What is the European Accessibility Act (EAA)? The German BFSG explained

The European Accessibility Act (EAA) is EU Directive 2019/882, adopted in April 2019. It requires a long list of everyday products and services to be usable by people with disabilities, and it has applied in every EU member state since 28 June 2025. Germany implemented the directive through the Barrierefreiheitsstärkungsgesetz (BFSG), the Accessibility Strengthening Act. The law covers, among other things, online shops and booking systems, consumer banking, e-books, smartphones and self-service terminals such as ticket machines. The technical benchmark is the European standard EN 301 549, which for websites and apps points to WCAG 2.1 Level AA. Market surveillance authorities can demand fixes, prohibit a non-compliant service and impose fines of up to 100,000 EUR. There is one important exemption: microenterprises that provide services, meaning fewer than 10 employees and at most 2 million EUR annual turnover, do not fall under the service obligations.

Which EU law is behind the BFSG?

The starting point is Directive (EU) 2019/882, better known as the European Accessibility Act. The EU adopted it on 17 April 2019 with a simple goal: instead of 27 different national accessibility rules, companies should face one harmonised set of requirements for the whole internal market. Member states had until 28 June 2022 to translate the directive into national law, and the obligations themselves apply since 28 June 2025.

A directive is not directly binding for companies. What binds you is the national implementation, and that is where the BFSG comes in.

What is the Barrierefreiheitsstärkungsgesetz (BFSG)?

The Barrierefreiheitsstärkungsgesetz is the German implementation of the EAA. It was passed in July 2021, so companies had almost four years of lead time, and it applies since 28 June 2025. The technical details live in a separate regulation, the BFSGV, which spells out what accessible actually means for each product and service category.

Enforcement is handled by the market surveillance authorities of the federal states. They coordinate through a central body, the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF) in Magdeburg. Consumers can file complaints there, and the authority can then investigate a provider.

Which products and services are covered by the EAA and BFSG?

The law names concrete categories rather than a blanket rule for everything digital. On the product side it covers, among others:

• Computers, notebooks, tablets and smartphones including their operating systems
• Self-service terminals: ATMs, ticket machines, check-in kiosks, payment terminals
• E-book readers
• Routers and other consumer terminal equipment for telecommunication services

On the service side, which is the part most website owners care about, the list includes:

• E-commerce services, meaning websites and apps through which consumers can conclude contracts, from classic online shops to booking and reservation systems
• Consumer banking services including online banking
• Electronic communication services such as messaging and telephony
• E-books and the software to read them
• Passenger transport services: websites, apps and electronic ticketing for air, bus, rail and waterborne transport

Does the BFSG apply to my website?

This is the question we hear most often, and the honest answer is: it depends on what your website does, not on how big it is. The decisive criterion for most businesses is whether you offer an e-commerce service to consumers. If visitors can buy something, book an appointment that forms a contract, order a subscription or complete a checkout of any kind, you are very likely in scope. A pure brochure website that only presents your company, without any ordering or booking function, is generally not covered by the BFSG.

Two more points that surprise people regularly. First, the law protects consumers, so pure B2B offerings are out of scope. Second, the rules follow the market, not the company headquarters: a shop operated from outside the EU that clearly targets EU consumers has to comply as well. And keep in mind that this article explains the rules, but it cannot replace legal advice for your specific setup.

Are small businesses exempt from the BFSG?

Partially. The EAA and the BFSG exempt microenterprises, but only for services. A microenterprise employs fewer than 10 people and has an annual turnover or balance sheet total of at most 2 million EUR. Both conditions must be met. A two-person web shop below that threshold therefore does not fall under the service obligations, while a manufacturer of covered products cannot rely on this exemption at all.

Beyond the microenterprise rule there is a general escape hatch: if compliance would fundamentally alter the product or service, or would impose a disproportionate burden, a company can invoke that and document the assessment. In practice the bar is high, and simply arguing that accessibility costs money will not be enough.

Even if you are exempt, it is worth remembering why the law exists. The WHO estimates that about 16 percent of the world population lives with a significant disability. An accessible shop is not just a legal checkbox, it is a bigger addressable market and usually better usability for everyone.

Which technical standard applies? EN 301 549 and WCAG 2.1 AA

The BFSG itself does not contain a single technical checklist. Instead, conformity is presumed when you follow the harmonised European standard EN 301 549. For websites and mobile apps, that standard incorporates the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA. In plain terms: if your website conforms to WCAG 2.1 AA, you are on solid ground for the web-related requirements.

WCAG 2.2 has been the current W3C recommendation since October 2023, but EN 301 549 has not been updated to reference it yet. Building against 2.2 anyway is a sensible choice, since the newer criteria are a superset in spirit and a future update of the standard is expected.

What are the deadlines and transition periods?

The core date is 28 June 2025. Since then, products placed on the market and services offered to consumers must be accessible. There are transition rules that soften the edges: services may keep using products that were lawfully in use before that date until 27 June 2030, and self-service terminals may stay in operation for up to 15 years from the start of their use. Service providers also have information duties and must describe in a publicly available form how their service meets the accessibility requirements.

Do not let the transition periods lull you into waiting. They cover legacy hardware and existing contracts, not a redesigned shop you launch next quarter.

What are the penalties for BFSG violations?

The market surveillance authority can first require you to fix the problem within a deadline. If that does not happen, it can restrict or prohibit the offering of the service and impose fines of up to 100,000 EUR, depending on the violation. On top of the official enforcement there is a quieter risk: accessibility defects are visible to everyone, including competitors and consumer associations, and a public complaint is not the kind of marketing anyone wants.

EAA vs Web Accessibility Directive: private vs public sector

The EAA is often mixed up with an older EU rule that covers the public sector. The two exist side by side:

The convenient part: both worlds point to the same technical standard, so the practical work on your website is identical.

How do I make my WordPress website EAA compliant?

Accessibility is not a plugin you install once, but for a typical WordPress site the path is well trodden. Start with the foundations and work upwards:

• Choose a theme that takes accessibility seriously, ideally one carrying the accessibility-ready tag in the WordPress theme directory
• Fix color contrast: normal text needs a contrast ratio of at least 4.5:1 against its background
• Write meaningful alternative text for images that carry information
• Make the whole site usable by keyboard alone, including menus, sliders and modals
• Give every form field a visible label and clear, text-based error messages
• Use real headings in a logical hierarchy instead of styled paragraphs
• Provide captions for videos and avoid content that only works with a mouse
• Publish an accessibility statement describing the state of your site and a contact for feedback

Then test. Automated checkers find a solid share of the issues, but a keyboard-only walkthrough and a screen reader session (NVDA on Windows is free, VoiceOver ships with macOS) will show you problems no scanner can see.

How does InspectWP help with accessibility?

InspectWP runs automated accessibility checks as part of its website analysis and flags common WCAG failures such as missing alternative texts, insufficient color contrast, missing form labels and broken heading structure, each with a severity rating and a pointer to the affected element. That gives you a prioritized starting list for BFSG compliance work instead of a vague feeling that something might be wrong. Automated findings do not replace a manual audit, but they cover the ground quickly and repeatably, and with scheduled reports you notice regressions before your users or a market surveillance authority do.