Accessibility Strengthening Act (BFSG) Series 2/3 – Review and Audit

The Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, or BFSG) transposes the European Accessibility Act (Directive 2019/882) into German law and requires companies to make digital and physical products and services accessible. This guide explains how organizations can prepare effectively, what requirements they need to meet, and how to ensure compliance.

Companies and public institutions face new challenges: by June 28, 2025, they must bring their products and services in line with the new statutory requirements.

Self-Assessment and Audit: How Accessible Is Your Organization?

The first step toward successfully implementing the BFSG is a detailed analysis of your current accessibility status.

Accessibility Check for Websites and Apps

Assess usability for people with visual, hearing, or mobility impairments.

Ensure compatibility with screen readers.

Use clear, high-contrast design elements.

Structure content so it can be operated entirely via keyboard.

Testing Methods & Tools

The following tools can help ensure digital accessibility:

WAVE (Web Accessibility Evaluation Tool): Automated website analysis. [LINK]

Lighthouse (Google tool): Tests accessibility, performance, and SEO. [LINK]

BITV Test (Barrier-Free Information Technology Ordinance Test): Assesses compliance with German accessibility standards. [LINK]

Requirements by Priority Level

Accessibility requirements are divided into three levels based on the WCAG standards:

A – Baseline Requirements (Mandatory under the BFSG)

Text alternatives for non-text content: Images, icons, and diagrams must include alt text.

Keyboard operability: All interactive elements must be usable without a mouse.

Avoidance of flashing content: Content must not flash more than three times per second.

Accessible documents and forms: PDFs must be properly structured, and forms must work with assistive technologies.

AA – Advanced Requirements (Largely mandatory under the BFSG)

Color contrast: Minimum contrast ratio of 4.5:1 for normal text.

Responsive design: Content must remain legible when zoomed up to 200%.

Captions and audio descriptions: All video content must include captions and/or audio descriptions.

Error messages and guidance: Clear, understandable feedback for incorrect form entries.

AAA – Highest Level of Accessibility (Recommended, not mandatory)

Extended audio descriptions for videos

Sign language videos for key content and services

Plain-language explanations for people with cognitive impairments

Legal Framework & Exemptions

Are There Exemptions for Small Businesses?

SMEs with fewer than ten employees and annual revenue below two million euros may be exempt in certain cases.

Even so, voluntary improvements are strongly recommended.

How Is Compliance Monitored and Enforced?

Authorities can conduct audits and require companies to remediate issues.

Non-compliance can result in fines and other sanctions.

Tips for Early Implementation

Make accessibility a permanent part of your digital strategy.

Gather user feedback and feed it into ongoing development.

Implement improvements incrementally rather than through a single overhaul.

To-Do List for Companies

Internal training & awareness: Educate employees on accessibility.

Engage experts: Work with accessibility specialists on analysis and optimization.

Develop an accessibility strategy: Define accessibility as a long-term business objective.

Conclusion

Implementing the BFSG is not just a legal obligation — it's also an opportunity to reach more customers and deliver a better user experience. Companies that prepare early avoid legal risk and can gain a competitive edge through accessible offerings.

Need help making your websites accessible, auditing them, or boosting their conversion performance at the same time? Contact us here!

Overview of our article series "Accessibility Strengthening Act":

Accessibility Strengthening Act – Fundamentals (Feb 13, 2025)

Accessibility Strengthening Act – Audit / Review (Feb 20, 2025)

Accessibility Strengthening Act – Requirement Details (Feb 27, 2025)