BFSG 2026: The Complete Guide
to the Accessibility Strengthening Act
Since June 28, 2025, the Barrierefreiheitsstärkungsgesetz (BFSG) applies to websites and apps that consumers use to enter into contracts. This guide explains who it covers, what it requires and how it is enforced.
28.06.2025
The BFSG applies to covered products and services (Section 1 BFSG)
95.9%
of home pages tested had at least one WCAG failure (WebAIM Million 2026). Most of those errors are on pages your customers use every day.
No trigger needed
The authority also checks services by random sampling (Section 28(2) BFSG)
26.09.2025
MLBF established
WCAG 2.1 EN 301 549 EAA 2019/882 BFSG BFSGV BITV 2.0 BaFG (AT) BehiG (CH)
What is the Accessibility Strengthening Act (BFSG)?
The BFSG, Germany’s implementation of EU Directive (EU) 2019/882 (European Accessibility Act, EAA), requires economic operators to make digital products and services accessible to consumers with disabilities. It was promulgated on 16 July 2021 and fully entered into force on 28 June 2025. The specific technical requirements are not defined in the BFSG itself, but in the associated regulation (BFSGV). Unlike the older Disability Equality Act (BGG), which primarily addresses public authorities, the BFSG applies to the private sector. The BFSG requires compliance with EN 301 549, the harmonised European standard for ICT accessibility, which refers to WCAG 2.1 Level AA for web content. Compliance with EN 301 549 creates a presumption of conformity.
Who is affected by the BFSG?
Which industries are particularly affected?
What the BFSG actually requires
The BFSG creates a four-level technical obligation chain. Each level narrows the standard down to what developers and designers actually work on:
- BFSG (Act) - establishes the obligation but does not itself define the technical standard
- BFSGV (Regulation) - specifies requirements for accessible design
- EN 301 549 (technical standard) - integrates WCAG 2.1 Level AA for web and mobile content; compliance creates a presumption of BFSG conformity
- Accessibility statement (mandatory document) - must state conformity status, known limitations, contact point, and responsible authority, with the current status
Compliance is assessed according to the four WCAG principles:
- Perceivable - alternative texts, contrast, scalable text, captions
- Operable - complete keyboard operation, sufficient time, no seizure-triggering content
- Understandable - consistent navigation, understandable error messages, predictable behaviour
- Robust - compatible with screen readers and other assistive technologies
Deadlines and transition provisions
| Date | Meaning |
| 28.06.2025 | BFSG (DE) and BaFG (AT) fully entered into force - no transition period for new websites/contracts |
| 27.06.2030 | End of transition period for service contracts concluded before 28.06.2025 |
| 01.01.2027 | Planned entry into force of the BehiG revision (CH) for private providers |
Enforcement and fines
Responsibility for market surveillance lies with the federal states (jointly coordinated through the MLBF), with partly different authority structures. The typical process:
- The authority requests information regarding compliance with accessibility requirements
- It orders implementation within a specified deadline
- If reasonable corrective measures are not taken, a renewed order with a threat of prohibition may follow
- As a final measure: prohibition of the offering
The BFSG treats breaches as administrative offences (Section 37 BFSG). The possible fines are substantial. In addition to administrative enforcement, consumers and qualified organisations may access the BGG conciliation body (§34 BFSG), and associations may bring legal action through collective action rights (§15a UKlaG).
BFSG across the entire DACH region
The BFSG is Germany’s implementation of the EAA. Austria and Switzerland are each following their own approaches.
Even though the revised BehiG will only directly obligate private providers in Switzerland from 2027, every Swiss company offering products or services to consumers in Germany or Austria has already been subject to the market location principle since June 2025. Anyone selling into the German or Austrian market must comply with BFSG or BaFG requirements, regardless of their company headquarters.
What continuous BFSG compliance means
An audit answers one question: Which violations exist on this platform at this moment? It does not cover the next deployment and does not document fixes from last month. As soon as a new product page goes live, a checkout component is updated, or a third-party script is installed, the audit no longer reflects the platform.
Frequently Asked Questions (FAQ)
A widget changes how visitors see a page, such as text size or contrast. The code behind it stays as it is: missing form labels, images without alt text, a checkout that does not work with a keyboard. The BFSG requires the service itself to be accessible. A widget can support that work but does not replace it.
Yes. The BFSG covers every part of a digital offering with which consumers interact, including checkout and account dashboards.
For websites, there is no transition period for new content. The obligation has applied directly since 28 June 2025, including for existing content. An exception only applies to service contracts concluded before 28.06.2025 (transition period until 27.06.2030).
Yes. Each national authority acts independently, without a cross-border fine ceiling.
Document your efforts immediately. An active remediation programme and a current accessibility statement provide your strongest protection.
No. The current reference standard EN 301 549 v3.2.1 is based on WCAG 2.1 AA. Meeting WCAG 2.2 AA is already advisable today, as future adjustments to the standard are expected to move in this direction.
The BGG (Disability Equality Act) primarily obligates public authorities. The BFSG applies to private businesses offering certain products and services to consumers.
No, only partially. Microenterprises are exempt exclusively for services, not products. Anyone manufacturing self-service terminals remains obligated.
There is no legally fixed inspection frequency. Given the continuous development of websites, continuous monitoring is recommended instead of a one-time annual audit. Every deployment can introduce new WCAG violations.
Ready to Improve Your Website Accessibility?
Talk to Stefan, our Digital Accessibility Expert, for practical guidance on your accessibility challenges, audit findings, and next steps.