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Accessibility Act (BFSG)

The Accessibility Act (BFSG) regulates the accessibility of products and services in Germany and implements the requirements of EU Directive 2019/882 (European Accessibility Act, EAA). It applies to digital products, websites, apps and self-service terminals, among other things. The aim is to improve the participation of people with disabilities in digital services.

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Legal basis

The EAA is based on various international, European and national standards. These include

  • Web Content Accessibility Guidelines (WCAG 2.1) of the World Wide Web Consortium (W3C), which are recognized as ISO standard 40500.
  • EN 301 549, the European standard for accessibility in information and communication technologies, which explicitly refers to WCAG 2.1.
  • BITV 2.0 (Barrier-free Information Technology Ordinance), which prescribes the implementation of WCAG 2.1 for public bodies in Germany.
  • Implementing Decision (EU) 2018/2048, which sets out the technical requirements of Directive (EU) 2016/2102 for public sector bodies.

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Scope of application of the BFSG

The BFSG applies to products and services that come onto the market after June 28, 2025. This includes:

  • Websites and mobile apps
  • E-commerce platforms
  • Banking and financial services
  • Ticket and booking systems
  • Telecommunication services
  • Self-service terminals (e.g. ticket machines, ATMs)

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The four principles of accessibility

WCAG 2.1 and EN 301 549 are based on four fundamental principles:
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Perceivability - content must be accessible to all senses

  • Alternative text for images
  • Subtitles for videos
  • Customizable font sizes

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Usability - users must be able to control content

  • Keyboard operability
  • Avoidance of time-critical interactions
  • No flashing or flickering content

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Comprehensibility - content must be easy to read and predictable

  • Clear language
  • Consistent navigation
  • Support for input errors

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Robustness - content must be compatible with different technologies

  • Screen reader support
  • Use of standards-compliant web technologies

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Technical standards

EN 301 549 refers directly to WCAG 2.1 and thus ensures that digital content is designed to be accessible in accordance with recognized international standards. In addition, there are:

  • Authoring Tool Accessibility Guidelines (ATAG) for accessible authoring tools
  • User Agent Accessibility Guidelines (UAAG) for browsers and media players

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WCAG 2.1 conformance levels

WCAG 2.1 is divided into three conformance levels:

  • A (basic requirements)
  • AA (standard for public bodies and companies)
  • AAA (highest standard, but not mandatory)

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EN 301 549 requires compliance with levels A and AA, whereby these are classified as “mandatory criteria”.

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Implementation and monitoring

In Germany, compliance with the BFSG is monitored by the relevant authorities. Companies that violate the regulations must expect sanctions. Complaints can be submitted via special bodies.

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Conclusion

The BFSG sets high standards for digital accessibility and contributes to inclusive participation. Companies should start implementation at an early stage in order to meet the legal requirements and make their digital offerings accessible to all.

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Sources:

https://www.bmas.de/DE/Service/Gesetze-und-Gesetzesvorhaben/barrierefreiheitsstaerkungsgesetz.html

https://www.barrierefreiheit-dienstekonsolidierung.bund.de/Webs/PB/DE/gesetze-und-richtlinien/wcag/wcag-artikel.html

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