Digital accessibility refers to the ability of people with disabilities to find and use a website or app without undue difficulty and, in principle, without assistance from others (pursuant to Section 3(1) of the Federal Act on the Accessibility of Information and Communication Technologies (BFSG)).
As of October 22, 2026. For informational purposes only; not legal advice.
What does this mean for your business?
The Act to Strengthen Accessibility (BFSG) has been in effect since June 28, 2025, but it does not apply to every website: Its scope is tied to contracts with consumers and the size of the company. Regardless of the legal requirement, here’s what matters for marketing: An image without alt text is invisible to both screen readers and search engines, and navigation that cannot be operated via keyboard excludes visitors. When requesting a quote, ask for details on which standard and compliance level the website will be tested against. If you’re planning a website relaunch, make accessibility a requirement in the specifications, including the standard and compliance level.
Does the BFSG apply to your website?
According to the text of the law, only if it is intended to conclude contracts with consumers and your company is not a microenterprise. According to Section 1 of the BFSG, the law covers services for consumers, including “services in electronic commerce”: websites and apps through which a consumer initiates a consumer contract at their own request (Section 2, No. 26 BFSG); Micro-enterprises with fewer than 10 employees and an annual turnover or balance sheet total of no more than 2 million euros are exempt from these requirements for services (§ 3(3) BFSG). According to the FAQs of the Federal Agency for Accessibility (as of May 2025), an online store for consumers falls under this category, whereas a sales portal without consumer contracts does not; the FAQs do not address purely informational websites or offerings for business customers—legal counsel should clarify these matters. For guidance on what to do in specific cases, see the article “Website Accessibility: BFSG Requirements for SMEs Explained.”
How is accessibility measured?
By standards, not by impression. If a website complies with the harmonized standard EN 301 549, the Federal Agency presumes that it meets the requirements of the BFSG (Sections 4 and 5 BFSG). Version V3.2.1 of the standard refers to the success criteria of WCAG 2.1; an update to WCAG 2.2 has been announced. The W3C’s WCAG 2.2 has been a W3C Recommendation since December 12, 2024; it is structured around four principles and defines the conformance levels A, AA, and AAA.
From Our Experience
On October 14, 2026, nine customer logos in an older gallery on our own website lacked alt text: invisible to screen readers and search engines alike. For a national association, we redesigned the main navigation to be accessible during the relaunch to TYPO3 v14, with keyboard navigation and screen reader support.
Scope
- WCAG (Web Content Accessibility Guidelines) is the technical standard set by the W3C; the BFSG is the law that references this standard via the EN 301 549 standard.
- Technical SEO overlaps with alt text, heading structure, and clean HTML, but focuses on crawlability rather than usability.
- An SEO audit also checks alt text and headings, but does not replace a compliance check against the standard.
- An SEO relaunch is the process in which accessibility is a separate item in the requirements specification.
Red flag in the proposal
Two examples. First, the blanket statement that every website must be accessible as of June 28, 2025; the law is tied to consumer contracts and company size. Second, the promise that an overlay plugin will make the website “BFSG-compliant” without anyone actually testing the site against the standard. According to the Federal Agency, the presumption of compliance is tied to adherence to harmonized standards; anyone taking a different approach must prove compliance on their own.
Source
- Accessibility Enhancement Act (BFSG), gesetze-im-internet.de, §§ 1, 2, 3, accessed on October 22, 2026
- Federal Agency for Accessibility: Act to Strengthen Accessibility, accessed on October 22, 2026
- Federal Agency for Accessibility: FAQ on Services in Electronic Commerce, accessed on October 22, 2026
- Federal Agency for Accessibility: Norms and Standards, accessed on October 22, 2026
- W3C: Web Content Accessibility Guidelines (WCAG) 2.2, accessed on October 22, 2026
- Own Findings: Alt-text check of our own website, October 14, 2026; Navigation for a federal association (client not named)