Germany accessibility law: BFSG explained

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.

If your service reaches consumers in Germany, EAA enforcement applies the same way it does to a domestic provider. The "country of consumption" rule means a Shopify store run from outside the EU but selling into Germany is covered. There is no carve-out for non-EU sellers.

What the law actually requires

The technical baseline is WCAG 2.1 Level AA via EN 301 549 v3.2.1. EN 301 549 references WCAG 2.1 Level AA in full and adds a few requirements specific to mobile apps and documents. Beyond the technical bar, Germany requires the following operational items, which auditors check first because they are simple to verify:

• 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Up to €100,000 per infringement; market surveillance can also order products withdrawn from sale.

Marktüberwachungsbehörde (state-level market surveillance authorities) runs the audits. They start with the largest covered services and move down. The first cycle of EAA audits in 2025–2026 will focus on visible non-compliance — missing accessibility statements, obvious WCAG violations on the homepage, lack of feedback channel — because those are cheap to detect. Deep technical audits come later.

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.

Practical first steps for a Germany site

If you are starting now and want to land before enforcement, run an automated audit, fix the high-impact issues (contrast, labels, keyboard, focus), publish an accessibility statement, and set up a feedback inbox. That sequence covers 80% of what auditors look for in a first sweep.

• Run a baseline scan to know your current score

• Fix critical and serious issues in priority order — these are the ones cited in complaints

• Publish a public accessibility statement on a stable URL (Germany regulators expect this discoverable)

• Add a feedback channel and answer within the country-specified window

• Re-scan after every major release; track regressions

Frequently asked questions

Accessibility law in nearby jurisdictions