BFSG: Does my website have to be accessible?

1. What does digital accessibility mean?

Digital accessibility means that everyone – including people with disabilities, with visual or hearing impairments, with motor or cognitive limitations – can perceive, operate and understand your website.

Three areas are crucial:

• Design & layout – sufficient contrast, readable type, clear structure.
• Programming – semantic HTML, keyboard operability, correct ARIA, screen-reader compatibility.
• Content – plain language, meaningful alt texts, clear link labels, captions for videos.

The international standard is the Web Content Accessibility Guidelines (WCAG) 2.2 at conformance level AA – the foundation that both BFSG and BITV build on.

2. BFSG, BITV, BGG, WCAG 2.2, EN 301 549 – the legal and standards overview

These terms are easily confused. Here is a compact overview:

Short version: if you have to comply with BFSG or BITV, you are audited against EN 301 549, which references WCAG 2.2 AA.

3. Am I affected by the BFSG?

The BFSG applies to the private sector and is mandatory for B2C companies that meet both criteria:

• Size: more than 10 employees or more than €2 million annual turnover.
• Business transactions: users can buy goods on your website (online shop) or initiate / conclude contracts.

Even simple interactions – newsletter sign-ups, contact forms used to initiate contracts, booking flows – can fall within scope.

Pure B2B services are currently outside BFSG. Caveat: tenders from large customers increasingly require accessibility contractually – so the de-facto pressure exists even without legislation.

4. Since when does the BFSG apply?

The effective date was 28 June 2025. Since then, affected products and services must be accessible. There are transitional periods until 28 June 2030 for certain existing contracts and self-service terminals. New websites, new online shops and new digital services must already comply today.

Anyone still waiting is not „on schedule" – they are already non-compliant.

5. Does the entire website have to be accessible?

No. Under the BFSG, only the parts of the website that are part of the affected digital business transaction or contract conclusion must be accessible.

For a typical online shop, that includes:

• Home page, category page, product page
• Shopping cart and the entire checkout
• Legal pages: terms, imprint, privacy
• Contact and service forms

Practical tip: the effort to maintain a clean "accessible vs. non-accessible" separation is often higher than just raising the whole site to WCAG 2.2 AA – with SEO benefits as a side effect.

6. Warning: overlay tools are not a solution

Third-party accessibility overlays ("accessibility widgets") cannot fix deep-rooted structural problems in the code and often create new barriers. As the site operator you remain liable for what you ship. Don't rely on tools that only help superficially and don't protect you from fines. Market-surveillance authorities, associations and individual users can all file complaints.

7. The role of the accessibility statement

Affected companies must publish an accessibility statement on the website. It describes the accessibility status and gives users a feedback channel.

Important for the private sector: unlike public authorities, you should not list remaining barriers in detail. A constructive, solution-oriented phrasing protects you from unnecessary exposure to competitors or authorities.

8. How do you start? Your roadmap to an accessible website

The pragmatic path in three stages:

1. Audit & baseline – automated checks (axe, Lighthouse) plus a manual WCAG 2.2 AA review. Result: a prioritised backlog with a "risk vs. effort" matrix.
2. Quick wins – contrast, alt texts, semantic heading structure, keyboard navigation, form labels. These measures often lift the score by 30–50 % within days.
3. Structural work – review the component library for accessibility, refactor custom widgets, anchor tests in CI/CD, train editorial guidelines.

Drupal projects have a particularly strong lever here: a central design system turns accessibility into a property of the component – instead of a manual per-page check.

9. The clear added value of an accessible website

The cost of adaptation is manageable – the benefits are substantial:

• New audiences: around 20 % of the population struggle with non-accessible sites.
• Brand strength: up to 77 % of consumers pay attention to a company's social commitment.
• Better SEO: semantic HTML, clear structures and alt texts improve ranking signals.
• Risk mitigation: fines of up to €100,000 from market-surveillance authorities are avoided.
• Less support load: clear, accessible sites generate fewer support requests.
• USP: accessibility is still a differentiator in many industries.