EAA, BFSG, BGG and BITV: Accessibility for TYPO3 Websites

Since 28 June 2025, the BFSG requires providers of certain consumer products and services, such as online shops, to be accessible. It implements the European Accessibility Act (EAA) in German law. The technical reference for websites is the standard EN 301 549, so far in version V3.2.1, which points to WCAG 2.1 Level AA.

In short:

• Affected: private providers of consumer products and services, for example in e-commerce. Pure business-to-business offers are generally not covered.
• Exemption: micro-enterprises regarding services (fewer than 10 employees and annual turnover or balance sheet total of no more than 2 million euros).
• Fines: up to 100,000 euros, for example for a non-compliant service; up to 10,000 euros for certain reporting and information duties (Section 37 BFSG).
• Federal public bodies: the BGG and BITV 2.0 apply to them.
• Standard in transition: EN 301 549 V4.1.1 was published on 2 September 2026. According to Deque, it is not yet cited in the Official Journal of the EU; citation is targeted around 30 November 2026 (a target, not confirmed).

Accessibility means making websites usable for as many people as possible, regardless of ability. How TYPO3 can help is covered in our article on accessibility with TYPO3.

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

What is the BGG?

The BGG (Behindertengleichstellungsgesetz, Disability Equality Act) is the German federal law on equality for people with disabilities (glossary: BGG). It is aimed mainly at federal public bodies and includes accessibility rules, also for digital services. It is made concrete by BITV 2.0.

What is the BITV?

BITV 2.0 (glossary: BITV) is the Barrierefreie-Informationstechnik-Verordnung (Barrier-free Information Technology Ordinance). It applies to federal public bodies and refers to the European standard EN 301 549, currently in version V3.2.1 according to the Bundesfachstelle Barrierefreiheit (German), which in turn refers to WCAG 2.1 (Level AA). It implements Directive (EU) 2016/2102.

What does BITV 2.0 cover?

BITV 2.0 concerns websites, mobile applications and internal IT systems of federal bodies. Among other things it regulates the accessibility statement, a feedback procedure and information in Easy Language and German Sign Language. Hardware, web hosting or internet providers as such are not covered by the BITV.

That depends on the legal basis:

• BFSG / EAA: Private providers of certain products and services for consumers, such as e-commerce, consumer banking services, passenger transport, telecommunications and e-books.
• BITV 2.0 / BGG: Federal public bodies. For states and municipalities, state law applies, which is based on Directive (EU) 2016/2102.

Who has to follow the EAA requirements?

Economic operators that offer the named products or services to consumers in the EU are affected. Companies outside the EU can also be affected if they offer covered services to consumers in the EU. Pure business-to-business offers are generally not covered.

Exemptions apply, among others, to:

• Micro-enterprises regarding services (Section 3(3) BFSG): fewer than 10 employees and annual turnover or balance sheet total of no more than 2 million euros.
• Cases where compliance would mean a fundamental alteration or a disproportionate burden. This must be assessed, documented and notified to the market surveillance authority (Sections 16 and 17 BFSG).

Who has to follow the BFSG requirements?

The BFSG is addressed to the covered economic operators, mainly private companies. Public bodies are mainly covered by the BGG and BITV 2.0 or by state law. In case of violations, market surveillance measures and fines of up to 100,000 euros are possible (Section 37 BFSG).

Note: This text is for general information only and is not legal advice. For legal questions, consult a qualified professional.

Anyone who does not meet accessibility requirements may face consequences depending on the legal basis. Which ones apply in a particular case should be checked legally.

• Authority measures and fines
  The joint market surveillance authority of the German states for the accessibility of products and services (MLBF) (German), based in Magdeburg, is responsible; according to state information it started its work on 26 September 2025. Under Section 37 BFSG, fines of up to 100,000 euros are possible, for example for a non-compliant service; up to 10,000 euros for certain reporting and information duties.
• Complaints and conciliation
  Consumers and recognised associations can ask the market surveillance authority to act (Section 32 BFSG). A conciliation procedure before the conciliation body under Section 16 BGG is also possible (Section 34 BFSG).
• Information duty for service providers
  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".
• Legal disputes
  Recognised associations can take legal action against violations under certain conditions. Legal and procedural costs can follow.
• Reputation
  People with disabilities are a relevant customer group. Offers that cannot be used may cost trust and revenue.
• Public contracts
  Public tenders may ask for proof of accessibility; accessibility with TYPO3 can be an advantage here.

Whether and how an authority first asks for remedial action before taking measures depends on the individual case.

The requirements of the BFSG have been applicable since 28 June 2025. Transitional periods exist for certain existing cases under Section 38 BFSG: service contracts concluded before that date may continue unchanged for no longer than 27 June 2030; likewise, service providers may keep using products they lawfully used before 28 June 2025 until that date. Self-service terminals that were already lawfully in use before 28 June 2025 may continue to be used until the end of their economic useful life, but for no longer than 15 years after being put into service. Whether this applies to your offering should be checked legally in each case.

What to do: getting started in three steps

1. Check whether your offering falls under the BFSG and whether an exemption may apply.
2. Carry out an accessibility audit and prioritise the improvements, for example keyboard operation and alternative texts.
3. Use TYPO3 tools and test with real users.

A structured approach can reduce effort and helps you keep the requirements in view. For practical next steps, see our article on accessibility with TYPO3.

Accessibility supports equal access to digital offerings, including for people with disabilities. It can also improve the user experience for everyone and increase engagement. For search engines some measures, such as a clean heading structure and alternative texts, are helpful as well; a direct ranking effect is not guaranteed. Anyone who ignores the requirements risks legal disputes and reputational damage. Accessibility also builds trust and reaches more people.

Sometimes, full accessibility can seem impossible, given the considerations one has to take into account, such as:

• Keyboard navigation
• Alternative text for images
• Video captions
• Use of clear and simple language

But don't let these factors stop you! 
There are many tools and resources out there to provide true accessibility for your site.

TYPO3 CMS is designed with flexibility and inclusion in mind. Here is how TYPO3 supports you with accessibility:

• Foundations: Clean, semantic HTML structures, customisable templates and ARIA attributes can be implemented with TYPO3.
• Extensions: Extensions such as T3AI and TYPO3 accessibility tools can support checks, for example contrast checks or hints on missing alternative texts.
• Editing: The backend helps editors maintain alternative texts and structure content logically.
• Standards: Whether a specific website meets WCAG and BITV 2.0 depends on templates, extensions and content and has to be tested.
• Scalability: The modular system allows step-by-step improvements.
• Community: The TYPO3 community offers resources, updates and expert exchange.

With TYPO3, accessibility can be organised well as an ongoing process. This is no guarantee of legal compliance.

Accessibility is not a one-time task but an ongoing process that should be reviewed regularly using user feedback and testing. Here is how:

• Make accessibility a habit: Keep improving your site regularly and respond to new user needs.
• Use TYPO3's tools: Ongoing checks help catch and fix issues early.
• Stay updated: Update TYPO3 and extensions regularly, for example with the help of TYPO3 backend notifications and TYPO3 Upgrade services.

This keeps your website better prepared for new requirements.

Note: Tools and extensions can improve website accessibility but do not guarantee full legal compliance. Audits and legal advice may be required in addition.

Preparing for the BFSG is not only a question of fines; it is also a chance to build a web that is usable for as many people as possible. With a structured approach and the options TYPO3 offers, you can create the technical foundation for this. Read more in our article on accessibility with TYPO3 and in the glossary entry on WCAG.

Accessibility is more than a law: it is a chance to make the web better for everyone.

Would you like to make your website more accessible? Get in touch. At NITSAN, your TYPO3 Agency, we support the technical implementation. We do not provide legal assessments.

Status: 27 October 2026. General information, not legal advice. Sources: Directive (EU) 2019/882, Implementing Decision (EU) 2021/1339, Legalithm, Deque, BFSG (German), BITV 2.0 (German), MLBF (German), Bundesfachstelle Barrierefreiheit: BFSG FAQ (German), WebAIM Million 2026.