Barrierefreiheitsstärkungsgesetz (BFSG)

Barrierefreiheitsstärkungsgesetz (BFSG): Explained

The Barrierefreiheitsstärkungsgesetz (BFSG), or Accessibility Strengthening Act, is the German law that transposes EU Directive 2019/882 (European Accessibility Act, EAA). It requires economic operators offering certain consumer products and services to make them accessible, and has applied since 28 June 2025.

In short: The BFSG concerns private providers of consumer products and services, such as online shops; micro-enterprises providing services are exempt. Pure business-to-business offers are generally not covered. The law is monitored by the market surveillance authority of the German states (MLBF).

Definition

The BFSG was passed in 2021. It aims to remove barriers that make it difficult for people with disabilities to use certain consumer products and services. The legal text is available at gesetze-im-internet.de (German), the directive at EUR-Lex.

Who is affected?

Economic operators (manufacturers, importers, distributors and service providers) offering covered consumer products or services are in scope, including:

E-commerce – online shops and consumer contracts concluded electronically.
Consumer banking services – such as online banking and ATMs.
Passenger transport – elements of air, bus, rail and waterborne transport; for urban, suburban and regional transport only self-service terminals (Section 1(3) BFSG).
Telecommunications services and access to audiovisual media services.
E-books and certain hardware such as self-service terminals, smartphones and computers.

For federal public bodies, the BGG and BITV 2.0 apply instead.

Requirements and standards

The requirements are specified in the BFSG ordinance (BFSGV). The technical reference is the European standard EN 301 549. So far this has been version V3.2.1, which for web content builds on WCAG 2.1 level AA (see W3C: WCAG 2.1). Version V3.2.1 was published in the Official Journal by Commission Implementing Decision (EU) 2021/1339 of 11 August 2021 (OJ L 289, 12.8.2021), but for Directive (EU) 2016/2102 (websites and mobile apps of public sector bodies). According to Legalithm (14 August 2026), no harmonised standard is cited in the Official Journal under Directive (EU) 2019/882, so no presumption of conformity under Article 15 of that Directive applies yet. Version V4.1.1, referring to WCAG 2.2, was published on 2 September 2026. According to Deque, V4.1.1 is not yet cited in the Official Journal; Deque names about 30 November 2026 as the target, which is not a confirmed date. Following a standard does not replace legal assessment.

Exemptions and transitional periods

Micro-enterprises providing services (fewer than 10 employees and no more than €2 million annual turnover or balance sheet total) are exempt (Section 3(3) BFSG). The exemption does not cover products.
A fundamental alteration or a disproportionate burden can stand in the way of requirements. The provider must assess and document this and notify the market surveillance authority (Sections 16 and 17 BFSG).
Under Section 38 BFSG, service contracts concluded before 28 June 2025 may continue unchanged for no longer than 27 June 2030. Self-service terminals lawfully used before that date may continue for no longer than 15 years after being put into service.

What can happen in case of violations?

Market surveillance is the responsibility of the joint market surveillance authority of the German states (MLBF) (German), based in Magdeburg; according to state information it has been working since 26 September 2025. Violations may lead to official measures and fines: under Section 37 BFSG up to €100,000, for example for a non-compliant service, and up to €10,000 for certain reporting and information duties. Consumers and recognised associations can ask the authority to act (Section 32 BFSG) or apply for conciliation (Section 34 BFSG). In addition, associations may pursue violations legally under certain conditions.

Relevance for your TYPO3 website

If you run an online shop or customer portal with TYPO3, your offering may fall under the BFSG. Whether this applies should be assessed legally on a case-by-case basis. Our TYPO3 accessibility services support the technical implementation; for background, see the article on the BFSG for businesses. The TYPO3 Accessibility Checker can additionally test your website automatically; it does not replace manual testing.

Sources

Status: 27 October 2026. General information, not legal advice.

Frequently asked questions about the BFSG

What is the Barrierefreiheitsstärkungsgesetz?

The BFSG is a German law that implements EU Directive 2019/882 (European Accessibility Act). It makes accessibility binding for certain consumer products and services.

Since when does the BFSG apply?

It was passed in 2021 and has applied since 28 June 2025. Under Section 38 BFSG, transitional periods for certain existing contracts run for no longer than 27 June 2030.

Who is exempt?

Micro-enterprises providing services (fewer than 10 employees and no more than €2 million annual turnover or balance sheet total) are exempt. The exemption does not cover products. Pure business-to-business offerings are generally not covered.

Which technical benchmark applies?

So far the standard EN 301 549 V3.2.1, which for web content builds on WCAG 2.1 level AA, has served as the reference. It was published in the Official Journal by Commission Implementing Decision (EU) 2021/1339 of 11 August 2021, for Directive (EU) 2016/2102. According to Legalithm (14 August 2026), no harmonised standard is cited in the Official Journal under Directive (EU) 2019/882, so no presumption of conformity under Article 15 of that Directive applies yet. Version V4.1.1 (WCAG 2.2) was published on 2 September 2026. According to Deque, V4.1.1 is not yet cited in the Official Journal; Deque names about 30 November 2026 as the target, which is not a confirmed date. A standard does not replace legal assessment.

Who monitors compliance and where can you complain?

Market surveillance lies with the joint market surveillance authority of the German states (MLBF) in Magdeburg. Consumers and recognised associations can ask the authority to act (Section 32 BFSG) or apply for conciliation (Section 34 BFSG).

How high are the fines?

Under Section 37 BFSG, fines of up to €100,000 are possible, for example for a non-compliant service, and up to €10,000 for certain reporting and information duties.

What information duties do service providers have?

Service providers must make certain information under Annex 3 No. 1 BFSG publicly available in an accessible form (Section 14(1) No. 2 BFSG). Many providers publish this information as an “accessibility statement”.

Status: 27 October 2026. General information, not legal advice.

A structured approach to TYPO3 accessibility

The guide walks through law, testing, templates, editorial work, forms and maintenance in 8 chapters. With a checklist you can tick off.