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Am I affected by the BFSG? A self-check for Germany’s accessibility law

Find out in up to seven questions whether your offer is likely to fall under Germany’s Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG). The check considers consumer focus, the type of service or product, the micro-enterprise exemption and the transitional rules. Below it, we explain each criterion with the relevant section of the law and examples.

Legal status checked on 13 November 2026

Start the self-check

Answer up to seven short questions. You can go back and change answers at any time. At the end you will see an assessment with reasons and the legal basis under German law.

The criteria at a glance

Whether the BFSG applies does not depend on having a website, but on what you offer and to whom. The self-check asks about these points one after another:

  1. Covered offer: The law only applies to the products in § 1(2) and the services in § 1(3) BFSG. Other offers are not covered.
  2. Consumer focus: Services are covered if they are provided to consumers (§ 1(3), § 2 no. 16 BFSG). A pure B2B offer is assessed differently.
  3. Company size: Micro-enterprises that offer or provide services are exempt under § 3(3) BFSG. This exemption does not apply to products.
  4. Timing and transition: The BFSG applies to services provided to consumers after 28 June 2025 and to products placed on the market after that date. § 38 BFSG contains limited transitional rules.

Which services does the BFSG cover?

§ 1(3) BFSG lists five groups of services for consumers. According to the joint market surveillance body of the German federal states (MLBF), this list is exhaustive.

E-commerce
Services offered via websites or apps and provided electronically at the individual request of a consumer with a view to concluding a consumer contract (§ 2 no. 26 BFSG). Typical examples are online shops, binding online bookings, subscriptions and ticket purchases, even if the goods sold are not BFSG products themselves.
Banking services for consumers
Among other things consumer credit, certain investment services, payment services, services linked to a payment account and e-money (§ 2 no. 24 BFSG).
E-books and reading software
Services that provide digital book files and software designed specifically for accessing, navigating and reading these files (§ 2 no. 37 BFSG).
Telecommunications services
For example internet access and telephony, except transmission services used for machine-to-machine communication (§ 1(3) no. 1 BFSG).
Elements of passenger transport
In air, bus, rail and water transport: websites, mobile services and apps, electronic tickets and ticketing services, transport information and interactive self-service terminals. For urban, suburban and regional transport, only the requirements for interactive self-service terminals apply (§ 1(3) no. 2 BFSG).

For covered services, § 14 BFSG requires that they meet the requirements of the implementing ordinance (BFSGV) and that you make the information under Annex 3 available in an accessible form. Under § 12 BFSGV, websites and apps must be perceivable, operable, understandable and robust; for e-commerce, § 19 BFSGV adds identification, authentication and payment functions, among others.

Which products does the BFSG cover?

§ 1(2) BFSG lists five product groups placed on the market after 28 June 2025:

General-purpose computers
Consumer general-purpose computer hardware, such as desktops, notebooks, smartphones and tablets, and the operating systems for it.
Terminals
Payment terminals as well as ATMs, ticketing machines, check-in machines and interactive information terminals intended for services under the BFSG.
Telecommunications terminal equipment
Consumer terminal equipment with interactive computing capability used for telecommunications services.
Terminal equipment for media services
Consumer terminal equipment with interactive computing capability whose main purpose is access to audiovisual media services.
E-readers
Dedicated devices with hardware and software for accessing, navigating and reading e-book files.

Manufacturers, authorised representatives, importers and distributors each have their own obligations depending on their role (§§ 6 to 13 BFSG). The micro-enterprise exemption does not apply to products.

Exemption for micro-enterprises

A micro-enterprise employs fewer than ten people and has either an annual turnover of at most 2 million euros or an annual balance sheet total of at most 2 million euros (§ 2 no. 17 BFSG). The headcount and at least one of the two financial limits must be met together. Micro-enterprises that offer or provide services are exempt from the accessibility requirements (§ 3(3) BFSG).

The joint market surveillance body of the German federal states (MLBF) explains the calculation: annual work units are decisive, part-time and seasonal work count proportionally, and apprentices do not count, nor do staff on maternity or parental leave for that period. Turnover is counted without VAT. For partner and linked enterprises, their figures are included proportionally or in full depending on the link. The size class only changes once a threshold has been exceeded or undercut in two consecutive financial years; as evidence, the MLBF mentions records from at least the last two financial years.

The Federal Accessibility Agency (Bundesfachstelle Barrierefreiheit) advises micro-enterprises under § 15 BFSG. An accessible website is worthwhile even without an obligation: it reaches more people, and growing beyond the thresholds later will not require a rebuild under time pressure.

Transitional rules and excluded content

The BFSG contains no general grace period for websites or shops offered to new customers today. § 38 BFSG only covers certain cases, and § 1(4) excludes specific content:

  • Service contracts concluded before 28 June 2025 may continue unchanged until they expire, but no later than 27 June 2030 (§ 38(1) BFSG).
  • Products a service provider already used lawfully for its service before 28 June 2025 may be used until 27 June 2030 (§ 38(1) BFSG).
  • Self-service terminals used lawfully before 28 June 2025 may continue to be used until the end of their economic life, but no longer than 15 years after they were first put into use (§ 38(2) BFSG).
  • Excluded are pre-recorded time-based media and office file formats published before 28 June 2025, certain online maps, third-party content that you neither fund, develop nor control, and archives that are no longer updated after 28 June 2025 (§ 1(4) BFSG).

§§ 16 and 17 BFSG set further limits: the requirements only apply insofar as they do not cause a fundamental alteration of the service or a disproportionate burden. You can only rely on this with a documented assessment.

Practical examples

These examples show typical classifications. They do not replace an assessment of your specific case.

Fashion online shop with 15 employees
Likely affected. Consumers conclude purchase contracts in the shop; that is e-commerce (§ 1(3) no. 5 BFSG). With 15 employees, the micro-enterprise exemption does not apply.
Online shop with six employees and 1.2 million euros turnover
Likely not affected for the shop as a service, because the micro-enterprise exemption applies (§ 3(3) BFSG). If the shop sells smartphones or e-readers, for example, the distributor obligations for these products still apply.
Craft business with an information website and contact form
Likely not affected. No consumer contract is concluded via the website; a contact form for questions does not turn it into e-commerce on its own.
Practice or salon with online appointment booking
Borderline case. Whether an online booking aims at concluding a consumer contract depends on the process and should be checked. If the business has fewer than ten employees and at most 2 million euros turnover or balance sheet total, the micro-enterprise exemption applies anyway.
Wholesaler with a shop for business customers only
Likely not affected if private individuals actually cannot order, for example because business status is verified before the first order. A mere note in the footer is not a reliable basis for this classification.
Meal delivery service (“meals on wheels”) with online ordering
Likely covered according to the Federal Accessibility Agency, because the website or app aims at concluding a consumer contract; subject to the micro-enterprise exemption.
Manufacturer of payment terminals
Likely affected regardless of company size: payment terminals are products under § 1(2) no. 2 BFSG, and the micro-enterprise exemption only applies to services.

Frequently asked questions about being affected by the BFSG

Does the BFSG apply to every company website?

No. The BFSG covers certain products and services for consumers, not websites as such. A website that only provides information about your company is generally not covered. That changes once consumers can conclude a contract through it.

Does the whole website have to be accessible or only the checkout?

The Federal Accessibility Agency writes that the requirements in § 12 no. 3 BFSGV and the surveillance rules in Annex 1 BFSG suggest that the entire website or app of a covered online shop must meet the requirements. Still, start with the journey up to the conclusion of the contract, because barriers there prevent the most.

Does the micro-enterprise exemption also apply to products?

No. § 3(3) BFSG only exempts micro-enterprises that offer or provide services. Anyone who manufactures, imports or sells covered products has the product obligations regardless of size.

Is a “business customers only” note enough?

What matters is whether private individuals can actually conclude a contract. A note without any verification may not be enough for a reliable classification. Record how you restrict your customer base and have borderline cases checked.

Is there a transition period for existing online shops?

Not in general. The BFSG has applied since 28 June 2025. § 38 BFSG only allows service contracts concluded before that date to continue unchanged until 27 June 2030 at the latest, and products and terminals already in use to keep being used.

Who checks compliance and what are the consequences?

The joint market surveillance body of the German federal states (MLBF) is responsible. It checks on suspicion and by random sampling, first asks for corrections and can prohibit an offer as a last step. § 37 BFSG provides for fines of up to 100,000 euros. Our article on BFSG warning letters explains whether warning letters under competition law are possible as well.

Which technical requirements apply to websites?

Under § 12 BFSGV, websites and apps must be perceivable, operable, understandable and robust. For websites and apps, the Federal Accessibility Agency refers to the requirements of EN 301 549. If a service meets harmonised standards published in the Official Journal of the EU, § 4 BFSG presumes that it meets the requirements they cover.

Does an accessibility widget replace the implementation?

No. A widget can offer personal reading aids, but it does not fix barriers in the code or content and does not prove conformity with the BFSG and the BFSGV.

Are my answers in the self-check stored?

No. The check runs entirely in your browser. The answers are neither sent to Accessonaut nor stored nor written into the page address. They are gone when you reload.

What you can do next

If you are likely affected, start by testing the most important pages and the journey up to the conclusion of the contract, fix barriers and publish the information under Annex 3. If you are not affected, an accessible website is still worthwhile.

Limits of this self-check

The self-check is not legal advice. It reflects the criteria of the German BFSG in simplified form and relies on your answers. It does not check sector-specific laws, obligations of public sector bodies under the BGG and BITV 2.0, or contracts with your customers. Results such as “likely not affected” only hold as long as your offer does not change. For borderline cases, linked enterprises or a warning letter, get individual advice.

Other countries:Austria: Accessibility Act (BaFG)Switzerland: legal framework and standards

Sources and review status

Legal status checked on 13 November 2026.

Further reading on the BFSG

All articles in the knowledge base