BFSG: Who Is Affected by the Accessibility Strengthening Act?
Since 28 June 2025, the Accessibility Strengthening Act (BFSG) has been in force – and with it, the obligation to make digital products and services accessible to all users. But which companies and economic operators are actually covered by the law? And what exemptions exist? Here's a clear overview of the rules and requirements.
The Key Facts at a Glance
Who Falls Under the BFSG – At a Glance
The BFSG applies to all economic operators in the B2C space – from online shops to banks to manufacturers of digital products. These four points summarize what affected companies need to know.
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Covers manufacturers, distributors, importers, and service providers in the B2C space
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Microenterprises are exempt only for services, not as product manufacturers
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A transition period until 2030 applies to products already on the market
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Violations can result in fines of up to €100,000
What Does the BFSG Regulate?
The Accessibility Strengthening Act (BFSG) implements EU Directive 2019/882 (European Accessibility Act) into German law. It requires companies to design their digital products and services so they are accessible to people with disabilities. The technical basis for implementation is the international WCAG guidelines (Web Content Accessibility Guidelines) and the European standard EN 301 549.
The law covers the entire B2C business sector – meaning all companies offering products or services to consumers. It applies equally to manufacturers, distributors, and importers. Compliance with accessibility requirements in Germany is monitored by the market surveillance authority. Violations can result in fines of up to €100,000 and exclusion from the market.
Important: the BFSG explicitly does not apply to purely B2B business. Companies that exclusively provide products or services to other businesses generally do not fall under the regulation – unless the offering is also directed at consumers.
Which Products and Services Fall Under the BFSG?
The BFSG specifically defines which digital products and services fall under the accessibility requirements. Companies offering any of the following in the B2C space are required to implement them.
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Websites and web applications: online shops, portals, content platforms, and any digital web content
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Mobile apps and applications: apps for smartphones, tablets, and other mobile devices
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E-commerce: digital sales platforms and commerce solutions for consumer transactions
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Banking services: online banking, digital financial services, and payment applications
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Self-service terminals and ATMs: interactive terminals in public and private settings
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E-books and associated reading applications
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Computers and operating systems: hardware and software for consumers
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Telecommunications services with internet access
Who Are the Affected Economic Operators?
The BFSG isn't just aimed at online shops or app providers. It defines a clear group of economic operators required to comply with accessibility requirements – regardless of whether they manufacture, import, or sell.
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Manufacturers: companies that develop accessible products and place them on the market
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Distributors: anyone offering accessible products to consumers as part of their business – for example online shops
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Importers: companies bringing products from third countries into the EU and making them available to consumers
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Service providers: anyone providing digital services to consumers – from banking services to e-commerce platforms
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Operators of self-service terminals: for example ATMs, ticket machines, or interactive kiosk systems
Who Is Not Affected?
The BFSG includes targeted exemptions. What matters is company size, annual revenue, and the specific scope of application.
Exemption for Service Providers
Companies with fewer than 10 employees and no more than €2M in annual revenue are exempt from the service obligations. This exemption does not apply to product manufacturers.
Disproportionate Burden
If implementation would represent a disproportionate economic burden, an exemption can be requested – with detailed justification and documentation.
Transition Period for Existing Products
Products lawfully placed on the market before 28 June 2025 may continue to be provided until 27 June 2030. Self-service terminals have a deadline of up to 2040.
Purely B2B Business
Companies operating exclusively in the B2B space, offering no products or services to consumers, do not fall under the BFSG.
Important: These exemptions don't apply automatically in every case. We recommend having your specific situation reviewed through expert consultation. SiteCockpit does not provide legal advice.
Requirements: What Do Affected Companies Need to Implement?
Companies covered by the BFSG must design their digital products and services according to the WCAG standards and the European standard EN 301 549. SiteCockpit supports you in technically implementing all relevant requirements.
Accessible Content & Text
All digital content – text, images, videos, and web applications – must be accessible to people with disabilities. The WCAG guidelines form the basis. A feedback mechanism that lets users report barriers is also legally required.
Explore easyVisionRegular Accessibility Testing
Compliance with accessibility requirements must be monitored continuously. Only regular testing provides the evidence needed for the market surveillance authority.
Explore easyMonitoringPublish an Accessibility Statement
All covered companies are required to publish an accessibility statement. This documents the current state of accessibility, names known deficiencies, and provides contact options for user feedback.
Explore easyStatementSiteCockpit easyMonitoring