Accessibility Under the EAA and Germany's BFSG: Who Must Comply

Since 28 June 2025, many digital products and services sold to consumers in the European Union must be accessible. The legal basis is the European Accessibility Act (EAA, Directive (EU) 2019/882), which each member state has transposed into national law. In Germany that law is the Barrierefreiheitsstärkungsgesetz, or BFSG. For online shops, booking platforms, banking services and many apps, accessibility is no longer optional. This article explains who is affected, which standards apply and how to approach it in practice, with a focus on Germany.

Note: This article is an overview and does not replace legal advice for your specific case.

One directive, national laws

The EAA sets common requirements, but enforcement, penalties and some details are defined nationally. If you serve consumers in several EU countries, the rules of each of those countries apply. Requirements are broadly aligned, so a solid implementation of the technical standards covers most of the ground. Companies outside the EU are covered as soon as they offer in-scope products or services to EU consumers.

Who is affected

The EAA covers specific products and services offered to consumers. For websites and apps, these services matter most:

• E-commerce services: online shops and any website or app through which consumers can conclude a contract, such as a booking, subscription or order.
• Consumer banking services: online banking, payment services, credit.
• Elements of passenger transport services: websites, apps, e-tickets and travel information.
• Electronic communications services, e-books and access to audiovisual media services.

Covered products include computers, smartphones, e-readers and self-service terminals such as ATMs and ticket machines.

Exemptions

• Micro-enterprises providing services are exempt. A micro-enterprise has fewer than ten employees and an annual turnover or balance sheet total of no more than two million euros. The exemption does not apply to manufacturers or distributors of products.
• Purely B2B offers are generally out of scope, since the EAA protects consumers. Check carefully, though: a shop that also sells to private customers is covered.
• Disproportionate burden: a business can claim that compliance would fundamentally alter its service or impose a disproportionate burden. This has to be assessed and documented. It is not a blanket opt-out.
• Transition periods apply, among others, to service contracts concluded before 28 June 2025 and to self-service terminals already in use.

In Germany, purely informational websites without contract conclusion, such as a company presentation with a contact form, are widely considered to be outside the e-commerce services category. Public sector bodies are covered by separate rules based on the Web Accessibility Directive.

Which standards apply

The EAA describes requirements in general terms. Standards make them concrete:

Our recommendation: implement WCAG 2.2 AA directly. The extra effort over 2.1 is small, and you already meet the baseline of the new version of the standard.

What WCAG 2.2 adds (selection, levels A and AA)

• Focus not obscured: an element with keyboard focus must not be completely hidden by sticky headers, cookie banners or chat widgets.
• Minimum target size: 24 × 24 CSS pixels, or enough spacing from neighbouring targets.
• Alternatives to dragging: anything that works by drag and drop must also work with simple clicks.
• Consistent help: contact or help options appear in the same place on every page.
• No redundant entry: information already entered is not requested again in the same process.
• Accessible authentication: no puzzle or transcribing a code as the only option. Password managers and paste must work.

Obligations beyond code

Besides accessible design, the EAA requires you to publish information on how your service meets the requirements. This information must itself be accessible, for example in your terms or on a dedicated page usually called an accessibility statement. It describes the service, the state of compliance and a contact route.

In Germany, supervision lies with a joint market surveillance authority of the federal states (MLBF) based in Magdeburg. It can raise deficiencies, set deadlines and, as a last resort, require a service to be discontinued. Violations can be fined up to €100,000. Consumer and association claims, as well as competitor cease-and-desist letters, are also possible.

Practical checklist

These points cover many of the most common problems. They do not replace a full WCAG audit.

Structure

• Every page has exactly one H1 and a logical heading hierarchy.
• The lang attribute is set, including for passages in other languages on multilingual pages.
• Landmarks (header, nav, main, footer) are present, along with a "skip to content" link.

Keyboard and focus

• Every function can be reached and operated by keyboard.
• Focus is always clearly visible and never obscured.
• Modal dialogs trap focus and return it when closed.

Content

• Meaningful images have alternative text; decorative images have an empty alt.
• Text contrast of at least 4.5:1, 3:1 for large text. Controls and graphics at least 3:1.
• Information is not conveyed by colour alone.
• Videos have captions; audio has a text alternative.

Forms

• Every field has a visible, programmatically associated label.
• Error messages name the problem and how to fix it.
• autocomplete attributes make personal data easier to enter.

Display

• The page works at 200% zoom and at 320 CSS pixels wide without horizontal scrolling.
• Animations respect prefers-reduced-motion.

Shop and checkout

• Product variants, cart, shipping options and payment are fully usable with keyboard and screen reader.
• Time limits can be extended or turned off.
• Embedded payment providers and third-party widgets are tested too. They are part of your service.

Testing: automated and manual

Automated tools such as axe or Lighthouse catch some problems, such as missing alt text or low contrast. Many criteria can only be judged by people, though: is the alt text meaningful? Is the focus order logical? Is the error message understandable?

A realistic approach:

1. Automated scans of every page type in the build pipeline
2. Manual checks with keyboard and screen reader (NVDA, VoiceOver) for each page type
3. Testing key journeys (sign-up, purchase, contact) with people who use assistive technology
4. Regular repetition, because every new feature can introduce new issues

Accessibility starts at the planning stage. Many requirements can be set in the wireframe, where they cost almost nothing.

The first step

First check whether, and with which offers, you fall under the EAA in the markets you serve. Then test your most important journey, usually purchase or booking, with a keyboard and a screen reader. What you find shows how much work lies ahead. We support audits, implementation and accessibility statements as part of our accessibility services.