Compliance Series • Post 11/20
The BFSG Explained — What the Barrierefreiheitsstärkungsgesetz Really Means for SMEs
The Barrierefreiheitsstärkungsgesetz (BFSG) has applied since June 2025 to all new business websites in Germany. Who is affected, what the 9 mandatory criteria are and how SMEs can become compliant without an agency.
TL;DR
- The BFSG Explained — What the Barrierefreiheitsstärkungsgesetz Really Means for SMEs — a practical guide for the DACH region.
- Covers "barrierefreiheitsstärkungsgesetz" with concrete examples.
- Covers "bfsg 2025" with concrete examples.
- At least 2 snippet-bait patterns for better SERP visibility.
The Barrierefreiheitsstärkungsgesetz (BFSG) is the German implementation of the European Accessibility Act (EAA) and has required companies since 28 June 2025 to make their digital products and services — particularly websites — accessible.
The three critical BFSG facts every SME must know
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BFSG has applied since 28.06.2025. For new websites immediately. Existing websites have a transition period until June 2030 — but anyone building a new website now must be compliant immediately.
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BFSG affects almost all SMEs. Only micro-enterprises with fewer than 10 employees AND less than €2M annual revenue are exempt — and even then only if they make no “substantial change” to their website.
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Violations can be warned off. Competitors and consumer associations can issue warnings for BFSG violations. In addition, authorities can impose fines up to €100,000.
The 9 WCAG 2.1 AA mandatory criteria for SME websites
- Contrast ratio ≥ 4.5:1 for normal text, ≥ 3:1 for large headings
- Alt text for all content images — precise and descriptive
- Keyboard navigation — all interactive elements reachable via Tab
- Visible focus indicator — user must see where keyboard focus is
- Screen reader compatible forms — labels, error messages, input helpers
- Subtitles for videos (if present) — or text alternative
- Responsive up to 200% zoom — no horizontal scrollbar needed
- Consistent navigation — menu structure identical across all pages
- Accessibility statement — publicly visible statement with contact for barrier reports
Who checks — and who sues?
Market surveillance is a state matter. Responsible authorities are the state offices for accessibility. In practice, warnings from competitors are the bigger risk — similar to the GDPR warning wave 2018–2022.
Prevention is simple: A Lighthouse Accessibility score of 95+ already covers ~80% of BFSG requirements. The remaining 20% is documentation (accessibility statement) and manual testing (keyboard navigation, screen reader test).
mekyn websites achieve Lighthouse Accessibility 100 out-of-the-box and include a pre-filled accessibility statement. Manual testing remains with the operator — but with minimal effort.
BFSG vs. WCAG — what’s the difference?
The BFSG is the law. WCAG 2.1 AA is the technical standard it references. Think of it this way:
- BFSG: “Your website must be accessible.” (legal requirement)
- WCAG 2.1 AA: “This is how you make it accessible.” (technical specification)
The WCAG has 50 success criteria at Level AA. For a typical SME marketing website without e-commerce, video or user login, you can reduce this to the 9 criteria listed above.
What the accessibility statement must contain
The accessibility statement is a legal requirement under BFSG §13. It must include:
- Status of compliance: “This website is partially/fully compliant with BFSG.”
- Known barriers: List of elements that are not yet accessible.
- Contact for barrier reports: Email address or contact form.
- Enforcement authority: Name and contact of the responsible state authority.
mekyn includes a template accessibility statement with every generated site. The operator only needs to fill in their contact details.
Timeline: When does what apply?
| Date | Requirement |
|---|---|
| 28.06.2025 | BFSG enters into force for new websites |
| 28.06.2030 | BFSG applies to existing websites (transition period ends) |
| Ongoing | Accessibility statement must be published and updated |
Important: “New” means any website launched after 28.06.2025 OR any substantial redesign of an existing website. Changing the entire navigation structure counts as a substantial change.
Frequently Asked Questions
What is the BFSG?
The Barrierefreiheitsstärkungsgesetz (BFSG) is the German implementation of the European Accessibility Act. It requires companies to make their digital products and websites accessible. In effect since 28 June 2025.
Who must comply with BFSG?
All companies with more than 10 employees OR more than €2M annual revenue that offer products or services to consumers — including websites, online shops and booking systems.
What happens for BFSG violations?
Warnings from competitors and consumer associations, fines up to €100,000 and market surveillance measures by responsible authorities.
How do I make my website BFSG-compliant?
Implement WCAG 2.1 AA criteria: check contrasts, alt text for images, keyboard navigation, screen reader compatibility and an accessibility statement.
Does BFSG apply to existing websites?
Yes, but existing websites have a transition period until June 2030. New websites from June 2025 must comply immediately.
Further reading on mekyn.com
→ Pillar page: Accessibility → Related: GDPR-Compliant Website — the 12 Mandatory Building Blocks → Related: WCAG 2.1 AA — the 9 Most Important Checkpoints → Tool: Contrast Checker (German)
External sources:
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