BFSG (German Accessibility Strengthening Act)

The BFSG transposes the EAA in Germany and has applied to listed products and services since 28 June 2025.

21 October 2026 · Category: Accessibility · Compliance-Kit

TL;DR

The Barrierefreiheitsstärkungsgesetz (BFSG) transposes Directive (EU) 2019/882, the European Accessibility Act, in Germany. It applies to products under § 1(2) BFSG that are placed on the market after 28 June 2025 and to services under § 1(3) BFSG that are provided to consumers after that date, such as consumer banking services and e-commerce services. Microenterprises offering or providing services are exempt (§ 3(3) BFSG). Infringements can be fined up to EUR 100,000 (§ 37 BFSG).

What is the BFSG (German Accessibility Strengthening Act)?

The BFSG is the German act transposing Directive (EU) 2019/882 (footnote 1 BFSG). Under the BFSG, products that an economic operator makes available on the market and services that it offers or provides must be accessible (§ 3(1), first sentence, BFSG). They are accessible when persons with disabilities can find, access and use them in the usual way, without particular difficulty and, in principle, without outside help (§ 3(1), second sentence, BFSG). The specific requirements are set by a statutory ordinance under § 3(2) BFSG (§ 3(1), third sentence, BFSG). See also Directive (EU) 2019/882. Member States apply their transposing provisions from 28 June 2025 (Article 31(2) of Directive (EU) 2019/882). The BFSG entered into force on 28 June 2025 (Article 3, first sentence, of the Act of 16 July 2021).

Catalogue under § 1 BFSG:

Products placed on the market after 28 June 2025 (§ 1(2)): consumer general purpose computer hardware systems and their operating systems, payment terminals, ATMs, ticketing and check-in machines, interactive information terminals, consumer terminal equipment with interactive computing capability used for telecommunications services and audiovisual media services, e-readers.
Services provided to consumers after 28 June 2025 (§ 1(3)): telecommunications services, elements of air, bus, rail and waterborne passenger transport services, consumer banking services, e-books and dedicated software, e-commerce services.

Exemptions for content of websites and mobile applications (§ 1(4) BFSG): pre-recorded time-based media and office file formats published before 28 June 2025 (no. 1 and 2), certain online maps (no. 3), third-party content that the operator neither funds, develops nor controls (no. 4) and archives whose content is neither updated nor revised after 28 June 2025 (no. 5).

Microenterprises: § 3(1) does not apply to microenterprises offering or providing services (§ 3(3) BFSG; Article 4(5) of Directive (EU) 2019/882). A microenterprise employs fewer than ten persons and has an annual turnover or an annual balance sheet total of no more than EUR 2 million (§ 2 no. 17 BFSG). The exemption mentions services only.

Benchmark, burden, fines: products and services that conform to harmonised standards or parts thereof whose references have been published in the Official Journal of the EU are presumed to meet the requirements, insofar as the standards cover them (§ 4 BFSG). The BFSG names neither WCAG nor PDF/UA. The requirements apply only insofar as compliance would not impose a disproportionate burden under Annex 4; the operator carries out this assessment itself (§ 17(1) BFSG). Offering or providing a service contrary to § 14(1) can be fined up to EUR 100,000 (§ 37(1) no. 8 and (2) BFSG). The same ceiling applies to the cases in § 37(1) no. 1, 7, 9 and 10; for the other cases it is EUR 10,000 (§ 37(2) BFSG).

Germany and Austria compared

Both countries transpose Directive (EU) 2019/882 through their own acts: Germany through the BFSG, Austria through the BaFG (§ 44 BaFG). Exemptions and the link to standards run in parallel; the penalties differ.

Germany

The BFSG requires service providers to prepare the information under Annex 3 no. 1 and make it available to the public in accessible form (§ 14(1) no. 2 BFSG). In their general terms and conditions or in another clearly perceivable way, they state how their service meets the requirements; this includes the competent market surveillance authority (Annex 3 no. 1, first sentence, and point (d) BFSG). Read more in the article BFSG: accessibility for companies and their documents.

Austria

The BaFG likewise exempts office files published before 28 June 2025 and archives that are not updated (§ 2(3) no. 2 and 5 BaFG). Microenterprises offering or providing services are exempt there too (§ 6(1) BaFG). The BaFG also requires information under Annex 3, which the service provider makes available to the public, including in accessible form (§ 14(2) BaFG). Offering or providing a service contrary to § 14(1) BaFG is an administrative offence: the fine is up to EUR 80,000, or up to EUR 50,000 for microenterprises and small and medium-sized enterprises (§ 36(1) no. 3 and second sentence BaFG).

Point	Germany (BFSG)	Austria (BaFG)
Office files before 28 June 2025	exempt (§ 1(4) no. 2)	exempt (§ 2(3) no. 2)
Archives without updates	exempt (§ 1(4) no. 5)	exempt (§ 2(3) no. 5)
Microenterprises providing services	exempt (§ 3(3))	exempt (§ 6(1))
Presumption of conformity	harmonised standards (§ 4)	harmonised standards (§ 5(1))
Information on the service	Annex 3 (§ 14(1) no. 2)	Annex 3 (§ 14(2))
Maximum for services	fine up to EUR 100,000 (§ 37(1) no. 8 and (2))	fine up to EUR 80,000, SMEs up to EUR 50,000 (§ 36(1) no. 3 and second sentence)

Practical example

An online retailer with 40 employees sells to consumers through its website and therefore provides an e-commerce service (§ 1(3) no. 5 and § 2 no. 26 BFSG). Its product data sheets, published as PDFs in 2023, fall under the exemption for office files (§ 1(4) no. 2 BFSG). A new data sheet that it creates in Word and uploads in October 2025 does not. The same applies to a PowerPoint guide to the ordering process that it publishes as a PDF after 28 June 2025.

In practice, this means you should set up headings, alternative text and the reading order in the source file before you generate the PDF. If you prefer not to remediate existing files in-house, you can have accessible documents prepared. This entry explains the term and is not legal advice.

Frequently asked questions

Since when has the BFSG applied?

The BFSG entered into force on 28 June 2025 (Article 3, first sentence, of the Act of 16 July 2021). It covers products placed on the market after 28 June 2025 and services provided to consumers after 28 June 2025 (§ 1(2) and (3) BFSG). Service providers may continue to use products they lawfully used before 28 June 2025 until 27 June 2030 (§ 38(1) BFSG).

Does the BFSG apply to older PDFs on a website?

No, insofar as they are office file formats published before 28 June 2025 (§ 1(4) no. 2 BFSG). Archives are exempt as long as their content is neither updated nor revised after 28 June 2025 (§ 1(4) no. 5 BFSG). Files published from 28 June 2025 onwards are not covered by the exemption.

Are microenterprises exempt from the BFSG?

Microenterprises offering or providing services do not have to meet the obligation in § 3(1) (§ 3(3) BFSG). A microenterprise has fewer than ten employees and an annual turnover or balance sheet total of no more than EUR 2 million (§ 2 no. 17 BFSG). The exemption mentions services only.

What fines does the BFSG provide for?

Offering or providing a service contrary to § 14(1) can be fined up to EUR 100,000 (§ 37(1) no. 8 and (2) BFSG). For other administrative offences, such as failing to provide information requested by the market surveillance authority, the ceiling is EUR 10,000 (§ 37(1) no. 6 and (2) BFSG).

Sources

Barrierefreiheitsstärkungsgesetz (BFSG), German Accessibility Strengthening Act, Fußnote 1 (Umsetzung RL 2019/882); § 1 Abs. 2, 3 und 4 Nr. 1 bis 5; § 2 Nr. 17 und 26; § 3 Abs. 1 Satz 1 bis 3 und Abs. 3; § 4; § 14 Abs. 1 Nr. 2; § 17 Abs. 1; § 37 Abs. 1 Nr. 1, 6, 7, 8, 9, 10 und Abs. 2; § 38 Abs. 1; Anlage 3 Nr. 1 Satz 1 und lit. d; Inkrafttreten 28.06.2025 (Art. 3 Satz 1 G v. 16.07.2021), gesetze-im-internet.de
Directive (EU) 2019/882 (European Accessibility Act), Art. 4(5); Art. 31(2), eur-lex.europa.eu
Barrierefreiheitsgesetz (BaFG), Austrian Accessibility Act, consolidated version, § 2(3) no. 2 and 5; § 5(1); § 6(1); § 14(2); § 36(1) no. 3 and second sentence (microenterprises and SMEs); § 44, ris.bka.gv.at

Legal status of the sources checked: 19 October 2026 (RIS, gesetze-im-internet.de, EUR-Lex)

Practitioner note: This article is practice-oriented compliance documentation, not legal advice. We are compliance specialists, not a law firm. For legally binding advice, consult an admitted lawyer.