BFSG · DeutschlandGermany's accessibility law
BFSG: Germany's accessibility law, explained
The Barrierefreiheitsstärkungsgesetz (BFSG) is Germany's transposition of the European Accessibility Act — and Germany is enforcing it with characteristic thoroughness. If you or your clients sell to German consumers, this is the law that applies.
01
Who it covers
Companies offering products or services to consumers in Germany — including e-commerce of any origin. The microenterprise exemption for services (under 10 employees, €2M turnover) mirrors the EAA. German B2C e-commerce is squarely in scope.
02
Fines and Abmahnungen
§ 37 BFSG allows fines up to €100,000, but reserves that ceiling for specific violations such as offering a non-conforming service; the information and labelling duties top out at €10,000. Enforcement sits with the MLBF, the market surveillance authority of all sixteen federal states, which opens by requesting correction. Separately, competitors and associations send Abmahnungen — cease-and-desist letters that move faster than any regulator.
03
The technical benchmark
Like the EAA, the BFSG points to EN 301 549 and therefore to WCAG level AA. An automated WCAG 2.2 scan finds the most common violations — contrast, alt text, form labels, empty links — which are exactly what an Abmahnung cites first.
04
What agencies should do
Audit every German-market client site now, fix the machine-detectable failures, document the effort (it matters legally), and put monitoring in place so regressions get caught before a competitor's lawyer catches them.
FAQ
Does the BFSG apply to non-German companies?
Yes — it applies to products and services offered to consumers in Germany, regardless of where the company is based.
What is an Abmahnung?
A formal cease-and-desist letter, usually from a competitor or association, demanding you stop a violation and pay the sender's legal costs. Never let the deadline pass — but standing is not automatic: § 8 UWG limits who may send one, and German counsel report that many accessibility Abmahnungen lack a genuine competitive relationship or any specific allegation. Have one reviewed before you pay.
Is there a transition period?
Services already under contract before 28 June 2025 have transition arrangements until 2030 at the latest. New offerings must comply now.
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