the most important journey – homepage, product, basket, submission – using only Tab, Shift+Tab and Enter. Can you reach everything and get back out again?
2. Visible focus. Is it clear where you are at every Tab step? Removing the focus outline with outline: none is the most common individual error.
3. Contrast. Text against its background must have a contrast ratio of at least 4,5:1, or at least 3:1 for large text from 24 px. Grey help text and pale buttons almost always fail.
4. Zoom to 200 %. Does all content remain readable and usable without horizontal scrolling?
5. Form fields. Does every field have a proper label element? Placeholders alone are not enough.
6. Error messages. Are errors described in text and associated with the relevant field, rather than just indicated by a red border?
7. Alternative text. Do images that convey information have meaningful alt attributes? Decorative images should have empty ones.
8. Heading structure. Exactly one H1 per page, followed by a clear hierarchy with no skipped levels.
9. Media. Do videos have captions? Does anything start playing sound automatically?
10. Language declaration. Is the page language set in the HTML so that screen readers pronounce content correctly?

An automated scan with Lighthouse or axe DevTools is a useful addition. Important to know: depending on the study, automated tests find only around a third of actual accessibility barriers. The rest requires manual testing.

If you are already planning a major rebuild, include this test in your preparation. Our Website relaunch checklist explains how it fits into the wider process.

Practical example: Caona Health App

We developed the interface and brand identity for the Caona Health App. Healthcare in particular serves a broad user base: older people, people with impaired vision and people using the app under stress. That is why we worked with clearly defined contrast ratios, large click targets and clearly visible focus states from the outset, rather than adding accessibility at the end.

View the full case study: Caona Health App →

The lesson applies to websites too: contrast and focus are design decisions, not repairs. Make those decisions during screen design and they cost nothing extra. Enforce them retrospectively and you will have to rework the colour palette and components.

What retrofitting costs

The honest answer: it depends on the state of the frontend, not the number of pages.

There is also the cost of assessment: a structured audit with a report and prioritised findings typically costs a low four-figure sum. Our Accessibility audit (BFSG) is designed for exactly this.

The most important commercial point is often overlooked: between a third and half of the fixes also improve conversion. Larger click targets, clearer error messages, more readable typography – these benefit every user, not just those using a screen reader.

The order to follow

1. Establish whether you are affected. Consumer business or not, microenterprise or not. Record the outcome in writing.
2. Carry out the self-test. Work through the ten points above and document them with screenshots.
3. Publish an accessibility statement. Be honest, list known gaps and provide a feedback address.
4. Fix critical journeys first. Everything that leads to completion: forms, basket, checkout, booking.
5. Commission an audit. A detailed assessment is only worthwhile once the obvious errors have been removed.
6. Plan for maintenance. Every new page or plugin can introduce barriers. An annual check is usually enough.