BFSG DEADLINE PASSED · JUNE 28, 2025

EAA compliance in Germany — BFSG enforcement is live

The Barrierefreiheitsstärkungsgesetz (BFSG) has been enforceable since June 28, 2025. Scrutia audits your site against WCAG 2.1 AA — the technical baseline of the BFSG — and provides fix code in minutes.

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BFSG: Germany's transposition of the EAA

The Barrierefreiheitsstärkungsgesetz (BFSG) is the federal law that implements the European Accessibility Act in Germany. Adopted by the Bundestag in 2021 and complemented by the BFSGV regulation in 2022, the BFSG defines technical requirements, covered products and services, exemptions, and enforcement.

The BFSG references the harmonized European standard EN 301 549, which incorporates WCAG 2.1 Level AA for web content. Meeting WCAG 2.1 AA is therefore the path to BFSG compliance for your website or web application.

Covered sectors

The BFSG explicitly covers several consumer-facing sectors. German market surveillance authorities have identified these as enforcement priorities:

  • E-commerce — product pages, cart, checkout, account management, order tracking
  • Consumer banking — online banking, card management, transfers, loan applications
  • Transport — DB Navigator, Flixbus, airline and ferry booking, ride-hailing
  • E-books and publishing — readers, stores, libraries (explicitly in the EAA)
  • Telecommunications — mobile operators, internet providers, messaging
  • Audiovisual media — streaming platforms, catch-up TV, on-demand services

Obligations for companies

  • Meet WCAG 2.1 AA on all consumer-facing digital services
  • Publish an Erklärung zur Barrierefreiheit (accessibility statement)
  • Maintain technical documentation of conformity
  • Provide a feedback mechanism for users to report barriers
  • Cooperate with market surveillance authorities

How Scrutia accelerates BFSG compliance

Scrutia automates the technical assessment phase of BFSG compliance. In 5 minutes you get a WCAG 2.1 AA audit that covers keyboard navigation, ARIA components, contrast, forms, and responsive behaviour — the areas most frequently cited in accessibility complaints.

The full report (149 €) includes HTML/CSS/JS fix code for every issue, enabling your developers to address barriers directly. This is designed to support your technical documentation file and your Erklärung zur Barrierefreiheit.

See also our country-specific Germany accessibility audit page and the wider EAA audit guide.

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BFSG compliance FAQ

What is the BFSG and how does it relate to the EAA?
The Barrierefreiheitsstärkungsgesetz (BFSG) is the German federal law transposing the European Accessibility Act (Directive 2019/882) into national law. Adopted in 2021 and complemented by the BFSGV in 2022, the BFSG has been enforceable since June 28, 2025. It defines the technical requirements (WCAG 2.1 AA via EN 301 549), the scope of covered products and services, and the enforcement framework.
Which German companies are covered by the BFSG?
The BFSG covers private companies providing digital products or consumer services in Germany with more than 10 employees OR more than €2 million in annual turnover. This includes e-commerce sites, online banking, self-service terminals, e-books, ticket machines, and consumer software. Micro-enterprises below both thresholds are exempt. B2B-only services are partially exempt but most consumer-facing services fall within scope.
Which sectors are priority targets for BFSG enforcement?
German market surveillance authorities have indicated that enforcement will focus first on high-impact sectors: e-commerce (especially large marketplaces), banking and payment services, transport booking platforms, and consumer electronics. E-books and digital reading services are also a priority because of the explicit mention in the EAA. SMEs in these sectors should not assume a grace period — the June 28, 2025 deadline has already passed.
What documentation must German companies maintain?
Under the BFSG, covered companies must maintain technical documentation demonstrating conformity with the accessibility requirements, publish an accessibility statement (Erklärung zur Barrierefreiheit) on their website, provide a feedback mechanism for users, and cooperate with market surveillance authorities in case of an audit. A Scrutia audit report serves as evidence of due diligence and can support the technical documentation required by the BFSG.
What happens if a non-EU company fails to comply with the BFSG?
Non-EU companies providing digital services to German consumers are fully subject to the BFSG. German authorities can order the withdrawal of non-compliant services from the German market, impose administrative fines up to €100,000, and cooperate with other EU market surveillance authorities. For non-EU companies without an EU establishment, the authorized representative is liable for compliance.

BFSG enforcement is live. Don't wait.

Check your compliance in 5 minutes. Free audit, full report with code fixes for 149 €.

Check BFSG compliance

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