The Barrierefreiheitsstärkungsgesetz (BFSG, Accessibility Strengthening Act) has regulated since 28 June 2025 which products and services for consumers must be accessible. It implements Directive (EU) 2019/882 (European Accessibility Act) in German law. This article explains the key points and what they can mean for businesses. It is general information and not legal advice.
What is the Barrierefreiheitsstärkungsgesetz (BFSG)?
The BFSG was adopted in 2021 and applies since 28 June 2025 to products placed on the market after that date and to services provided after that date. It aims to ensure that certain consumer products and services can also be used by people with disabilities. Its basis is Directive (EU) 2019/882.
Why accessibility matters in everyday life
Whether shopping online, banking online or buying a ticket, people with disabilities depend on usable digital services. Building a website with accessible TYPO3 creates a technical foundation for this.
Background and purpose
The BFSG is meant to create more uniform requirements in the EU and strengthen the internal market for accessible products and services. For public bodies, the Disability Equality Act and BITV 2.0 continue to apply.
In short: since June 2025 the BFSG obliges covered businesses to offer certain products and services in an accessible way.
The key rules of the BFSG at a glance
- Which products and services are covered
Covered are certain consumer products, such as computers, smartphones, e-readers, ATMs and ticket and check-in machines. Services include e-commerce, consumer banking services, passenger transport, telecommunications, e-books and access to audiovisual media services. Websites and apps are affected insofar as they provide such services. - Technical requirements
The requirements are specified by the BFSG and its ordinance (BFSGV). For digital offerings the European standard EN 301 549 is an important reference; it refers to WCAG 2.1 Level AA. - Exemptions
Micro-enterprises (fewer than 10 employees and annual turnover or balance sheet total of no more than 2 million euros) are exempt as far as services are concerned. A fundamental alteration of the product or a disproportionate burden may also apply; this must be assessed and documented. - Information duties
Businesses must inform consumers about the accessibility of their services, for example in their general terms and conditions. - Supervision and consequences
Market surveillance lies with the German states. In case of violations, measures by the authorities and fines of up to 100,000 euros are possible. Recognised associations can take legal action under certain conditions. - Transitional periods
Transitional periods apply in certain cases. For example, service contracts concluded before 28 June 2025 may under some conditions continue until 27 June 2030. Self-service terminals may remain in use until the end of their economic lifetime, at most 20 years.
What the BFSG can mean for businesses
- Check whether you are affected
What matters is whether you offer covered products or services to consumers. Pure business-to-business offers are generally not covered. Have this checked legally in your individual case. - Digital accessibility
Affected websites and apps should meet the requirements. Tools such as the TYPO3 Accessibility Checker and manual tests help. Automated tests only cover part of the problems. - Documentation
Businesses should record how they implement the requirements and which exemptions they rely on. - Cost and effort
Adapting websites, apps and processes can take effort. Plan budget and time for it. - Customer expectations
Associations and consumers increasingly look for accessible offerings.
Which areas the BFSG covers
- E-commerce
Online shops and other e-commerce services for consumers. - Consumer banking services
Online banking, apps and ATMs. - Passenger transport
Websites, apps, ticket machines and information for certain transport services. - Telecommunications and media access
Certain telecommunications services and access to audiovisual media services. - E-books
E-books and software and devices intended for them. - Products
For example computers, smartphones, e-readers and self-service terminals.
The BFSG does not, among other things, regulate structural requirements for buildings or employer duties for offices. Other rules apply to those, such as the building codes of the states. WCAG 3.0 is also a W3C draft and not a legal basis; EN 301 549, which refers to WCAG 2.1, is currently the relevant reference.
Steps businesses can take now
- Clarify whether you are affected
Check whether your products or services fall under the BFSG and whether an exemption may apply. - Audit your digital offerings
Review your website, shop and apps with automated and manual tests. Where possible, involve users with disabilities. - Fix and document issues
Prioritise barriers in navigation, forms, contrast and alternative texts, and record the results. - Provide information
Inform consumers about the accessibility of your services, for example in your terms and conditions. - Train your team
Train editors, designers and developers so accessibility is considered in daily work. - Involve specialists
For binding statements consult a qualified lawyer; we are happy to support the technical implementation.
Get Started with TYPO3 Accessibility Solutions
At NITSAN we support you with the technical implementation of accessibility. Our team of TYPO3 experts helps you review your digital offerings and remove barriers.
Get in touch if you would like to know how we can make your website accessible to as many users as possible.
Conclusion
Since 28 June 2025 the BFSG has made accessibility requirements binding for certain products and services for consumers. Whether and to what extent it affects you depends on your offering. Clarify this in your individual case and approach the technical implementation in a structured way.
At NITSAN, your TYPO3 Agency, we support you with the technical implementation of your website's accessibility. We do not provide legal assessments; for those we recommend qualified lawyers.
In short: the BFSG: overview and possible consequences for businesses.
Status: October 2026. General information, not legal advice. Sources: BFSG, Directive (EU) 2019/882.
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.
Frequently asked questions about the BFSG
Does the BFSG apply to my website?
That depends on whether you offer covered products or services to consumers, for example an online shop. Pure business-to-business offerings are generally not covered. Have this checked legally in your individual case.
Who is exempt from the BFSG?
Micro-enterprises providing services (fewer than 10 employees and no more than €2 million annual turnover or balance sheet total) are exempt. A fundamental alteration of the product or a disproportionate burden can also be invoked if it is assessed and documented.
Which standard applies to websites?
The requirements are specified by the BFSG and the BFSG ordinance. The European standard EN 301 549 is an important reference and refers to WCAG 2.1 Level AA for web content.
What can a violation lead to?
Market surveillance lies with the federal states. Official measures and fines of up to €100,000 are possible. Recognised associations can take legal action under certain conditions.
Status: October 2026. General information, not legal advice.
Contact for SMEs, government organizations and BITV 2.0
Stefan Reinhardt
Service Partner - Germany

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