Who has to comply
B2C e-commerce, banking, e-books, transport ticketing, computers, smartphones, TVs, ATMs, payment terminals, and self-service kiosks. Microenterprises (<10 employees AND <€2M turnover) selling services are exempt.
Germany is the largest e-commerce market in the EU, which makes it the single most likely place for a non-EU seller to trip the BFSG. Under the country-of-consumption principle, a Shopify or Amazon storefront run from the US, UK or Asia is fully covered the moment it ships to a German consumer or prices in euros for a German address. German consumers are also unusually litigious about consumer rights, and Abmahnung (formal cease-and-desist) letters from competitors and consumer associations are a well-established enforcement channel that reaches foreign sellers through their German-facing checkout.
What the law actually requires
BFSG sets the technical bar at WCAG 2.1 Level AA via EN 301 549 v3.2.1. On top of it, Barrierefreiheitsstärkungsgesetz (BFSG) lists these operational duties:
- Conformance with EN 301 549 v3.2.1 (which references WCAG 2.1 Level AA) for digital services
- A public accessibility statement on every covered service
- Feedback mechanism for users to report accessibility issues
- Documented compliance — internal records of conformity, kept for 5 years
- Periodic re-evaluation when the service changes substantially
Penalties and how enforcement actually works
Up to €100,000 per infringement; market surveillance can also order products withdrawn from sale.
Germany does not have a single national regulator. The BFSG is enforced by the market surveillance authorities (Marktüberwachungsbehörden) of the 16 federal states, coordinated loosely through a joint federal body, so which office contacts you depends on where your German activity is concentrated. Enforcement is largely complaint- and sweep-driven rather than proactively technical in the first cycle: authorities react to consumer reports and can demand your conformity documentation, order remediation within a set period, and ultimately order a product or service withdrawn from the German market if you ignore them.
Public-sector obligations
Germany also has a separate public-sector law: BITV 2.0 (Barrierefreie-Informationstechnik-Verordnung) for federal and state public-sector websites and apps; in force since 2011, last updated 2019. It predates the EAA and remains in force for government and public-funded sites. Public bodies must publish a conformance statement and re-audit periodically.
Reading the BFSG at the source
The law is cited as Barrierefreiheitsstärkungsgesetz (Barrierefreiheitsstärkungsgesetz (BFSG)). Enforcement: Marktüberwachungsbehörde (state-level market surveillance authorities). Key date: 28 June 2025. For the exact wording, read the 2 official references for Germany listed under Sources below.
Sources
- BFSG text (Gesetze im Internet, Federal Ministry of Justice)
- EN 301 549 standard (ETSI search)
- European Accessibility Act (Directive (EU) 2019/882) · European Commission
Links checked 12 October 2026. Not legal advice. Methodology · About Certvo
Frequently asked questions
Does BFSG apply to my B2B German website?
No — the BFSG covers consumer-facing (B2C) services. Public-sector and federal sites are covered by BITV 2.0. Pure B2B sites are out of scope, but most checkouts and account flows that any consumer can use trigger BFSG.
What if I am a microenterprise?
Microenterprises with fewer than 10 employees AND less than €2M turnover that provide services (not products) are exempt. Product manufacturers do not get the exemption.
When does enforcement actually start?
28 June 2025. Market surveillance authorities can begin issuing notices from day one. Existing service contracts have transitional protection until 28 June 2030.