June 28, 2025 marks the crucial deadline by which all necessary adaptations to websites and digital services must be implemented as part of the Accessibility Reinforcement Act (BFSG). This national implementation of the European Accessibility Act (Directive (EU) 2019/882) aims to remove barriers for people with disabilities so that they can participate in digital life on an equal footing. Online retail companies, hardware and software manufacturers and media providers are all affected. Failure to comply could result in bans, warnings and fines.
We will explain the background and support you in dealing with the new legal requirements in a practical way.
Who is obligated?
Inclusion is to be promoted, particularly in the use of digital services. Products and services that are made accessible after June 28, 2025 must be designed to be barrier-free. An exception applies to companies with fewer than 10 employees or an annual turnover of less than 2 million euros.
This affects manufacturers, retailers and importers as well as service providers – including many web store operators. The object of the requirements is hardware, software, terminals or media devices to be designed inclusively, but also services from the areas of telecommunications, ticket and booking systems. In addition, all electronic commerce is affected by the new regulations and therefore every online offer of goods or services.
What are the obligations?
The requirements for the overarching goal of accessibility are based on the state of the art. Companies must adhere to norms and standards that are regularly published by the Federal Accessibility Agency.
Products (e.g. packaging, instructions for use) and services (e.g. presentation of offers) must be accessible and usable for people with disabilities. The most important requirements are:
- Availability of information about products or services
- with more than one sensory channel, e.g. visual and auditory
- with legible font size or zoom option
- without using hard-to-read representations (colors, contrasts, structure)
- Navigation without mouse, i.e. only with the keyboard
- Image descriptions, subtitles and alternative texts for visual and audio content
- Easy to understand language
- Declaration on accessibility as mandatory information
Public bodies have been obliged to do so since 2021. Their implementation can therefore be used as a guide. In addition to “easy language”, zoom or read-aloud functions are also used, and occasionally even sign language.
Sanctions for violations
Market surveillance authorities can intervene in the event of breaches of accessibility requirements. This can be accompanied by prohibition orders through to the ordering of product recalls. Not only manufacturers are affected, but also dealers and importers. Fines of up to €100,000 are also possible.
Consumers can also independently apply to the market surveillance authorities for such measures. Even class actions are conceivable.
It remains to be seen whether warnings will also be issued by competitors or consumer protection associations. This would certainly be the most unpleasant consequence of non-compliance with the BFSG requirements.
Implementation in practice
You should therefore start working on adapting your website now. Plugins that implement the requirements of the BFSG in the software are certainly useful. However, the legal texts must also be adapted: A declaration on accessibility must be provided as mandatory information on the website.
