BFSG 2025: site not accessible?
Mandatory since June 2025 — up to €100,000 fines. How the audit-to-roadmap process looks for mid-market sites.
Background
What the BFSG mandates — and for whom
The German Accessibility Reinforcement Act (BFSG) transposes the European Accessibility Directive (EAA) into German law. Mandatory since 28 June 2025 for all digital products serving B2C end customers — that is, the majority of all online shops, booking platforms, customer portals and app providers.
Who is affected: any business with more than 10 employees AND annual revenue above €2 million that offers digital products to consumers. Pure B2B platforms are exempt, but as soon as a consumer can use the service (e.g. login, booking, purchase), you fall under it.
What's checked: the standard is WCAG 2.1 Level AA. Concretely: keyboard operability, screen-reader compatibility, color contrasts, alt texts, form labels, error identification, consistency. The market surveillance authorities (in Germany: the Federal Agency for Accessibility) check on a case basis — on complaints or spot checks.
Sanctions: fines up to €100,000 per violation. Often more serious than the fine is the order to withdraw from the market — your platform may no longer be offered until it's remediated.
Common questions
What managing directors ask most often
How do I know if I'm affected?
Three criteria together: more than 10 employees, over €2 million annual revenue, and a B2C service on the site (shop, booking, customer login, app). There are exemptions for pure B2B offers, but if a consumer can use the site at all, the interpretation tends to be strict.
Do I have to rebuild the site from scratch?
Rarely. Most sites need structured retrofitting, not a complete relaunch: contrast corrections, alt texts, form labels, tab-order cleanup, screen-reader markup. Bigger interventions arise with self-built custom components without ARIA logic, or with sites that use pure JavaScript rendering without SSR.
Is an automated audit (axe, Lighthouse) enough?
No. Automated tools catch 30–40% of WCAG violations. The rest needs manual testing — screen reader, keyboard navigation, cognitive-load assessment. We combine automated scans with manual review on critical flows (login, checkout, booking).
How quickly does this need to be implemented?
The deadline was 28 June 2025. In practice, tolerance is currently granted with a demonstrable roadmap — if you can show a documented plan, an ongoing audit process and interim milestones, the authorities are still lenient. Whoever does nothing risks serious sanctions from Q4 2026.
Sound familiar?
Typical situation
If even just one of these applies to you, you should clarify your BFSG obligation now.
- ✓You're B2C or have B2C components (shop, booking, login, app).
- ✓You're vaguely aware of the BFSG, but no one has concretely checked what needs to be done for you.
- ✓Your site was never built or tested to WCAG standards.
- ✓You fear a relaunch may be needed — but want clarity on whether that's really the case.
- ✓A first citizen complaint came in, or you expect one.
My approach
5 phases, in 4–8 weeks
Phase 2 (audit report) is the success guarantor — without a clean finding you don't know where to invest. With a good report you have arguments toward authorities and for the marketing budget.
PHASE 01
Scope clarification & prioritization
Which pages/flows are relevant? What are the critical paths (checkout, booking)? What can follow later? Pragmatic prioritization by business risk.
PHASE 02
WCAG 2.1 AA audit (auto + manual)
Structured finding: automated scans (axe, Lighthouse, Wave) plus manual testing of critical flows with screen reader and keyboard. Output: a prioritized findings report.
PHASE 03
Implementation roadmap
Findings sorted by effort and risk, planned in sprints. What must be fixed this week, what's okay in 4 weeks, what can follow structurally.
PHASE 04
Implementation (guided)
With your development team or ours. Incremental adjustments, pull-request reviews to the accessibility standard.
PHASE 05
Re-audit & documentation
A second audit run after implementation, an accessibility statement (a BFSG requirement) prepared, an ongoing monitoring recommendation. Plus: training for your team so new features stay accessible.
Tools & stack
What's used
Auto scanner
axe DevTools + Lighthouse
Catches 30–40% automatically — the basis for manual deep-diving.
Screen reader
NVDA + VoiceOver
Manual testing of critical flows — no tool replaces this.
CI integration
axe-core in the build pipeline
So new features don't create regressions.
Monitoring
Weekly site crawl
Auto alert on drift after deploy.
Timeline
Express track for an acute complaint: 2 weeks for critical flows.
My offer
Intro call — free, 45 minutes
Clarify the BFSG obligation, roughly assess the site, sketch a possible roadmap. If it fits, an audit offer with a clear fixed price follows. If not, you still have clarity.
Included
- ✓Are you subject to the BFSG? Which parts of your site are affected?
- ✓Roughly how does your site stand (a visual sneak check)?
- ✓Which quick wins can you implement yourself this week?
- ✓What does a realistic audit effort look like for you?
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