What Does the BFSG Regulate?
The BFSG defines accessibility requirements for products and services placed on the market or provided after June 28, 2025. In the area of digital services, the law particularly affects websites and mobile applications offering consumer services. The requirements are based on the harmonized European standard EN 301 549, which in turn is based on the Web Content Accessibility Guidelines (WCAG) 2.1 at conformance level AA.
Market surveillance is carried out by state authorities. Violations can result in fines of up to 100,000 euros. Additionally, competitors and consumer protection associations can assert injunctive relief, significantly strengthening enforcement. The BFSG thereby supplements existing GDPR compliance obligations with an additional dimension.
Who Does the BFSG Affect?
The BFSG applies to economic operators offering products and services to consumers. In the area of websites and digital services, those particularly affected include:
- E-commerce: Online shops selling goods or services to end consumers, including the entire customer journey from product page to checkout
- Banking services: Online banking, financial services, and payment services for consumers
- Telecommunications: Websites and apps of telecom providers, including self-service portals and contract management
- E-books and digital media: Platforms for digital publications, e-reader software, and media services
- Passenger transport: Booking portals and information systems for travel and transport
- Messaging services and email: Communication services for consumers
Micro-enterprises with fewer than 10 employees and a maximum annual turnover of 2 million euros are exempt for services. However, the exemption does not apply to products. Additionally, experts recommend that even micro-enterprises implement accessibility, as it expands the user base and provides SEO benefits.
WCAG 2.1 AA: The Technical Standard
The Web Content Accessibility Guidelines (WCAG) 2.1 at conformance level AA form the technical framework for BFSG compliance. They are based on four fundamental principles that together ensure web content is accessible to all people.
Perceivable
Content must be perceivable in different forms. Concretely: all images need meaningful alt texts or are marked as decorative (alt=""). Videos must have captions and ideally audio descriptions. Color contrasts must be at least 4.5:1 for normal text and 3:1 for large text (18pt or 14pt bold and above). Content must not rely solely on color to convey information.
Operable
All functions must be reachable via keyboard. Navigation must be predictable, and users need sufficient time for their actions. Concretely: every interactive element must be reachable via Tab key and have a visible focus indicator. Dropdown menus, modals, and custom widgets must be fully keyboard-operable. There must be no keyboard trap from which the user cannot escape via keyboard.
Understandable
Content and operation must be understandable. Forms need clear labels and helpful error messages. The page language must be declared in the HTML lang attribute. Navigation and page structure must be consistent. Error messages must describe the error and offer a solution. Form fields must have programmatically associated labels, not just visually placed text.
Robust
Content must be reliably interpretable by various user agents, including assistive technologies like screen readers. This requires valid, semantic HTML, correct ARIA attributes (when native HTML elements are insufficient), and a logical document structure with correct heading hierarchy.
The Most Common Accessibility Problems
Missing Keyboard Navigation
Many websites are only operable with a mouse. Dropdown menus responding exclusively to hover, modal dialogs without focus management, and custom widgets without keyboard support exclude users who cannot use a mouse. This affects not only people with motor impairments but also power users who prefer keyboard navigation.
Insufficient Color Contrasts
Light gray text on a white background may look aesthetic but is barely readable for people with visual impairments. According to a study by WebAIM, 83.6% of all homepages fail WCAG contrast requirements (WebAIM Million). Colored buttons with white text also frequently fail the required contrast ratio of 4.5:1 for normal text. Check all text with a contrast checker and correct insufficient values.
Missing or Meaningless Alt Texts
Images without alt texts are invisible to screen reader users. Purely decorative images should have an empty alt="" attribute, while informative images need a description conveying the content rather than describing the file. Alt texts like image1.jpg or photo are unhelpful. Describe what the image shows and why it is relevant in context.
Missing Form Labels
Forms without programmatically associated labels are unusable for screen reader users. Visually placed text next to the input field is insufficient. The <label> element must be linked via the for attribute to the input field's id. Alternatively, the input field can be nested within the <label> element. Correct form labels are also relevant for a compliant cookie consent management, as the cookie banner itself must be accessible.
Missing Heading Hierarchy
Headings must be used in a logical hierarchy. One <h1> per page, followed by <h2>, <h3>, and so on, without skipping levels. Screen reader users frequently navigate via heading structure and depend on correct hierarchy to grasp page content.
Steps Toward BFSG Compliance
1. Conduct an Assessment
Document all pages, forms, interactive elements, and multimedia content on your website. Identify areas with the highest need for action. Typically, navigation, forms, and dynamic content like sliders, accordions, and tabs are the biggest problem areas. Automated accessibility scanners like the one integrated in XICTRAQ provide an initial overview.
2. Prioritize by User Impact
Not all accessibility issues have the same impact on user experience. Start with barriers that most severely restrict access: missing keyboard navigation on main navigation and forms, insufficient contrasts on key pages, and missing form labels in the checkout process. These measures have the greatest effect with comparatively low effort.
3. Technical Implementation
Implement corrections systematically. Start with the semantic HTML foundation: correct heading hierarchy, <nav> for navigation, <main> for primary content, <aside> for sidebars, <footer> for the footer. Add ARIA attributes only where native HTML elements are insufficient. Ensure all interactive elements are keyboard-accessible and have visible focus indicators.
4. Make Content Accessible
Accessibility is not only about code. Texts should be written in simple, understandable language. Paragraphs should be kept short. Links need descriptive text understandable without surrounding context, so not click here or learn more. Tables need headers describing the content of columns and rows.
5. Test and Monitor
Automated tests can check approximately 30-40% of WCAG requirements (Deque Systems). This includes contrasts, alt texts, ARIA attributes, and heading hierarchy. The remaining 60-70% require manual testing, particularly keyboard navigation, semantic correctness, and screen reader compatibility. Plan for both test types.
Automated Accessibility Testing with XICTRAQ
XICTRAQ integrates automated accessibility checks into its compliance module. With each scan, the automatically testable WCAG criteria are verified and changes reported. The system checks, among other things:
- Color contrasts of all text elements against WCAG 4.5:1 / 3:1 thresholds
- Presence and quality of image alt texts
- Correct association of form labels with input fields
- Logical heading hierarchy without skipped levels
- ARIA attributes for correctness and completeness
langattribute in the HTML element- Focus indicators for interactive elements
- Zoom behavior up to 200% without functionality loss
Results are summarized in the dashboard with an accessibility score from 0 to 100. This lets you see at a glance where your website stands and where action is needed. When deterioration occurs after a deployment, you are immediately notified so you can fix accessibility regressions early.
Accessibility and SEO: Double Benefits
Accessible websites are typically built more cleanly from a technical standpoint and therefore better optimized for search engines. The overlaps are significant: semantic HTML helps both screen readers and Google crawlers understand page content. Clear heading hierarchies improve crawlability and user guidance. Descriptive alt texts enable indexing of image content. Correct lang attributes help search engines with language assignment.
Google confirmed in 2024 that accessibility factors like semantic HTML and correct document structure indirectly feed into Core Web Vitals. Investments in accessibility therefore pay off twice: legal GDPR and BFSG compliance and better visibility in search engines. XICTRAQ delivers both perspectives in an integrated dashboard combining compliance status, performance metrics, and accessibility score.
Accessibility as a Business Advantage
Beyond the legal obligation and SEO benefits, accessibility opens up a substantial target audience. In Germany, 7.8 million people have a recognized severe disability (German Federal Statistical Office). Additionally, millions of people with minor impairments benefit from accessible websites: seniors with declining eyesight, people with temporary injuries, or users in challenging situations like bright sunlight on a smartphone display.
Accessible websites also provide a better user experience for all visitors. Clear contrasts, understandable navigation, well-structured content, and usable forms benefit every user. Studies show that accessible e-commerce websites achieve higher conversion rates because the overall user experience is better (Nucleus Research). The investment in a comprehensive monitoring tool like XICTRAQ pays for itself quickly.
Transition Periods and Enforcement
BFSG requirements have applied since June 28, 2025, for new products and services. For existing services, a transition period allows existing contracts to continue until expiry. However, new versions or substantial revisions of existing websites must meet the requirements.
Market surveillance is carried out by state authorities, conducting random checks and investigating complaints. The fine framework extends up to 100,000 euros. Additionally, competitors and consumer protection associations can file injunctions, significantly strengthening practical enforcement. Companies should therefore not postpone implementation but address it proactively.
Accessibility Statement
Website operators falling under the BFSG should publish an accessibility statement. This statement documents the current state of accessibility, known limitations, planned measures, and a contact channel for feedback. For public bodies, such a statement is already mandatory under BITV 2.0. For private-sector companies, it is not explicitly required under the BFSG but is recommended as best practice and demonstrates commitment to inclusion.
Checklist: Achieving BFSG Compliance
- All images have meaningful alt texts or are marked as decorative
- Color contrasts meet WCAG 4.5:1 (text) and 3:1 (large text)
- All interactive elements are keyboard-accessible and operable
- Forms have programmatically associated labels
- Headings follow a logical hierarchy (h1 > h2 > h3)
- The
langattribute is set on the HTML element - Focus indicators are visible on all interactive elements
- The website is fully usable at 200% zoom
- Videos have captions
- ARIA attributes are used correctly and sparingly
- Navigation is consistent and predictable
- Form error messages are descriptive and helpful
Frequently Asked Questions About the BFSG
Does my website need to be accessible?
What fines apply for BFSG violations?
Is an automated test sufficient for BFSG compliance?
What is the difference between WCAG A, AA, and AAA?
How does XICTRAQ help with accessibility?
Does accessibility improve my Google ranking?
This article is based on data from: (Deque Systems), Core Web Vitals (Google), (Nucleus Research), (WHO), (WebAIM).