The German Bundestag is taking a big step towards a world in which everyone has a place. With the Accessibility Reinforcement Act, or BFSG for short, Germany wants to make everyday life easier for people with disabilities. This law opens doors - literally and figuratively.

Find out what requirements are placed on your company website and what steps you need to take.

What is the Accessibility Reinforcement Act?

The BFG is the German response to Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019. The law ensures that products and services are made more accessible in order to enable people with disabilities in particular to participate in society in a self-determined manner.

Are only public bodies affected, or does this also apply to the private sector?

In principle, the law affects all economic operators who offer products or services that affect the public. This includes, for example

  • Electronic commerce
  • Banking services
  • Mobility services
  • Social security and health services

Companies are now faced with the challenge of adapting their products and services accordingly in order to fulfil the requirements of the Barrier-Free Strengthening Act. The aim is to remove barriers and create an inclusive society in which all people can participate without restriction. The implementation of these requirements requires not only technical but also organisational measures.

It is important that companies begin to familiarise themselves with the new regulations at an early stage and take appropriate measures to ensure the accessibility of their offerings. By creating an accessible environment, not only people with disabilities, but ultimately society as a whole will benefit from greater diversity and inclusion.

What obligations arise from the BFG?

Companies must gradually fulfil the requirements of the Accessibility Improvement Act. The core obligations include

1. design and functionality: products and services should be designed in such a way that they can be used independently by people with disabilities as far as possible. This includes websites, mobile applications and electronic devices.

2. information and customer service: Information on products and services should be provided in accessible formats and customer service barriers should be removed.

3. staff training: Companies should ensure that their employees are trained in dealing with accessible products and services.

4. feedback mechanisms: Implement procedures through which users can provide feedback on accessibility.

Penalties and sanctions

Non-compliance can lead to sanctions, including fines. A proactive approach is therefore necessary.

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Implementation measures for companies in the private sector

Companies can take the following steps to ensure compliance:

  • Conduct accessibility audits
  • Setting up accessibility consulting services
  • Developing accessible websites and apps according to WCAG guidelines
  • Train employees in accessible services and the use of assistive technologies

The BITV self-test for your website can be carried out here free of charge after registration:​​​​​​​

Accessibility Meaning in the context of BFSG

Interestingly, the legal text of the BFSG does not contain any precise definitions for the application of accessibility; it merely refers to the European standard EN 301 549. This in turn refers to the AA standards of the Web Content Accessibility Guidelines (WCAG) 2.1. These guidelines generally provide a good definition of accessibility and show what accessibility means for websites.

To list all standards in detail at this point would certainly go beyond the scope of the whole. In general, however, the accessibility requirements can be divided into four principles:

This includes text alternatives to images and simple layouts in which information is clearly structured and content can be easily received both visually and audibly.

  • It should be possible to navigate through the site using only the keyboard.
  • All users should have enough time to perceive content.
  • Input fields such as forms should be clearly labelled in the backend so that they can also be used without a keyboard.
  • Content should be designed in such a way that the likelihood of an epileptic seizure is minimised.
  • Content should be easy to read and understand. This may concern the font size or the contrast between font and background, for example.
  • Web conventions should be adhered to, for example links should be underlined and, if possible, displayed in one colour, e.g. blue.
  • The website should provide feedback in the event of errors and help to correct them, including clear error messages, for example.

The website should support assistive devices such as screen readers and thus be compatible in the future.

Under each of these four principles, there are some requirements and success criteria that help to reduce the digital barriers and reach people with disabilities.

The correct criteria are set out in the Web Content Accessibility Guidelines (WCAG) and form the international standard for accessible web design. In addition to the 60 WCAG 2.1 test steps, according to the European standard 38 further requirements must be fulfilled, which the EN 301 549 formulates for web content. It is a kind of guideline catalog that describes which points must be fulfilled for an accessible website.

If you are legally required to design an accessible website, you can use the list of test criteria according to BIK to get a realistic overview of all relevant features and criteria.

BITV compliant website according to BIK

In order to comprehensively and reliably test a website for its accessibility, the so-called BIK-BITV test can be carried out by an official testing agency in 98 test steps. It compares the current conditions of a website with the requirements of the Barrier-Free Information Technology Ordinance 2.0.

If all applicable test steps are fulfilled and the tested pages of your offer are rated "compliant", you will receive the "BIK BITV compliant" test mark and can include it on the website.

Who is exempt from the BFSG?

There are certain exceptions to the BSFG. One particularly important exception concerns companies with fewer than 10 employees and a maximum total annual turnover of 2 million euros. These companies are considered small businesses and are therefore not affected by the Accessibility Improvement Act.

Our proposal is to make websites and services in general as accessible and barrier-free as possible. This makes sense not only from an economic point of view. An accessible website improves the user experience and can therefore increase the conversion rate.

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Typische Probleme auf Websites

Es existieren verschiedene gängige Schwierigkeiten, die Menschen mit Behinderungen beim Zugang zu vielen Websites haben können. Konkrete Einschränkungen können es diesen Personen gegebenenfalls erschweren, die Website entsprechend ihrer ursprünglichen Funktion zu nutzen.

Zu diesen typischen Schwierigkeiten gehören etwa:

  • Slight differences between text and background, whether through similar brightness or colour tones, which are difficult to distinguish for people with red/green blindness
  • Text that is too small and cannot be enlarged.
  • Missing subtitles in videos.
  • Navigation elements that cannot be operated with the keyboard or can only be operated to a limited extent, for example form fields that cannot be accessed in the expected order.
  • PDFs with unrecognisable text that cannot be read aloud.
  • Complex and bureaucratic language.
  • Images without alternative text for screen readers.

Measures to reduce barriers on the website

There are a number of measures that can and should be implemented now, without the obligations of the BFSG, in order to resolve the difficulties described (which are only examples and by no means exhaustive):

  • Schriftarten und Schriftgröße sollten so gewählt sein, dass die Texte immer gut lesbar sind und in ausreichendem Kontrast zum Hintergrund stehen.
  • Schrift sollte sich stets vergrößern lassen – und auch bei vergrößerter Darstellung sollte die Website noch voll und ganz benutzbar bleiben. Interaktive Elemente sollten auf jeden Fall groß genug und auch klar voneinander abgegrenzt sein.
  • Videos sollten stets mit Untertiteln auch in ihrer Ursprungssprache versehen werden. 
  • Links, Formulare, Buttons und Eingabefelder – letztlich alle interaktiven Elemente einer Website – sollten im Quellcode so ausgezeichnet sein, dass sie zum einen auch durch Screenreader korrekt erkannt und ausgegeben und zum anderen über die Tastatur problemlos und auf sinnvolle Art und Weise angesteuert werden können.
  • PDFs und andere Dokumente sollten barrierefrei gestaltet und umgesetzt werden.
  • Texte sollten stets verständlich und nachvollziehbar, klar strukturiert, sprachlich korrekt und sauber geschrieben sein. Ideal wäre es zudem, Inhalte in Leichter Sprache anzubieten, die auch von Menschen mit schlechten Deutschkenntnissen gut verstanden werden können.
  • Bilder sollten stets mit Alternativtext versehen werden.

Another non-trivial but important step towards accessibility? It should be possible to make contact via different channels, for example by email, by telephone and ideally also via personal visits. Always bear in mind that limiting yourself to a specific communication channel can exclude some people.

In addition, the WCAG and BITV standards provide for a whole range of other, no less important measures and steps to make your website truly accessible.


In order for companies to successfully implement the requirements of the Accessibility Reinforcement Act, it is crucial that they take a close look at the needs and challenges of people with disabilities. Creating an accessible environment requires not only technical adaptations, but also conscious sensitisation in dealing with diversity and inclusion.

Companies should therefore regularly train their employees in accessibility and assistive technology to ensure that all customers are served equally. Only through a comprehensive understanding and consistent implementation of the requirements of the Accessibility Improvement Act can companies bring about positive changes in the long term and contribute to building an inclusive society.

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Important terms and information about the Accessibility Improvement Act (BFSG)

The European Accessibility Act (EAA) is the directive that obliges member states of the European Union to enact laws and regulations that ensure accessibility throughout Europe.

The EAA specifies a minimum level of accessibility for products and services. It was adopted in mid-2019 and had to be transposed into national law by 28 June 2022. The implementation of the European Accessibility Act (EAA) is another important challenge for companies. This legislation obliges the member states of the European Union to enact laws and regulations to ensure accessibility throughout Europe. The EAA defines a minimum level of accessibility for products and services and was adopted in mid-2019. This act had to be transposed into national law by 28 June 2022. These requirements require companies to further adapt their products and services in order to fulfil the legal requirements and promote an inclusive society.

The products and services covered by the EAA include

  • ATMs and banking services
  • computers
  • Telephones and TV sets
  • Telecommunications services
  • transport
  • online trade.

What to do in detail is regulated in the European standard EN 301 549.

The EN 301 549 standard ( describes the procedure for ensuring that products and services are accessible under the European Accessibility Act.

For websites and applications, EN 301 549 directly references the international standard "Web Content Accessibility Guidelines (WCAG) 2.1" at level AA. The EN 301 549 standard provides clear instructions on how products and services can be designed to be accessible in accordance with the European Accessibility Act. In the area of websites and applications, EN 301 549 refers directly to the international standard "Web Content Accessibility Guidelines (WCAG) 2.1" at level AA.

The deadline for the law is 28 June 2025, and products placed on the market after this date and services provided after this date must be accessible.

Examples of products that are subject to the BFSG include computers, tablets and mobile phones, televisions with internet access, e-book readers, vending machines (including cash and ticket machines) and routers.

In addition to passenger transport, services also include telephone and messenger services as well as e-commerce services. Many websites also fall into this category, especially web shops, of course, but also other services such as contact forms and appointment booking masks.

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How we can support your company around the topic BITV and accessible websites:

  • We offer comprehensive advice on the requirements and guidelines of the BITV and perform an accessibility analysis of your existing website to identify potential weaknesses.
  • We are happy to support you in redesigning or adapting your website to meet the requirements of BITV. This includes the design of a user-friendly and accessible user interface as well as the implementation of accessible techniques and functions. In addition, we can support you in creating accessible content.
  • In training courses and workshops, we can raise awareness of accessibility and impart knowledge about the implementation of accessible websites according to BITV. This can help ensure that your organization complies with accessible standards in the long term.
  • If desired, we can also help you obtain an official accessibility certificate for your website. This can officially validate your efforts to create an accessible online presence.

Do you have any other questions?

Oliver Parrizas will be happy to answer any questions you may have on the subject. +49-800-911-91-91

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