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.