The BFSG for product teams: obligations, deadlines, fines.
The Barrierefreiheitsstärkungsgesetz implements the European Accessibility Act in Germany. This overview is written for product and engineering teams.
By Peter Csipkay 1 min read
Timeline
- 2019 The EU adopts the European Accessibility Act
- 2021 The BFSG is promulgated in Germany
- 28 June 2025 Obligations apply to new offerings
What is the BFSG?
The Barrierefreiheitsstärkungsgesetz (BGBl. I 2021, No. 59) transposes EU Directive 2019/882 into German law. It requires economic operators to make digital products and services accessible.
Which products are affected?
Computers and operating systems, smartphones, ATMs, self-service terminals, e-book readers, internet-connected TVs and all associated digital services:
- Online banking
- E-commerce
- Messaging
- Streaming
- E-books
- Electronic tickets
What requirements apply?
The requirements are defined in §3 BFSG and Annex I. Technically they follow EN 301 549, which is based on WCAG 2.1 AA. WCAG 2.2 AA is recommended and represents the current state of the art.
What must be documented?
Economic operators must publish an accessibility statement documenting their conformance status, naming known barriers and providing a user feedback mechanism. The statement must remain permanently accessible.
What fines can be imposed?
For infringements, market surveillance authorities can impose fines of up to €100,000. For repeated or serious violations, the sale of the product must be prohibited. The responsible authority is the market surveillance body of the relevant German state.
Checklist for your team
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General information, not legal advice. For your specific case, please consult a lawyer.
Step 2 of the checklist: know where you stand.
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