European Accessibility Act (EAA) in Germany – All the Key Details

Trying to understand the European Accessibility Act (EAA) in Germany can be confusing. With each country implementing its own version, the rules aren’t always clear. But if your business provides digital services or products in Germany, you need to be prepared.

In this post, we break down everything you need to know about the EAA in Germany, including who needs to comply, key exemptions, enforcement, deadlines, and penalties for non-compliance. By the end, you’ll have complete clarity.

How Is the EAA Implemented in Germany?

Germany transposed the European Accessibility Act (EAA) into national law through the BFSG (Barrierefreiheitsstärkungsgesetz) and its accompanying regulation, the BFSGV (Barrierefreiheitsstärkungsverordnung).

If you’re not a German speaker, don’t be intimidated by the long, tongue-twisting words. BFSG means Accessibility Strengthening Act, and BFSGV means Accessibility Strengthening Ordinance. Here’s a quick breakdown of what each one does:

• BFSG establishes the legal framework, defining obligations, affected products and services, and penalties.
• BFSGV provides technical specifications and compliance details based on EU standards like EN 301 549.

Put simply, BFSG lays out the legal requirements, while BFSGV details how to meet them.

Who Needs to Comply with the EAA in Germany?

The BFSG applies to private-sector companies that manufacture, distribute, or provide consumer-facing products and services in Germany.

Key areas covered include:

• Websites and mobile applications: All consumer-facing websites and apps, including e-commerce platforms, government portals, banking apps, and media streaming services, must meet accessibility standards.
• Digital services: This includes online marketplaces, financial services, telecommunications platforms, and transport booking systems.
• Physical products: Consumer electronics, ATMs, ticketing machines, and self-service terminals must be designed for accessibility.
• Electronic communications and media services: Television, online video platforms, and telecommunication services must include accessibility features like subtitles, audio descriptions, and screen reader compatibility.

Who Is Exempt from the EAA in Germany?

While the BFSG applies broadly, some exemptions exist:

• Micro-enterprises: Companies with fewer than 10 employees and under €2M annual turnover are exempt from service-related accessibility but must comply if manufacturing covered products.
• Disproportionate burden clause: Businesses can seek exemption if compliance creates an undue economic or technical burden, but they must document justification.
• Fundamental change exception: If accessibility changes alter a product’s intended purpose, businesses may be exempt with proper documentation.
• Existing non-updated content: Digital content published before 28 June 2025 (e.g., old PDFs, archived web pages) is exempt unless updated.
• B2B (Business-to-Business) products: Products and services used exclusively for internal business purposes (not consumer-facing) are not covered.

What Are the Compliance Deadlines?

The BFSG follows the standard EAA compliance timeline:

• 28 June 2025: All new or significantly updated products and services must comply with accessibility requirements.
• 28 June 2030: Businesses must phase out or update non-compliant products and services introduced before 2025.
• 28 June 2045: Self-service terminals (ATMs, ticket kiosks, etc.) installed before 2025 can remain in use for up to 20 years before requiring replacement.

Who Enforces the EAA in Germany?

Germany has designated multiple authorities to oversee BFSG compliance:

• Market surveillance authorities: Federal and state agencies conducting inspections and issuing fines.
• State media authorities (Landesmedienanstalten): Responsible for monitoring digital and audiovisual content.
• Sector-specific regulators: Agencies like the Federal Network Agency (Bundesnetzagentur) oversee telecommunications and financial institutions.

Consumers and disability advocacy organisations can file complaints, prompting investigations by these authorities. If a company fails to meet accessibility requirements, regulators can order corrective actions and impose fines.

What Are the Penalties for Non-Compliance?

Germany imposes strict penalties for failing to meet accessibility requirements:

• Up to €100,000 for major violations (e.g., failing core accessibility requirements).
• Up to €10,000 for minor offenses (e.g., incorrect accessibility documentation).
• Product or service bans: Regulators can suspend or withdraw non-compliant products from the market.
• Legal action: Consumer protection groups or competitors can file lawsuits under Germany’s Unfair Competition Act (UWG).

How to Ensure EAA Compliance in Germany

To ensure EAA compliance in Germany, businesses must adhere to the Barrierefreiheitsstärkungsgesetz (BFSG), which enforces the European Accessibility Act. Compliance is primarily based on EN 301 549, but additional national regulations may apply.

Follow these key steps to meet BFSG requirements:

Step 1: Identify Affected Products and Services

Determine which of your digital services and consumer-facing products must comply with BFSG. These include websites, mobile apps, self-service terminals, e-commerce platforms, e-books, banking services, and consumer electronics.

Step 2: Conduct an Accessibility Audit

Evaluate your digital platforms and physical products against EN 301 549 (or BFSGV) and WCAG 2.2 Level AA to identify compliance gaps. Use WebYes to test your website against WCAG guidelines, and seek expert guidance for other digital and physical products.

Step 3: Develop a Compliance Roadmap

Put together a clear plan to tackle accessibility issues from the audit, focusing on the biggest barriers and keeping the compliance deadline in mind. Make sure everyone knows their role so things get done smoothly.

Step 4: Train Your Teams on Accessibility

Make sure your developers, designers, and product managers get WCAG and the POUR principles. Keep them sharp with ongoing training on BFSG rules, usability best practices, and assistive tech so accessibility stays a priority.

Step 5: Publish an Accessibility Statement

Once you’ve removed barriers and made your website or app usable for everyone, it’s time to publish an Accessibility Statement. This should outline your compliance status and provide users with a clear way to report any remaining accessibility issues.

Step 6: Implement Continuous Monitoring

Accessibility isn’t a one-time task – it’s an ongoing commitment. Continuously test and update your websites with WebYes for automated monitoring, and run regular manual reviews for other digital and physical products to stay compliant and ensure accessibility for all users.

How Can WebYes Help You Meet EAA Requirements in Germany?

WebYes can help you meet EAA compliance in Germany by ensuring your website meets accessibility standards. No need to spend hours decoding WCAG guidelines – we handle the heavy lifting. Our tool quickly identifies accessibility issues and guides you through fixing them.

With WebYes, you get:

• Instant accessibility audits: Just enter your website URL, and WebYes will scan for WCAG 2.2 compliance issues.
• Actionable fixes: WebYes gives clear suggestions so you know exactly how to fix the accessibility issues.
• Continuous monitoring: Keep your site accessible over time with ongoing scans that catch new issues before they become problems.

Kickstart your website compliance journey today! Run a free WebYes audit and get a clear, actionable report on your site’s accessibility – so you can stay EAA-compliant and make your site accessible to everyone, in Germany and across the EU.