BFSG countdown
The Barrierefreiheitsstärkungsgesetz (BFSG) transposes the European Accessibility Act into German law. The main deadline was 28 June 2025 — it has passed, and the requirements have applied ever since. Only two narrowly drawn transitional periods under § 38 BFSG remain open. Select what you offer and you will see whether you are covered and which deadline is still running for you.
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Material scope under § 1(2) BFSG. Multiple selection. There is no micro-enterprise exemption for products.
Material scope under § 1(3) BFSG. Multiple selection. The micro-enterprise exemption only bites here.
Both conditions have to be met for the exemption in § 3(3) BFSG to apply.
Only these two deadlines are still running. Everything else has applied directly since 28 June 2025.
Calculating deadlines …
§ 1 BFSG defines the material scope: it covers certain products — general-purpose computer hardware with its operating system, self-service terminals, consumer terminal equipment for telecommunications and audiovisual media services, e-book readers — and certain services, namely telecommunications services, elements of passenger transport services, consumer banking services, e-books and e-commerce services. § 3(1) BFSG obliges economic operators to make those products and services accessible; the substantive requirements are set out in the BFSGV. § 3(3) BFSG exempts micro-enterprises — but only in so far as they provide services, never for products. § 38 BFSG contains two transitional provisions: service providers may continue to provide services using products they already lawfully used for that purpose before 28 June 2025, but no later than 27 June 2030, and self-service terminals may continue to be used until the end of their economically useful life, and for no more than 15 years after they were put into use.
Orientation only — not legal advice. Whether a specific offering falls within scope is a question of interpretation in the individual case; this tool reproduces the statutory categories but examines neither your product nor your website. Nor does it replace the assessment of whether there is a disproportionate burden under § 17 BFSG or a fundamental alteration under § 16 BFSG.
Frequently asked
- The deadline has passed — why a countdown at all?
- Because two deadlines are still running. The main deadline of 28 June 2025 has passed; the accessibility requirements have applied directly ever since, and there is no general grace period. § 38 BFSG does allow two narrowly defined exceptions: continued use of products already deployed to provide a service before 28 June 2025, no later than 27 June 2030, and continued use of self-service terminals until the end of their economically useful life, capped at 15 years from being put into use. Both expire and both can be dated — which is exactly what the countdown shows.
- Does the 2030 date mean my website only has to be accessible by 2030?
- No, and this is the most common misunderstanding. § 38(1) BFSG permits a service to continue being provided using products already in place — hardware lawfully deployed before 28 June 2025, for instance. The service itself, including its web presence and its checkout flow, has had to meet the requirements since 28 June 2025. An online shop is not a piece of stock you get to use up.
- Does the micro-enterprise exemption apply to me?
- Micro-enterprises within the meaning of the BFSG are undertakings with fewer than ten employees whose annual turnover or annual balance sheet total does not exceed EUR 2 million. Under § 3(3) BFSG they are exempt from the accessibility requirements — but only in so far as they provide services. Anyone who manufactures, imports or distributes products is fully covered even as a micro-enterprise. Both thresholds have to be checked: the headcount must be below ten and one of the two financial limits must also be met.
- Which technical requirements apply in practice?
- The substantive requirements are set out in the ordinance to the BFSG (BFSGV), which works through each product and service category individually. Under § 4 BFSG, products and services are presumed to meet the requirements in so far as they conform to harmonised standards. The recognised state of the art for ICT is EN 301 549, which for web content and mobile applications refers to WCAG 2.1 Level AA. Working to WCAG 2.1 AA therefore means working to the reference that matters in practice — but the assessment still has to be aligned with the BFSGV.
- What are the consequences of non-compliance?
- Since 2025, market surveillance for the whole of Germany sits with the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF), based in Magdeburg. It can order measures up to and including prohibiting a service from being offered or a product from being made available. § 37 BFSG provides for fines of up to EUR 100,000 for the more serious infringements and up to EUR 10,000 for the remainder. Under § 32 BFSG, consumers as well as recognised associations and qualified entities can apply for the market surveillance authority to act. Beyond that, a warning-letter risk under unfair competition law is being discussed; whether accessibility failures are actionable under competition law has not been conclusively settled.
- How does this differ from BGG and BITV 2.0?
- The BGG and the BITV 2.0 made under it bind federal public bodies; the Länder have their own equivalent statutes and ordinances. The BFSG, by contrast, addresses the private sector and is aimed at manufacturers, importers, distributors and service providers. A private company working for the public sector may additionally be bound to BITV requirements through procurement terms — but that then follows from the contract, not from the BFSG.