What the law actually is
The European Accessibility Act (Directive (EU) 2019/882) is EU law requiring certain products and services to be accessible. Germany implemented it as the Barrierefreiheitsstärkungsgesetz (BFSG), in force since 28 June 2025, with the details in the accompanying regulation (BFSGV).
This is separate from the older BITV 2.0, which applies to public-sector bodies. If you are a public authority, BITV 2.0 still applies to you — and the technical bar is nearly identical.
Who has to comply
BFSG covers business-to-consumer digital products and services, including:
- Online shops and any e-commerce service aimed at consumers
- Banking, payment and insurance-adjacent consumer services
- E-books and e-book software
- Passenger transport: ticketing, check-in, real-time travel information
- Telecommunication services and interpersonal communication
- Access to audiovisual media services
- Hardware: self-service terminals, ATMs, ticket machines, e-readers, smartphones
Exception: micro-enterprises — fewer than 10 employees and either annual turnover or balance sheet total of at most €2 million — are exempt for services (not for products). Pure B2B offerings are outside the scope. That exemption is narrower than most people assume: if you sell to consumers, check it properly.
What “accessible” means technically
For web content, EN 301 549 V3.2.1 references WCAG 2.1 levels A and AA. WCAG 2.2 adds further criteria and is a useful engineering target; it is not interchangeable with that version of the standard. Check the requirements and applicable standards for your service. See the European Commission’s explanation of the standard. As a practical starting point:
- Everything operable by keyboard, with visible focus
- Meaningful text alternatives, correct headings, correct names and roles
- Contrast of at least 4.5:1 for body text
- Content readable and operable at 400% zoom and 320 px width
- Errors identified, described and announced to assistive technology
- No time limits or motion that cannot be controlled
What you must publish
Beyond the site itself, you owe your users documentation:
- An accessibility statement describing how the service meets the requirements
- Information in an accessible format, findable without a login
- A feedback channel so people can report barriers — and a process behind it
Reviseberg drafts the statement from your actual findings and the manual results you record, versions it, publishes it at a public address — and shows beside it what a statement written today could still claim.
What happens if you ignore it
Market surveillance authorities (in Germany the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen, MLBF) act on complaints from consumers and associations. The escalation typically runs: request for information → order to remedy → fine → prohibition of the service on the market. Fines can reach €100,000, but the practical risks arrive earlier: competitor warnings, association claims, procurement exclusion, and the reputational cost of a public complaint.
A realistic 90-day plan
- Week 1 — Measure. Full crawl plus the keyboard agent on your top journey. You need a defensible baseline, not a feeling.
- Weeks 2–3 — Triage. Group findings by template. Fixing a component fixes hundreds of pages.
- Weeks 4–8 — Fix the blockers. Keyboard traps, unlabelled form fields, missing focus, checkout dead ends. These are what actually stop people buying.
- Weeks 9–10 — Documents. Invoices, terms, product sheets: tag the PDFs or move them to HTML.
- Weeks 11–12 — Publish and institutionalise. Accessibility statement, feedback channel, and a gate in your release process so it does not regress.
Frequently asked
Does an overlay widget make me compliant? No. A widget does not change the underlying code, and the ones sold as making a site compliant are explicitly criticised by accessibility experts and disability organisations. Several legal complaints in the US and EU involve sites that had one installed, and in 2025 the FTC ordered accessiBe to stop claiming its widget could make any website WCAG-conformant without evidence. A toolbar that offers visitors their own display preferences can be useful; one that claims to fix or certify a site is the problem. Reviseberg offers such a toolbar as an option, and says plainly that it changes nothing about whether your site meets the law.
Is a one-off audit enough? It is a good baseline. It stops being accurate on your next release, which is why continuous testing exists.
We are B2B — are we safe? Mostly, for the BFSG. But procurement increasingly requires accessibility, and public-sector customers must ask for it.