Barrierefreiheitsstärkungsgesetz (BFSG) — Guide for Web Agencies

What is the BFSG?

The Barrierefreiheitsstärkungsgesetz (BFSG) is Germany's implementation of EU Directive 2019/882 (European Accessibility Act). It requires businesses to make their digital products and services accessible.

The law has been in force since 28. Juni 2025. The technical basis is EN 301 549, which references WCAG 2.1 Level AA.

Who must comply with the BFSG?

All businesses selling digital products or services to consumers in the EU, except:

• Microenterprises — fewer than 10 employees AND annual turnover under EUR 2 million (for services only)
• Covered sectors: e-commerce, banking, telecommunications, passenger transport, e-books

What are the fines?

The BFSG provides for fines of up to EUR 100,000 per violation. The market surveillance authorities of the federal states are responsible for enforcement.

Additionally, non-compliant products and services can be excluded from the German market.

Source: WebYes EAA Fines 2025

The most common WCAG violations

According to the WebAIM 2025 study (1 million homepages analysed): (WebAIM 2025)

1. Insufficient contrast — 79.1% of pages
2. Missing image alt text — 55.5% of pages
3. Missing form labels — 48.2% of pages
4. Empty links — 45.4% of pages
5. Empty buttons — 29.6% of pages
6. Missing document language — 15.8% of pages

Why overlays don't work

Accessibility overlay widgets (JavaScript plugins that claim to "fix" accessibility automatically) have been proven ineffective:

• The FTC fined accessiBe $1 million (April 2025) for misleading claims — Source: FTC
• 22.6% of accessibility lawsuits in 2025 targeted websites with overlay widgets

How to achieve BFSG compliance

1. Automated scanning — Tools like WCAGAlert detect ~57% of WCAG issues automatically.
2. Fix the code — Add alt text, improve contrast, add form labels.
3. Manual testing — Test with keyboard navigation and screen reader (NVDA, VoiceOver).
4. Continuous monitoring — Accessibility is not a one-time fix. Monitor continuously.