What is the Accessibility Reinforcement Act (BFSG)? What businesses need to know

Starting June 28, 2025, the Accessibility Reinforcement Act (BFSG) will be legally binding for many digital products and services in Germany. What legal foundations apply, how can one assess the accessibility of a website, and which tools facilitate efficient implementation?

Legal foundation: EU Directive becomes German law

The origin of the Accessibility Reinforcement Act (or the BFSG in German) lies at EU level. With Directive (EU) 2019/882, known as the European Accessibility Act (EAA), the European Union established a unified legal framework to reduce digital barriers in products and services. The goal is a uniform minimum standard for accessibility within the EU internal market.

This directive was adopted on April 17, 2019, and had to be transposed into national law by June 28, 2022, at the latest. Germany did so with the Accessibility Reinforcement Act (BFSG), published in the Federal Law Gazette on July 22, 2021. The practical compliance deadline for affected businesses is June 28, 2025.

For Canadian companies operating in or targeting the EU market, compliance with EAA regulations is essential. While accessibility in Canada is governed by laws such as the Accessible Canada Act (ACA) and various provincial regulations (e.g., AODA in Ontario), the European Accessibility Act (EAA) introduces distinct and additional requirements for products and services offered within the European Union.

Therefore, Canadian businesses should evaluate their digital platforms, services, and products to ensure they comply with both Canadian accessibility standards and EAA requirements when operating in or marketing to the EU. This includes websites, mobile applications, e-commerce platforms, and digital communications tools.

Who is affected?

The Accessibility Reinforcement Act (BFSG) applies to a wide range of products and services, including:

• E-commerce websites and online stores
• Digital booking systems and banking apps
• Self-service terminals (e.g., ATMs)
• Digital devices such as smartphones, routers, or e-book readers
• Software with end-user interfaces (e.g., login-based apps)

Microenterprises are exempt only if they exclusively provide services — once they manufacture or sell products, the law applies to them.

What exactly does the Law require?

The Accessibility Reinforcement Act (BFSG) requires many businesses to make their digital offerings accessible starting June 28, 2025. The requirements are based on several levels — international, European, and national:

• The WCAG (Web Content Accessibility Guidelines) were developed by the W3C and have long served as the international standard for accessible web design. They define specific success criteria for accessible content and user interactions.
• Building on the WCAG, the European Accessibility Act (EAA) was adopted in 2019 as an EU directive. It mandates that certain digital products and services within the EU must be accessible.
• In 2021, the EAA was transposed into German national law through the Accessibility Reinforcement Act (BFSG). This law defines which businesses are affected, what penalties may apply in case of violations and what specific requirements must be implemented.
• In practice, compliance is guided by EN 301 549. This harmonized European technical standard translates the requirements of the EAA and WCAG into concrete terms — for example, regarding color contrast, keyboard navigation or alternative text.

Check: Does your website comply with the Accessibility Reinforcement Act (BFSG)?

If your company is affected, take the following steps:

1. Analysis & audit: Use tools like Lighthouse, axe DevTools, WAVE, or the BITV-Test.
2. Follow standards: Ensure compliance with WCAG 2.2 and EN 301 549.
3. Publish an accessibility statement: Promote transparency and gather user feedback.
4. Ongoing testing & maintenance: Accessibility is not a one-time project.

Tools and plugins for support

When reviewing accessibility, tools like Google Lighthouse can be extremely helpful. Each of the following tools offers specific benefits:

Maintenance and updates

Implementing accessibility requirements is not a one-time project. Instead, the Accessibility Reinforcement Act (BFSG) mandates that accessibility must be continuously ensured, even as digital offerings are updated or modified.

In practice, this means that whenever you make technical or content-related changes to your website — whether through new features, a website relaunch or a design update — these changes must be re-tested for accessibility and implemented in compliance with current standards.

This is especially important for:

• New or revised pages, forms or navigation elements
• New multimedia content such as videos, PDFs, or graphics
• System changes, e.g., switching CMS or web hosting provider
• Integration of third-party components (e.g., booking tools)

Even existing content should be reviewed regularly to ensure ongoing compliance.

Recommendation

To ensure long-term compliance with legal requirements, companies should establish accessibility as an integral part of their digital maintenance processes. A structured maintenance plan helps to regularly review technical and editorial changes and identify barriers at an early stage. This includes:

• Regular manual and automated audits (e.g., every six months)
• Training for web teams and content editors
• Feedback mechanisms to allow users to report accessibility issues
• Updating the accessibility statement whenever content or functionality changes

What are the risks of non-compliance?

Starting June 28, 2025, violations of the Accessibility Reinforcement Act (BFSG) will be subject to legal penalties. Potential consequences include:

• Fines of up to €100,000 (around $114,000) in EU markets
• Cease and desist orders and legal actions under competition law
• Loss of public funding or subsidies
• Reputational damage
• Lower search engine rankings

Checklist: How to achieve digital accessibility

This overview summarizes the key requirements for accessible websites based on the WCAG and EN 301 549 standards:

The Accessibility Reinforcement Act (BSFG) is more than just a regulatory obligation — it’s a call for greater inclusion in the digital space. It also presents an opportunity for businesses to expand their reach, tap into new target audiences and remain competitive in the long term.