Sector guide · Transport & events

BFSG for ticketing and passenger transport

Selling a journey or a seat to a consumer can put you in scope, and how far depends on the kind of transport. For air, bus, rail and waterborne passenger services the BFSG covers the booking flow, the travel information, the ticket, the check-in and the machine in the station. For urban, suburban and regional transport, only the interactive self-service terminals fall under the transport category.

  • Air, bus, rail, ship: web, app, e-ticket, terminals
  • Local transport: self-service terminals only
  • Seat maps are the classic failure

What is covered

The BFSG names elements of passenger transport services (section 1(3) no. 2 BFSG), and the list depends on the mode of transport.

  • Air, bus, rail and waterborne transport: websites and apps that sell tickets to consumers, travel information including real-time and disruption notices, electronic tickets and the wallet or PDF you deliver them in, and check-in
  • Urban, suburban and regional transport: only interactive self-service terminals fall under the transport category. Whether a local operator's online ticket shop counts as an e-commerce service in its own right is not settled — take legal advice
  • Self-service ticket machines and check-in terminals are also products under the BFSG, with requirements of their own
  • Event ticketing is not passenger transport, but selling tickets online to consumers is an e-commerce service and in scope as that

Sector guide · Transport & events

Where ticketing fails

  • Seat maps with no alternative

    An interactive seat map that only responds to pointer input, with no list of available seats and no way to pick one with a keyboard. It is the clearest 2.1.1 failure in the sector.

  • Countdowns on the booking

    “Your seats are held for 07:59.” A hard countdown with no extension fails 2.2.1, and the people most likely to need longer are exactly the ones it locks out.

  • Timetables as data tables without headers

    Departure boards rendered as grids of divs, or as tables with no header cells, so a screen reader reads times with nothing attaching them to a destination.

  • Tickets as untagged images

    The ticket PDF is a picture with a barcode. The seat, the coach and the time exist nowhere as text.

Where to start

  1. Book a ticket with the keyboard

    Search, choose, seat, pay, receive. If you cannot finish it without touching the mouse, neither can a proportion of your customers.

  2. Give the seat map a list

    Keep the map. Add a list of available seats with the same information, operable the same way. That is usually a day of work and closes the worst finding in the sector.

  3. Make the ticket text

    Whatever the visual design, the ticket needs its details as real text — in the PDF, in the email, in the wallet pass.

  4. Assess machines separately

    Terminals are products with their own annex in the law. No web scan touches them, and they need their own record.

Questions operators ask

We are a small events organiser using a third-party ticketing platform. Who is responsible?

Both of you, for different things. The platform is responsible for the service it provides; you are responsible for the service you offer under your own name, including the pages you configure and the theme you chose. In practice, ask your platform for their accessibility statement and test what your customers actually see.

Does the exemption for micro-enterprises help us?

Possibly — the service exemption is fewer than 10 employees and an annual turnover or balance sheet total of at most €2m (one of the two is enough). Note that it exempts you from the obligations, not from the fact that people who cannot use the booking will not book.

Written to be useful, not to be legal advice. It reflects our reading of the BFSG and EN 301 549 as of 12 October 2026; for a binding assessment of your obligations, ask a lawyer.

Further reading

  • Keyboard agent

    Keyboard accessibility testing with real keys: the agent tabs through your pages, finds keyboard traps and invisible focus, and records every step.

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