BFSG: who is affected.

Consumer services provided after 28.06.2025 (§1(3) BFSG):

• E-commerce services. In practice: websites and apps through which a contract with consumers is concluded. For online retail that is the whole purchase journey, including goods that are not themselves covered by the BFSG.
• Consumer banking services, including online banking.
• Telecommunications services.
• E-books and dedicated software.
• For passenger transport by air, bus, rail and water: websites, apps, e-tickets, travel information and interactive self-service terminals.

For urban, suburban and regional transport, the BFSG covers only interactive self-service terminals, not website or app. For insurers, energy suppliers or housing companies, the BFSG applies through e-commerce, i.e. wherever a consumer contract is prepared or concluded online. Pure B2B offerings are not covered.

• Consumer computers, notebooks, tablets and smartphones, including the operating system.
• Self-service terminals: payment terminals, ATMs, ticket and check-in machines, interactive information terminals.
• Consumer devices for telecommunications and audiovisual media services, for example smart TVs.
• E-book readers.

Micro-enterprises providing services are exempt from the accessibility requirements (§3(3) BFSG). Micro-enterprise means fewer than 10 employees and no more than €2 million annual turnover or balance sheet total. Manufacturers of products get no such exemption.

There is also the disproportionate burden exemption. It is not a free pass: it must be justified case by case and documented.

For websites and apps, §1(4) BFSG excludes certain content, including:

• Pre-recorded time-based media published before 28.06.2025.
• Office file formats published before 28.06.2025.
• Third-party content you neither fund, develop nor control.
• Archived content no longer updated after 28.06.2025.

Everything you newly publish or revise after the cut-off date is covered.

• Products a service provider lawfully used before 28.06.2025 may continue to be used for comparable services until 27.06.2030.
• Service contracts concluded before 28.06.2025 may run unchanged until they end, at the latest 27.06.2030.
• Self-service terminals in use before 28.06.2025 may run until the end of their economic life, at most 15 years after commissioning.

Websites and apps through which new contracts are concluded today have no transition period.

The requirements are set out in the BFSG ordinance (BFSGV). For websites and apps, EN 301 549 V3.2.1 is the reference standard in practice, in substance WCAG 2.1 level AA. A presumption of conformity under the BFSG only arises once a standard is cited in the EU Official Journal under the European Accessibility Act. That has not happened yet. Version V4.1.1 with WCAG 2.2 has been published since 02.09.2026 but is not cited yet.

Automated tests cover only part of the WCAG criteria, roughly a third. The rest needs manual review. Overlay widgets do not make a website accessible. In 2025 the US Federal Trade Commission obliged a vendor that promised this to pay USD 1 million.

The competent authority is the joint market surveillance office of the German states for accessibility (MLBF) in Magdeburg. Fines go up to €100,000. By summer 2026 it had received around 700 complaints; no fines have been publicly documented so far. Pressure currently comes mostly from tenders, corporate customers, consumer complaints and the accessibility statement, whose absence anyone can see from outside.