Since 28 June 2025 (BFSG), Germany's Accessibility Reinforcement Act (Barrierefreiheitsstärkungsgesetz, BFSG) has brought a duty that many companies previously knew only from the public sector: certain digital products and services must be accessible. This explicitly includes the websites and online shops of companies that serve consumers. For many businesses this raises a clear question for the first time: does my website meet the requirements, or do I risk complaints and, in the worst case, a fine? This guide explains in plain terms what the Act is about, who is obliged and who is exempt, what the technical benchmark WCAG 2.2 at level AA means in practice, and in which steps a website becomes accessible. There is no formal certificate issued by an authority, but a clean, documented approach clearly improves the starting position and makes the website better for everyone at the same time.
What the Accessibility Act Is and When It Applies
The Accessibility Reinforcement Act, BFSG for short, transposes the European directive on accessibility requirements for products and services (EU Directive 2019/882), also known as the European Accessibility Act, into German law. The aim is a uniform European framework: anyone offering digital services to consumers should design them so that people with different abilities can use them without outside help. The law took effect on 28 June 2025 (BFSG). Unlike public administration, which has long been obliged to provide accessibility, private-sector providers in the consumer business are now covered as well.
Accessibility is not a service for a small fringe group. Worldwide, around 16 percent (WHO) of people live with a disability, roughly 1.3 billion people. In Germany, about 7.8 million (Destatis) people were registered as severely disabled at the end of 2023. On top of that, many people have temporary or age-related limitations, for example after an injury or due to declining eyesight. An accessible website therefore reaches a group that often fails at poorly operable pages today and then moves on to the next provider.
Key Facts at a Glance
Who Is Obliged and Who Remains Exempt
The BFSG addresses manufacturers, dealers and service providers who offer certain products and services to consumers. Especially relevant for the web is the category of services in electronic commerce, colloquially online trade. This covers any website or app through which consumers can enter into contracts for goods or services, so the classic online shop as well as a booking system, an appointment portal or a registration process with a payment function. Areas such as consumer banking services, passenger transport, telecommunications and e-books are also explicitly included.
Not every simple company website is automatically covered. A pure business-card page without any contract conclusion does not initially fall under the electronic-commerce duty. However, as soon as a transaction is possible, for example a shopping cart, an online booking or a paid contract, the law applies. The line therefore does not run along company size but along the function of the site. Anyone unsure whether their own website is affected should have the specific functions checked rather than relying on a rough estimate.
- Online shops and sales platforms with cart and checkout
- Booking and appointment portals with a binding conclusion
- Customer accounts and sign-up processes for paid services
- Banking services and payment services for consumers
- Travel and ticket bookings in passenger transport
- E-books, e-book software and the associated reading apps
Exemption for Micro-Enterprises Providing Services
What WCAG 2.2 AA Means in Practice
The BFSG itself does not name individual technical rules but refers to the harmonised European standard EN 301 549. For web content, this standard draws on the Web Content Accessibility Guidelines, WCAG for short, at level AA. In practice, the current version WCAG 2.2 at conformance level AA is the decisive benchmark. The WCAG are organised around four principles, known by the initials POUR: perceivable, operable, understandable and robust. These four principles provide a good map for understanding accessibility not as a checklist of individual tricks but as a consistent property of the website.
Perceivable
Content must be accessible to different senses: alt text for images, sufficient colour contrast and a clear heading structure.
Operable
Everything can be operated by keyboard, the focus is visible, there are no time traps and buttons are large enough to hit.
Understandable
Language and flow are clear, form fields are labelled and error messages explain in a comprehensible way what to do.
Robust
The code is valid and semantic, so screen readers and other assistive tools can reliably read out the content.
Version 2.2 added several new success criteria compared with previous versions, above all improving operation with keyboard, mouse and touch. These include that a focused element must not be hidden by fixed elements such as sticky headers, that actions performed by dragging must also be possible with a simple tap, and that interactive targets such as buttons should have a minimum size of 24 by 24 (WCAG 2.2) pixels. Also new is the requirement that information already entered in the same process should not be requested again unnecessarily and that a sign-in must be possible without pure memory effort such as recalling complicated character strings.
New Criteria in WCAG 2.2 at a Glance
The Most Common Barriers on Websites
Many barriers arise not from ill will but from habit and a lack of testing. The annual analysis of one million home pages shows the scale: around 94.8 percent (WebAIM) of the home pages examined had automatically detectable WCAG failures, on average about 51 (WebAIM) errors per page. By far the most common defect was insufficient text contrast, present on around 79.1 percent (WebAIM) of pages. Automated tests only detect part of the problems, so the actual number of barriers is usually even higher. The good news: a large share of these errors is known, well documented and fixable with clear measures.
- Insufficient contrast between text and background
- Missing or meaningless alt text on images
- Form fields without an associated label
- Links whose text says nothing without context, such as more
- Content that cannot be reached fully by keyboard
- Missing or invisible focus outline when navigating
- Colour as the only carrier of information, such as red alone for errors
An Accessible Website in Five Steps
Accessibility can be approached methodically rather than treated as an unmanageable mountain. A proven approach begins with an honest inventory and leads into ongoing maintenance. The order matters: first measure where the website stands, then tackle the most impactful issues first. This creates noticeable progress quickly without getting lost in detail.
1. Inventory and Audit
The website is tested with automated tools and manually against WCAG 2.2 AA. Besides test software, this includes keyboard tests and a run-through with a screen reader, because many barriers only become visible in real operation.
On the technical level, the difference often shows in small but effective details. An image needs alt text describing its purpose, a form field needs a visibly associated label and a required field a machine-readable marking. The following example shows how to mark up an accessible form field and an image.
<!-- Image with meaningful alt text -->
<img src="team.jpg" alt="Two XICWEB staff members at a desk">
<!-- Associated label and required-field marking -->
<label for="email">Email address</label>
<input
id="email"
name="email"
type="email"
autocomplete="email"
aria-required="true">
<!-- Skip link as the first focusable element -->
<a class="skip-link" href="#content">Skip to content</a>Effort, Cost and Ongoing Maintenance
The effort for an accessible website depends heavily on the starting point. A technically clean, modern site usually needs targeted corrections to contrast, focus and forms, whereas an aging site with tangled code tends to call for a relaunch. In many cases it is more economical to build accessibility into a redesign that is planned anyway rather than to bolt it on afterwards. An initial accessibility check with a prioritised action plan is often available for a manageable amount in the low four-figure range net and creates a solid basis for further planning without immediately tying up the entire budget.
| Aspect | Website without accessibility | Accessible website |
|---|---|---|
| Accessibility Act requirements | Complaints and fine possible | Standard requirements are addressed |
| Reachable audience | Users with limitations fail | Considerably larger group of users |
| Operability for all | Frustration at forms and navigation | Clear, consistent operation |
| Search engines | Unclear structure, weak semantics | Clean semantics help findability |
| Maintenance | Barriers grow back unnoticed | Accessibility is part of the process |
Accessibility pays off beyond mere compliance. A clearly structured, semantically clean website is at the same time a good basis for findability in search engines, as we describe in our article on the SEO basics for businesses. Well-labelled forms and clear guidance also lower the hurdles to an enquiry, a topic we explore in conversion optimisation for more enquiries. And because many barriers stem from outdated technology, it is worth looking at typical mistakes in a website relaunch as well as fast loading times, which we cover in our article on Core Web Vitals. If you are setting up data protection cleanly in parallel, our GDPR website checklist provides the matching steps.
A word on expectations belongs here. No one can seriously promise permanently complete conformance or an official clearance, because websites change constantly and the assessment of individual criteria depends on context. What can be planned and evidenced is a transparent approach: measure, prioritise, implement, document and maintain. From our project work (Projekterfahrung) we know that continuous, clean work carries further in the long run than a one-off effort shortly before a deadline.