German Accessibility Strengthening Act (BFSG) Series 3/3 – Detailed Requirements

Germany's Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) transposes the European Accessibility Act (Directive 2019/882) into German law, requiring companies to make digital and physical products, as well as services, accessible. This guide shows how companies can best prepare, which requirements must be met, and how to ensure compliance.

Priority levels of accessibility requirements

Based on WCAG standards, requirements can be divided into the following categories:

A (basic requirements): Essential accessibility features, without which use would be impossible or severely impaired.

AA (enhanced requirements): The standard level, ensuring largely accessible use.

AAA (highest level of accessibility): Recommended, but not mandatory.

Requirements by priority level

A – basic requirements (mandatory under the BFSG)

Text alternatives for non-text content

Images, icons, diagrams, and other visual content must include alternative text.

Alternative text should describe the purpose of the image and be readable by screen readers.

Keyboard operability

All functions and interactive elements must be operable without a mouse, using only the keyboard.

Focus indicators must be visible and allow logical navigation through the page.

Avoiding time limits, or offering alternatives

Content must not disappear automatically after a set time, or an option must be offered to extend or disable the time limit.

Avoiding flashing and flickering

Content must not flash more than three times per second, in order to avoid triggering seizures in people with epilepsy.

Accessible documents and forms

PDFs and other documents must be correctly structured and usable with screen readers.

Forms must be clearly labeled and usable with assistive technologies.

AA – enhanced requirements (recommended, and largely mandatory under the BFSG)

Color contrast and readability

Minimum contrast ratio of 4.5:1 for normal text and 3:1 for large text.

Color must not be the sole means of conveying information.

Responsive design and adaptability

Content must remain legible and usable when zoomed or magnified up to 200%.

Subtitles and audio descriptions for videos

All video content must include subtitles and/or audio descriptions.

Error messages and guidance

Clear, understandable messages for incorrect or incomplete form entries.

Automatic correction suggestions, where possible.

Flexible layout and easy navigation

Navigation must be consistent and intuitive.

Multiple ways to find content (e.g., search, sitemap) should be provided.

AAA – highest level of accessibility (not mandatory, but recommended)

Extended audio descriptions

Videos and multimedia content should include detailed audio descriptions.

Enhanced contrast settings

Even stronger contrast than the AA requirements, especially for users with limited vision.

Alternative communication methods

Providing sign language videos or chats for important content and services.

Explanations in plain language

Providing versions of content in simplified language for people with cognitive impairments.

Conclusion and recommendations

Companies should implement at least the A and AA level requirements to comply with the BFSG's legal provisions. Implementing the AAA criteria can further enhance user comfort and offers significant advantages, particularly for companies with a broad target audience.

It is strongly recommended to:

Conduct regular accessibility tests using tools such as WAVE or Lighthouse.

Provide training for developers, designers, and content managers on accessibility.

Involve users with disabilities in testing processes to gather realistic usability feedback.

With early, strategic planning, companies can not only avoid legal risk but also expand their digital reach and create a better experience for everyone.

Need help making your websites accessible, having them reviewed, or want to take the opportunity to boost their conversion power at the same time? Contact us here!

Overview of our "Accessibility Strengthening Act" article series:

Accessibility Strengthening Act – Fundamentals (Feb. 13, 2025)

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

Accessibility Strengthening Act – Detailed Requirements (Feb. 27, 2025)