Guide · Annex 3 BFSG
The accessibility statement the BFSG asks for
Since 28 June 2025, a business offering a service in scope of the BFSG has to publish how that service meets the accessibility requirements. The law speaks of “information” under Annex 3; everybody else calls it the accessibility statement. What goes in it, where it goes — and why the part that matters cannot be written from a template.
What it has to contain
Annex 3 BFSG lists four things. They go into your terms and conditions, or are made available “in another clearly perceivable way” — in an accessible format either way.
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a)
A general description of the service
In an accessible format: what the service is and who it is for, in words a customer understands.
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b)
What it takes to understand how the service works
The descriptions and explanations somebody needs to use it — how ordering, paying or signing in works, for example.
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c)
How the service meets the accessibility requirements
The requirements are set by the regulation under § 3 (2) BFSG (the BFSGV) and measured in practice against EN 301 549 — for a website, WCAG at level AA. This is the part that needs evidence, and the part no template can write.
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d)
The competent market surveillance authority
In Germany, the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF).
Where it goes, and for how long
The law leaves the form open and is strict about the rest.
- In your terms and conditions or somewhere else clearly perceivable — in practice, a page of its own, linked from the footer of every page
- In an accessible format: an HTML page, not a scanned PDF
- Available for as long as you offer the service (§ 14 (2) BFSG)
- Kept true: § 14 (3) BFSG expects the service to go on meeting the requirements as it changes — a statement from launch year describes a site that no longer exists
A structure you can use
There is no official template for businesses. This structure covers Annex 3 and takes the rest from the EU model statement public bodies use — the shape readers and authorities already know.
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Scope
Which website, app or service the statement covers, and when it was prepared.
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Description of the service
What the service is and how it is used — Annex 3 (a) and (b).
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Compliance status
The standard it was measured against (EN 301 549, WCAG 2.2 AA) and how far the service meets it: fully, partially or not. “Partially”, with a list, is an honest answer; “fully” means every criterion was tested — Annex 3 (c).
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Non-accessible content
What does not meet the requirements yet, why, what the alternative is, and by when it will be fixed.
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How this statement was prepared
Automated testing, manual testing, by whom and when. It is the part an authority reads first.
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Feedback and contact
How to report a barrier, and who answers.
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Market surveillance authority
Name and contact details of the competent authority — Annex 3 (d).
Why a generator cannot write it for you
A template produces a document. What makes the document true is the test behind it — and the sentence a generator is happiest to write, “this website is fully accessible”, is the one an authority, a competitor or an association is most likely to check.
- Annex 3 (c) describes your site as it is. Nobody can fill it in without testing it
- Of the 49 WCAG 2.2 AA criteria, a tool can decide 5 on its own, 19 in part and 25 not at all — a statement has to say which of them were tested, and how
- A criterion nobody tested is untested, not passed — so a statement built on evidence says “partially compliant” until the evidence supports more
- Every claim should lead back to a test: when it ran, what it covered, who decided
In Reviseberg
Drafted from the evidence, published as a version
The statement in Reviseberg is not a form to fill in. It is built from what was actually tested on your site.
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Measure
A crawl runs every automated rule on your pages, and the keyboard agent walks the journeys you name.
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Record what a machine cannot decide
Manual results are recorded with the method and the person who decided, and expire after twelve months — after which the criterion is untested again.
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Draft
The compliance status, the non-accessible content and how the statement was prepared come from those results. A criterion nobody tested never counts as a pass, so the draft cannot claim more than the evidence shows.
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Complete
You add the contact for feedback and the enforcement body — for the BFSG, the market surveillance authority. The general description of your service, Annex 3 (a) and (b), is yours to write: it describes your business, not your markup.
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Publish
Publishing writes a version at a public address and archives the one it replaces. A statement is never edited in place — a legal document that quietly changes its wording is not a record.
Public bodies publish a different document
Federal public bodies publish an „Erklärung zur Barrierefreiheit“ under § 12b BGG and the BITV 2.0, the Länder and municipalities under their own laws. The structure is similar and the obligations are not — a template written for an authority is not the right document for an online shop, and the reverse.
Questions about the statement
Do I need an accessibility statement?
If you offer consumers a service in scope of the BFSG — an online shop, banking, e-books, ticketing, telecoms — you have to provide the information in Annex 3. Micro-enterprises that provide services (fewer than 10 employees and no more than €2 million annual turnover or balance sheet total) are exempt from the requirements. Our BFSG guide covers who is in scope.
Is it an accessibility statement or “information on accessibility”?
The BFSG speaks of the information in Annex 3. “Accessibility statement” — in German Barrierefreiheitserklärung — is the name everybody uses for it; „Erklärung zur Barrierefreiheit“ is the document public bodies publish under § 12b BGG. Both are a public account of how accessible an offering is.
Can I use a template or a generator?
For the structure, yes — you are welcome to use the one above. For the content, only with a test behind it: Annex 3 (c) has to describe your site as it is, and a generated “fully compliant” with nothing behind it is the riskiest sentence on the page.
Where should the statement go?
The law allows your terms and conditions or “another clearly perceivable way”. In practice: a page of its own, linked from the footer of every page and from your terms, reachable without signing in.
How often does it have to be updated?
The law sets no interval. It does require the service to go on meeting the requirements as it changes (§ 14 (3) BFSG), so update the statement whenever the site changes materially. We recommend at least once a year — which is how long a manual test result stays valid in Reviseberg.
Does Reviseberg write the statement for me?
It drafts the parts a test can support — the compliance status, the non-accessible content and how the statement was prepared — from your own results, and publishes them as a version. The description of your service and the legal sign-off stay with you.
Written to be useful, not to be legal advice. It reflects our reading of the BFSG and EN 301 549 as of 2026-09-13; for a binding assessment of your obligations, ask a lawyer.
Start with the evidence
A statement is only as good as the test behind it. Send a URL: the first findings appear in about 30 seconds, and the full report on up to 100 pages arrives by email.