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BFSG2026-08-12

BFSG and WCAG: What the Accessibility Strengthening Act Requires Technically

Stephanie Escarciga (opens in a new tab)

Germany's Accessibility Strengthening Act (BFSG) has applied since 28 June 2025. It implements the EU's European Accessibility Act. The act sets requirements for online shops and many digital services for consumers.

Status: October 2026

From EU law to testable rules

The BFSG sits within four layers:

  • European Accessibility Act (Directive (EU) 2019/882): the EU-wide accessibility requirement
  • BFSG: the German law that defines who is covered and how compliance is enforced
  • EN 301 549: the European standard that describes what accessible means technically
  • WCAG 2.1, Level AA: the testable criteria for websites and web applications that EN 301 549 refers to

Who the BFSG covers

The law applies to certain products and services for consumers. These include:

  • online shops and other e-commerce services
  • banking and payment services
  • e-books and e-reading software
  • telecommunications services
  • hardware such as computers, smartphones, e-readers and self-service terminals

Micro-enterprises are exempt insofar as they provide services. A micro-enterprise has fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million. The exemption does not apply to products. Offerings aimed exclusively at businesses are not covered by the BFSG.

Whether the obligation applies to your company is a question for your legal advisor.

Transition periods

There is no transition period for an online shop's website. Transition rules apply only in specific cases:

  • service contracts concluded before 28 June 2025, until 27 June 2030 at the latest
  • products used to provide a service before 28 June 2025, until 27 June 2030
  • self-service terminals until the end of their useful life, at most 15 years after they were put into service

Supervision and fines

Compliance is monitored by the joint market surveillance authority of the German federal states for the accessibility of products and services (MLBF) in Magdeburg. Violations can be fined up to €100,000. Warning letters under competition law are also possible.

Service providers must also state in an accessibility statement how their offering meets the requirements.

The four WCAG principles

Every WCAG criterion belongs to one of four principles:

  • Perceivable: content can be perceived, for example through alternative text for images, sufficient contrast and captions for videos.
  • Operable: the page can be fully controlled by keyboard, and focus is visible at all times.
  • Understandable: labels, navigation and error messages are clear.
  • Robust: the code is structured so that screen readers and other assistive technologies can read it reliably.

The three levels

  • Level A: the baseline, for example alternative text for every image
  • Level AA: the level EN 301 549 refers to, for example a contrast ratio of at least 4.5:1 for normal text
  • Level AAA: the highest level, for example sign language for prerecorded audio; not legally required

WCAG 2.2 and the new EN 301 549

On 2 September 2026, ETSI published EN 301 549 version 4.1.1. For web content, it refers to WCAG 2.2, Level AA. It becomes authoritative for the BFSG once the European Commission cites it in the Official Journal of the EU. Until then, WCAG 2.1 AA remains the benchmark.

WCAG 2.2 adds, among others, these Level A and AA criteria:

  • Keyboard focus is not entirely hidden by other content, such as sticky bars or buttons.
  • Click targets are at least 24 × 24 pixels or have enough spacing between them.
  • Anything operated by dragging also works with a single click.
  • Help options that appear on several pages are in the same place on each of them.
  • Information already entered in the same process does not have to be entered again.
  • Logging in does not require a memory or calculation task; passwords can be pasted, for example.

Typical barriers in online shops

  • images without alternative text
  • insufficient contrast on buttons or body text
  • form fields without an associated label
  • clickable div elements instead of real buttons: they cannot be reached by keyboard, and screen readers do not recognise them as buttons
  • missing or invisible keyboard focus
  • error messages that are shown but not announced
  • pages that force horizontal scrolling at a width of 320 CSS pixels

An example of contrast: grey text in #999999 on white reaches about 2.8:1 and fails. Text in #767676 reaches 4.5:1 and passes.

How barriers are found

Automated tools such as axe-core or Lighthouse quickly find missing alternative text, contrast errors and missing labels. However, they detect only part of the barriers.

The rest only shows up in manual testing:

  • Keyboard: can every element be reached and operated without a mouse, in a logical order?
  • Screen readers such as NVDA or VoiceOver: are fields, images and error messages announced correctly?
  • Zoom: does the page remain usable at 200% text size, and does it reflow at a width of 320 CSS pixels without horizontal scrolling?

Only both types of testing together give a complete picture.

Seovantis tests defined pages and processes against WCAG 2.1 AA and fixes barriers directly in the code of online shops and portals: Accessibility in the code

What accessibility overlays can and cannot do

Accessibility overlays place a toolbar on top of the page. Visitors can use it to change font size or contrast. They do not change the code of the page.

The monitoring bodies of the German federal government and the federal states have published a joint assessment on this (as of March 2025). According to it, overlay tools currently cannot make a website with existing barriers fully accessible. They can even create new barriers, for example in combination with screen readers.

Barriers can therefore only be fixed where they arise: in the code of the page.

Sources

Related service

Accessibility (BFSG)

Accessibility audit at a fixed price: Quick Check from €490 net, audits against WCAG 2.1 levels A and AA, fixes in the code on request.

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