Web & Design
Accessible websites: what the BFSG requires from 2025
Who is affected by Germany’s Accessibility Strengthening Act, what do market surveillance authorities check, and what does retrofitting cost? A guide with a 10-point self-test.
Short answer
Germany’s Accessibility Strengthening Act (BFSG) has applied since 28. Juni 2025. It primarily affects businesses offering digital services to consumers: online shops, bookings, banking services, e-books and telecommunications. Purely B2B offerings and microenterprises with fewer than 10 employees and annual turnover of no more than 2 Mio. Euro are exempt for services. The technical benchmark is EN 301 549, which adopts WCAG 2.1 Level AA for web content. In our experience, retrofitting an existing website costs between 2.000 and 15.000 Euro, depending on the size and condition of the frontend.
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.
Kernaussage
Accessibility is not a design issue or an optional extra. It is a requirement for the technical implementation of the frontend – structure, contrast, focus, labelling.
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.
| Scenario | BFSG requirement | Note |
|---|---|---|
| Online shop for consumers | Yes | Typical use case, including checkout |
| Appointment booking for practices, studios, law firms | Yes | Consumer service |
| Purely informational company website with no transactions | No | Note: adding bookings or a shop changes this |
| B2B portal, supplier platform | No | No consumer business |
| Microenterprise with a shop | Yes | Exemption applies only to services, not products |
| Public body | Yes | Already regulated under BITV 2.0 |
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:
- Perceivable – content must be visible or audible: contrast, alternative text, captions.
- Operable – everything accessible by keyboard, enough time, no flashing effects.
- Understandable – clear language, predictable navigation, helpful error messages.
- Robust – clean HTML that screen readers and assistive tools interpret correctly.
Most websites do not fail on obscure issues, but on four things: insufficient contrast, invisible keyboard focus, form fields without proper labels and buttons that are actually divs. These can be fixed in a single sprint if addressed early.
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:
- A complaint is received or a spot check is initiated.
- The authority requests documentation, usually the accessibility statement and technical information.
- The function in question is then assessed, usually with assistive technology and automated tools.
- If shortcomings are found, a request for remediation is issued with a deadline.
- 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.
Kernaussage
Two things should be in place immediately: an accessibility statement and a feedback channel for reporting barriers. Both can be set up in a day and address the most common initial finding.
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.
- 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?
- Visible focus. Is it clear where you are at every Tab step? Removing the focus outline with
outline: noneis the most common individual error. - 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.
- Zoom to 200 %. Does all content remain readable and usable without horizontal scrolling?
- Form fields. Does every field have a proper label element? Placeholders alone are not enough.
- Error messages. Are errors described in text and associated with the relevant field, rather than just indicated by a red border?
- Alternative text. Do images that convey information have meaningful alt attributes? Decorative images should have empty ones.
- Heading structure. Exactly one H1 per page, followed by a clear hierarchy with no skipped levels.
- Media. Do videos have captions? Does anything start playing sound automatically?
- 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.
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.
| Starting point | Typical effort | Approximate cost |
|---|---|---|
| Modern website, clean components, only contrast and focus fixes needed | 2–4 days | 2.000–4.000 € |
| Medium-sized website with forms and booking, some custom components | 1–2 weeks | 5.000–9.000 € |
| Shop that has grown over time, many plugins, old templates | 3–6 weeks | 10.000–15.000 € |
| New development with accessibility built in from the start | included in the project | no additional charge |
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
- Establish whether you are affected. Consumer business or not, microenterprise or not. Record the outcome in writing.
- Carry out the self-test. Work through the ten points above and document them with screenshots.
- Publish an accessibility statement. Be honest, list known gaps and provide a feedback address.
- Fix critical journeys first. Everything that leads to completion: forms, basket, checkout, booking.
- Commission an audit. A detailed assessment is only worthwhile once the obvious errors have been removed.
- Plan for maintenance. Every new page or plugin can introduce barriers. An annual check is usually enough.
We assess your website against WCAG 2.1 AA, document every finding with a screenshot and provide a prioritised action list that your developers can work through directly.
Frequently asked questions
When does the requirement for accessible websites apply?+
Germany’s Accessibility Strengthening Act has applied since 28. Juni 2025. There are transitional periods for certain self-service terminals and ongoing service contracts, but the requirement has applied to consumer-facing websites since that date.
Who must have an accessible website?+
Businesses offering digital services to consumers: online shops, booking and customer portals, banking and telecommunications services, e-books and passenger transport. Purely B2B offerings are exempt.
Are microenterprises exempt from the BFSG?+
For services, yes, provided they employ fewer than 10 people and their annual turnover or annual balance sheet total does not exceed 2 Mio. Euro. This exemption does not apply to products.
What does WCAG 2.1 AA mean in practice?+
WCAG 2.1 Level AA is the technical assessment benchmark behind the law. Among other things, it requires text contrast of at least 4,5:1, full keyboard operability, visible focus, labelled form fields and alternative text for images that convey information.
How do I check whether my website is accessible?+
Start with a manual test: keyboard-only operation, zoom to 200 Prozent, contrast checks and form labels. Supplement this with automated tools such as Lighthouse or axe DevTools. Automated tests find only some barriers; the rest requires manual testing.
What are the consequences of breaching the BFSG?+
Market surveillance authorities can order remediation, prohibit the provision of a service and impose fines. In practice, the first step is usually a request with a deadline, rather than an immediate fine.
Do I need an accessibility statement?+
Yes. It must be publicly available, describe the current state of accessibility, identify known gaps and provide a way to report barriers. It is usually the first thing an authority checks.
What does it cost to make an existing website accessible?+
For a modern, well-built website, contrast and focus corrections alone cost around 2.000 to 4.000 Euro. Shops that have grown over time and use many plugins are more likely to cost between 10.000 and 15.000 Euro. For new developments, there is no additional charge if accessibility is planned in from the outset.
Is an accessibility overlay or widget enough?+
No. Overlays do not fix structural problems in the HTML and are criticised by disability advocacy organisations. They will not pass an assessment if the underlying focus behaviour, semantics and form labels remain faulty.
Sources
- Barrierefreiheitsstärkungsgesetz (BFSG), Bundesministerium der Justiz (2021-07-16)
- EN 301 549 – Accessibility requirements for ICT products and services, ETSI (2021-03-01)
#Accessibility#BFSG#WCAG#Web & Digital
Author
Josef KujawskiManaging Director & Creative Director at Maluure
Josef leads the strategic and creative development of brands at Maluure. For over a decade, he has guided medium-sized businesses from brand positioning to digital delivery.
Managing Director of Maluure GmbH, Cologne. Specialising in corporate design, brand strategy and digital brand experiences.
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