The BFSG (Barrierefreiheitsstärkungsgesetz)
Since 28 June 2025, accessibility requirements have applied in Germany to certain products and services offered to consumers. This page gives an overview: what the law covers, who it may affect and where PDFs come in.
General overview, not legal advice. This page summarises the basics in simplified form. It is a draft and is currently under expert review. Whether and how the BFSG applies to your offering depends on your specific case.
What the BFSG covers
The BFSG transposes Directive (EU) 2019/882, known as the European Accessibility Act, into German law. Its aim is that people with disabilities can use certain everyday products and services without outside help wherever possible, from online shops to ticket machines.
The detailed requirements are set out in a regulation under the act, the BFSGV. Unlike the rules for public bodies, the BFSG addresses economic operators: manufacturers, importers and distributors of products, and service providers.
At a glance
- Full name
- Gesetz zur Umsetzung der Richtlinie (EU) 2019/882 über die Barrierefreiheitsanforderungen für Produkte und Dienstleistungen
- European basis
- Directive (EU) 2019/882 (European Accessibility Act)
- Applies since
- 28 June 2025, with transitional rules
- Details
- Regulation under the BFSG (BFSGV)
- Supervision
- Market surveillance authorities of the German states
Who the BFSG may affect
The law does not apply to all businesses, only to certain products and services offered to consumers. Whether an offering is covered depends on the type of service and its audience, and should be checked case by case.
-
Products (selection)
- Computers, notebooks, tablets and their operating systems for consumers
- Self-service terminals such as cash machines, ticket machines and check-in kiosks
- Smartphones and other telecommunications terminal equipment
- Devices used to access audiovisual media services
- E-book readers
-
Services (selection)
- E-commerce services, for example online shops and booking portals
- Consumer banking services
- E-books and dedicated software
- Electronic communications services
- Certain elements of passenger transport services, such as websites, apps, electronic tickets and travel information
Exemption for micro-enterprises
Micro-enterprises that provide services are exempt from the requirements. This generally means businesses with fewer than ten employees and an annual turnover or balance sheet total of no more than €2 million. The exemption does not apply to products.
What the law requires
The obligations depend on whether you make or sell a product or provide a service. In simple terms, there are three areas:
- Accessibility requirements: products and services should be perceivable, operable, understandable and robust. The BFSGV describes what this means in detail, for example for websites, apps and the information provided.
- Information on accessibility: service providers explain in plain terms how their service meets the requirements, for example in their terms and conditions or in another clearly perceivable way.
- Product-related duties: manufacturers, importers and distributors each have their own duties, for example conformity assessment, CE marking and accessible instructions for use.
Exceptions are possible within narrow limits, for example where a requirement would fundamentally alter the service or impose a disproportionate burden. This usually has to be justified and documented.
Technical orientation
In practice, EN 301 549 is often used for technical implementation. Harmonised standards specifically for the European Accessibility Act are being developed at European level (as of October 2026).
When the BFSG applies
The BFSG has applied since 28 June 2025. It mainly concerns products placed on the market and services provided to consumers from that date. For existing offerings the law provides transitional rules, for example:
- Products that a provider lawfully used for its services before 28 June 2025 may generally continue to be used for similar services until 27 June 2030.
- Service contracts concluded before 28 June 2025 may continue until they expire, but no later than 27 June 2030.
- Self-service terminals lawfully in use before 28 June 2025 may in principle be used until the end of their economically useful life, but for no more than 15 years.
The transitional rules are narrow. Whether they apply to a specific offering should be checked case by case.
Supervision and possible consequences
Compliance is monitored by the market surveillance authorities of the German states. They can review offerings, require corrections and set deadlines for them. If shortcomings are not remedied, orders to stop making a product available or to discontinue a service are possible as a last resort.
The law provides for fines for certain infringements; the amount depends on the type of infringement. Consumers and recognised associations can contact the authority and ask it to act.
In context
How strictly and how often the authorities will check in practice cannot yet be reliably predicted. It makes sense to review your own offerings early and to document open points in a traceable way.
Where PDFs come in
The BFSG does not treat PDFs as a category of their own. They become relevant when they form part of a covered service, that is, when they contain information consumers need in order to use the service. Possible examples:
-
Contracts and contract documents
Contract documents, terms and pre-contractual information provided as PDFs, for example in e-commerce or banking.
-
Account statements and notices
Account statements, invoices and other notices provided as part of consumer banking services.
-
Product and price information
Data sheets, price lists or instructions offered for download in an online shop.
-
Tickets and travel information
Electronic tickets and travel information in passenger transport services.
Not every PDF is covered
For website and app content there are exemptions, for example for office file formats such as PDFs published before 28 June 2025, and for archives that are not edited after that date. If such documents are updated or republished, the exemption may no longer apply.
Frequently asked questions
Does the BFSG also apply to business-to-business offerings?
Usually not. The law targets products and services for consumers. If an offering is aimed at both businesses and consumers, check case by case which parts are covered.
Do we have to make older PDFs accessible?
That depends on the case. There is an exemption for office file formats published before 28 June 2025. If documents continue to be used as part of a covered service, or are updated, it usually makes sense to provide them in accessible form.
Is a PDF/UA document enough?
A PDF/UA document is a good technical basis. Whether the requirements are met also depends on the content, such as accurate alternative text and a sensible reading order, and on how it works together with the website or app. More on the PDF/UA page.
Can EqualDoc tell us whether the BFSG applies to us?
No. EqualDoc remediates PDFs for accessibility and checks them against the machine-checkable requirements of PDF/UA and EN 301 549. Whether and how the BFSG applies to your offering is a legal question. EqualDoc issues no certificates and provides no legal advice.
Prepare PDFs for your services
The free PDF check shows which barriers a document contains. EqualDoc remediates PDFs automatically and provides a report that also lists the points that need human review.