The German Accessibility Improvement Act: Barrierefreiheitsstärkungsgesetz (BFSG)
On June 28, 2025, the German Accessibility Act (Barrierefreiheitsstärkungsgesetz or BFSG) comes into effect throughout the EU, requiring companies to implement the accessibility requirements of the European Accessibility Act. This will ensure that products and services with a digital interface are more accessible. For businesses, this means making their digital offerings and user interfaces accessible. This will allow everyone to have better access to their products and services.
In light of the growing importance of accessibility, the Accessibility Improvement Act was passed on July 22, 2021. The law establishes a standardized implementation of accessibility requirements for a selection of products and services.
Below you will find the most important key data of the law: From when does the law apply to whom and what must be implemented?
What is Accessibility?
Many people think that accessibility means having ramps in places with stairs or having wide doors. But structural changes are not enough to make everyday life accessible. Accessibility is about designing buildings, public places, workplaces, homes, transport, everyday objects, services and leisure activities in such a way that they can be accessed and used by everyone without assistance. Overall, accessibility benefits everyone.
Before the Accessibility Improvement Act (BFSG) was introduced, each EU member state had different accessibility requirements, some of which even contradicted each other. The law is intended to create clear and uniform standards in order to increase the availability of affordable accessible products and services.
The BFSG is a law implementing the European Accessibility Act (EAA), EU Directive 2019/882. The EAA was adopted on 17 April 2019 and includes the accessibility requirements to be implemented under the BFSG. The requirements apply to a selection of products and services that are placed on the market after June 28, 2025.
Which Companies are Subject to the Accessibility Improvement Act?
The Accessibility Improvement Act applies to all companies whose products or services fall within the listed scope (see next section). The exception to this are micro-enterprises that provide one of the listed services. Companies with fewer than ten employees and an annual turnover or annual balance sheet total of no more than 2 million euros are considered micro-enterprises.
Companies can also invoke two exceptions under certain circumstances in order to be excluded from the scope of the Accessibility Improvement Act:
1. Compliance with the requirements would lead to a fundamental change in the product or service: the performance of the product is affected to such an extent that it can no longer achieve its intended purpose | 2. Compliance with the requirements would place a disproportionate burden on the economic operator: additional excessive organizational or financial burden that makes it impossible to implement one or more requirements |
All companies that are not affected can of course implement the requirements voluntarily. The fact that society in general is getting older and therefore the need for accessibility is increasing can be relevant when making this decision. Moreover, accessible offers can open up a larger sales market and competitive advantages for a company. Finally, it is likely that the scope of the BFSG will be expanded in the coming years and that introducing it will position the company for the future.
Scope of Application: Which Products and Services are Affected?
The scope of the BFSG has a clear focus on digital accessibility, as it can be summarised as products and services that can be operated digitally. Specifically, the following products and services must meet the requirements of the Accessibility Improvement Act:
How are the Requirements of the BFSG Being Implemented?
Implementation of the requirements of the BFSG varies greatly between products and services.
Accessible Products
The requirements for accessible products differ again depending on the economic operator's position in the supply chain:
Manufacturers
Duties of the manufacturer:
May only place products on the market if
- the products are accessible
- conformity assessment procedures are carried out and technical documentation is prepared
- EU Declaration of Conformity is issued and CE marking is applied
Labeling and information requirements:
- Specify product identification and manufacturer contact data
- Provide accessible instructions for use and safety information
Obligations towards the market surveillance authority:
- provide all information on conformity and hand over documents upon justified request
- In the event of non-compliance, take corrective action and inform the market surveillance authority, recall or withdrawal if necessary
Ongoing requirements:
- Continue to ensure accessibility during series production and modifications
- Authorized representative can be appointed for the duties
Importers
Duties of the importer:
May only place products on the market if
- products are produced accessibly, even when produced in third countries
- it is ensured that the manufacturer fulfills its obligations
- accessibility is guaranteed during storage and transportation
Measures in the event of non-compliance:
- Restore conformity before sale
- Inform manufacturers and market surveillance authorities
- If necessary, withdrawal or recall of the product
Obligations towards the market surveillance authority:
- Keep the EU Declaration of Conformity for five years
- Submit technical documents on request
- Cooperation and information obligations - like the manufacturer
Retailers
Duties of the retailers:
May only place products on the market if
- the CE marking is present
- instructions for use and safety information are available in German
- manufacturer's marking is attached for identification
- the importer provides their identification data
- storage and transportation must not impair accessibility functions
Measures in the event of non-compliance:
- Only make the product available once conformity has been established
- Ensure that the manufacturer or importer takes measures to restore conformity
- Otherwise, take back or recall the product
- Retailers do not have to implement any compliance measures themselves
Obligations towards the market surveillance authority are the same as for manufacturers and importers
Accessible Services
Requirements for service providers:
| Accessibility information:
| Take changes into account:
|
The implementation of accessibility requirements for services is based on the Web Content Accessibility Guidelines (WCAG). These cover multi-level guidelines and instructions for making web design and development as accessible as possible for people with disabilities. The following disabilities are considered the most important types for implementation:
- Visual impairment and blindness
- Hearing impairment and deafness
- Motor impairments
- Cognitive impairments and learning disabilities
- Photosensitivity
- Multiple impairments
The requirements for presenting services online are fundamentally divided into four principles of accessibility:
| | | |
What Happens if an Economic Operator Fails to Fulfill its Obligations?
If economic operators do not comply with their obligations under the Accessibility Improvement Act (BFSG), the market surveillance authorities of the federal states are responsible for checking compliance with the accessibility requirements.
As part of the market surveillance of products, economic operators must cooperate with the authorities. If a product does not meet the requirements, they will receive a request to establish conformity. If they do not comply with this request, the authorities can restrict or prohibit the provision of the product and issue a recall order.
A similar procedure applies to the market surveillance of services. Service providers must also meet the requirements and can be requested to do so. In the event of non-compliance, the service can be ordered to be discontinued.
In addition, the market surveillance authorities can impose fines of up to 100,000 euros to punish infringements. Consumers and associations have the right to notify the authorities of infringements and can file a complaint if no action is taken. They can also initiate arbitration proceedings in the event of disputes regarding accessibility.
Benefits of the BFSG
| Criticism of the Accessibility Improvement Act
|
BFSG and PIM
The Accessibility Improvement Act (BFSG) places requirements on the accessibility of products and services, especially in digital environments such as online stores. A Product Information Management (PIM) system can play a key role in the efficient implementation of these requirements by enabling the central management of product information and ensuring that this information is prepared in an accessible manner. The BFSG can thus be linked to a PIM system and online stores:
Accessible product information in the PIM system: A PIM system facilitates the central storage of standardized, easy-to-understand product descriptions in accessible language. It ensures that media formats such as images and videos have alternative texts and subtitles and synchronizes accessible information across different channels. | Automated accessibility check: A modern PIM system can implement automatic checks to ensure compliance with accessibility guidelines such as the WCAG standards. Validation tools check the presence of alt texts and the accessibility of form elements, for example. |
Accessible online store: The data stored in the PIM system can be used in an accessible online store. This includes a semantic HTML structure, keyboard navigation, high contrasts and readability as well as compatibility with screen readers. | Accessible e-commerce process: The ordering process in the online store needs to be accessible, with the PIM system ensuring that important information such as prices and availability are clearly displayed. All common payment methods should also be available without barriers. |
Multilingualism and simple language: A PIM system enables the management of product information in different languages and the use of simple language for descriptions. Clearly structured data makes it easier for users to find relevant information. | Product documentation and support: Documentation and instructions should be stored in the PIM system and made available in accessible formats. Accessible contact options for customer service and easy-to-understand FAQ data should also be provided. |
ANTEROS: The PIM System for Accessible and Efficient Product Information
The ANTEROS PIM system offers all these benefits and much more to make your digital content accessible and user-friendly. With ANTEROS, you not only efficiently implement the Accessibility Improvement Act (BFSG), but also optimize your entire product information process. Discover all the features and experience ANTEROS for yourself.
