German Accessibility Strengthening Act: duties for digital services and contracts

Short answer: BFSG compliance has been mandatory in Germany since 28 June 2025. The German Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) requires companies to make certain consumer products and services accessible, above all online shops, online banking, telecoms services and e-books. Service providers must also publish accessibility information. Micro-enterprises that only provide services are exempt, and service contracts concluded before the deadline benefit from a transition period of no more than five years.

This article is for in-house legal, compliance and digital teams at companies that sell to consumers in Germany, including Swiss and other non-German businesses. It explains who the BFSG covers, which deadlines still apply, what to address in contracts and which roles the work requires.

What is the German Accessibility Strengthening Act about?

The BFSG is the first German law that obliges private businesses to make products and services accessible. It transposes Directive (EU) 2019/882, the European Accessibility Act. The directive has applied in all EU member states since 28 June 2025 (Article 31), and each state has written it into its own law.

Under section 3(1) BFSG, products and services are accessible when people with disabilities can find, access and use them in the usual way, without particular difficulty and, in principle, without help from others. The detailed requirements are set out in the implementing ordinance (BFSGV). Examples:

• More than one sensory channel: instructions and warnings must be perceivable, for example visually and by touch or sound (section 4 BFSGV).
• Online shops: provide accessibility information on the products sold, where the manufacturer supplies it, and make identification, authentication and payment functions perceivable, operable, understandable and robust (section 19 BFSGV).
• Consumer banking: information must be understandable and must not exceed language level B2 (section 17(2) BFSGV).

For websites and apps, the Federal Accessibility Agency (Bundesfachstelle Barrierefreiheit) points to the European standard EN 301 549, which in turn refers to the Web Content Accessibility Guidelines (WCAG). Meeting a harmonised standard creates a presumption of conformity (sections 4 and 5 BFSG).

Who is affected?

The BFSG applies to manufacturers, distributors and importers of listed products and to providers of listed services for consumers (section 1(2) and (3) BFSG). According to the Federal Accessibility Agency, services offered only to businesses are not covered.

Exemptions: micro-enterprises that provide services, meaning fewer than ten employees and annual turnover or balance sheet total of no more than EUR 2 million, are exempt (section 3(3) BFSG). The exemption does not apply to products. Other companies may rely on a fundamental alteration of the product or service or a disproportionate burden (sections 16 and 17 BFSG), but must justify this, and the authority can review it.

Brochure websites that only inform or advertise, with no contract concluded online, should not count as e-commerce services in the Federal Accessibility Agency's view. The test is whether a consumer contract is concluded through the website or app (section 2 no. 26 BFSG).

Swiss companies: the directive does not apply in Switzerland. Swiss businesses that sell products or digital services to consumers in Germany should nevertheless check whether the BFSG, or another EU member state's implementing law, applies to them.

Deadlines and status

The obligations have applied since 28 June 2025; only transition periods remain open. The table shows the position on 10 November 2026.

The transition period does not cover every digital offering. Under Article 32 of the directive, service contracts agreed before 28 June 2025 may continue unchanged until they expire, but for no longer than five years. New contracts and new services must comply now.

What companies need to do now

Companies in scope need an inventory of affected offerings, a test standard and contracts that support both. A practical sequence:

1. Confirm scope: list every product, website, app and customer journey through which consumers conclude contracts, and record for each whether and why the BFSG applies.
2. Document exemptions: set out the reasoning for micro-enterprise status, disproportionate burden or fundamental alteration in writing; market surveillance may test it.
3. Set the test standard: use EN 301 549 and WCAG as the benchmark for testing, acceptance and remediation.
4. Publish the Annex 3 information: a general description of the service, explanations needed to understand how it works, how it meets the accessibility requirements and the competent market surveillance authority (section 14(1) no. 2 BFSG). The law names the terms and conditions as one possible place; the Federal Accessibility Agency also recommends an "Accessibility" link in the header or footer.
5. Update supplier contracts: bind agencies, software vendors and platform providers to the test standard and agree acceptance criteria, remediation, support with authority requests and documentation.
6. Map legacy contracts: record consumer contracts concluded before 28 June 2025 with their terms, and plan the switch-over by June 2030 at the latest.
7. Organise complaints and authority requests: assign ownership, deadlines and response templates for MLBF requests and for conciliation under section 16 of the Disability Equality Act (BGG).

If requirements are not met, the market surveillance authority asks the company to restore conformity. If it does not, measures can range from fines to prohibiting the service. Consumers and associations can apply to the authority for action.

Which roles and how much capacity the work needs

BFSG compliance cuts across legal, product development and procurement. On the legal side, the effort sits mainly in the scope assessment, the mandatory information and contract updates.

Example (assumption): a retailer has 120 supplier and agency contracts that touch digital customer journeys. At 90 minutes per contract for review and amendment, that is 180 hours. Add 60 hours for scope, exemptions and mandatory information. At a 60% workload, one contract lawyer would be busy for about two months.

How interim support helps

Interim professionals close the gap when the BFSG review and contract updates come on top of day-to-day work, while the company stays in control. Alpinum Solutions provides IT and technology lawyers, contract lawyers, contract managers and compliance specialists through Arbeitnehmerüberlassung (German temporary agency work, staff leasing) and freelancing, part-time or full-time at 20 to 100%. In staff leasing, the client directs the work; freelancers work independently within the agreed mandate. For staff leasing in Germany, Alpinum holds the licence of the Regionaldirektion Hessen of the Federal Employment Agency.

• Project support: lawyers for scope assessment, mandatory information and contract amendments, see IT, technology and data privacy law: project lawyers.
• Contract volume: teams to review large numbers of supplier and agency contracts, see Commercial contracting and contract management.
• Related EU rules: from 9 December 2026, new product liability rules also apply to new products and software, see New EU Product Liability Directive: effects on contracts, software and compliance.

Alpinum is not a law firm and does not give legal advice; whether an offering falls under the BFSG is for the company to assess case by case.

Frequently asked questions about BFSG compliance

Does the BFSG apply to every company website?

No. Websites and apps fall under the BFSG when they deliver a covered consumer service, such as online banking or concluding a consumer contract online. A brochure website that only informs or advertises should not be covered, according to the Federal Accessibility Agency. The German labour ministry's guidelines, however, cite online appointment booking as an example of a covered e-commerce service.

Does the BFSG apply to B2B business?

As a rule, no. The BFSG covers products and services used by consumers, meaning individuals acting mainly outside their trade, business or profession. The Federal Accessibility Agency states that services offered only to businesses are not affected. Companies serving mixed customer groups should assess and document consumer access separately rather than assume an exemption.

Which companies are exempt from the BFSG?

Micro-enterprises that provide services are exempt: fewer than ten employees and annual turnover or balance sheet total of no more than EUR 2 million (section 3(3) BFSG). The exemption does not cover products. Other companies can only rely on a disproportionate burden or a fundamental alteration of the offering, and they must justify and document it.

What must companies state in their terms and conditions?

Service providers must publish the information set out in Annex 3 BFSG: a general description of the service, explanations of how it is delivered, how it meets the accessibility requirements and the competent market surveillance authority. The law names the terms and conditions as one possible place. The information itself must be accessible, easy to find and understandable, and kept available for as long as the service is offered.

What happens if a company breaches the BFSG?

The joint market surveillance authority of the German states checks services by sampling and follows up complaints. If it finds shortcomings, it asks the company to restore conformity. If the company does not, fines and ultimately a ban on the service are possible. Consumers and associations can apply for measures and, if refused, go to the administrative courts.

Next step

If the scope assessment, mandatory information or contract updates need more capacity than your team has, talk to us about scope and profile. Alpinum Solutions is the leading provider of interim legal & compliance in Germany; your company directs the assignment. Selected profiles are usually available within 48 hours; companies and Alpinum agree the start date together.

• IT, technology and data privacy law: professionals and project lawyers
• Interim legal and compliance in Germany
• EU Data Act: what legal teams need to implement in contracts and data access
• Regulatory radar: all articles on regulatory change
• Discuss your needs

Last updated: 10 November 2026.