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EU Accessibility Act in Germany: What Business Can Expect from BFSG?

Written by Kateryna Klynovska on . Posted in EEA.

In our previous article, we explored the main pillars and risks of non-compliance with the European Accessibility Act (Directive 2019/882). Now, let’s turn to Germany — where the Accessibility Act becomes national law under the Barrierefreiheitsstärkungsgesetz (BFSG).

Germany’s national implementation of the EAA came into force on 28 June 2025. The BFSG law is designed to bring key products and services in line with accessibility standards, without expanding beyond the EU baseline like Poland does. While it follows the directive closely, the German Act introduces specific rules around exemptions, enforcement, and transitional periods that businesses should pay attention to.

What Sets the German Act Apart? 

Germany has largely aligned its implementation with the requirements of the EU Accessibility Act, introducing specific provisions around enforcement and transitional rules. The national law closely mirrors the directive’s scope and technical standards, relying on WCAG 2.1 Level AA and EN 301 549 as key accessibility benchmarks. The BFSG applies to a defined list of consumer-facing products and services, particularly in the digital, banking, telecom, and retail sectors.

What Products and Services should Be Accessible under German Accessibility Act?

The BFSG applies to a wide range of products and digital services offered to consumers. These include:

Products covered:

  1. Consumer computer hardware and operating systems
  2. Self-service terminals:
    • Payment terminals, ATMs, ticketing and check-in machines
    • Interactive terminals (excluding those integrated into vehicles or transport systems)
  3. Consumer telecom and media devices with interactive or computing capabilities
  4. E-book readers

Services covered:

  1. Consumer telecommunications services (excluding machine-to-machine transmission)
  2. Elements of passenger transport (air, bus, rail, waterborne), excluding local/regional services
  3. Websites and mobile apps
  4. E-tickets and real-time travel information (via interactive screens in the EU)
  5. Interactive self-service terminals for transport services (within the EU)
  6. Consumer banking services
  7. E-books and related software
  8. E-commerce platforms and services

The law applies to both manufacturers of the listed products and service providers offering them to consumers in the EU market, whether operating within Germany or serving German consumers cross-border. It focuses on areas where digital accessibility has the most direct consumer impact, particularly in everyday commercial transactions and public-facing technologies.

How the European Accessibility Act Affects Businesses in Germany?

Germany’s BFSG transposes the EAA almost directly and not beyond, introducing harmonized technical standards but tailoring its rules for enforcement and timelines. For businesses in banking, insurance, telecom, public sector, e-commerce, and transport, this means:

  • All digital content must meet WCAG 2.1 AA accessibility criteria (including accessible PDFs).
  • Products and services must function seamlessly with assistive technologies.
  • Physical product labels and instructions must meet defined legibility standards.
  • Online documentation must be publicly accessible and in an accessible format.
  • Businesses must be able to demonstrate compliance efforts through technical documentation, testing reports, and accessibility declarations.

What are Exemptions for German Accessibility Act?

Under Article 4(4) of the European Accessibility Act, the BFSG excludes several areas from its scope:

  • Products and services designed solely for professional or business-to-business use — not intended for consumer markets.
  • The built environment connected to services, such as physical buildings or facilities, which remains outside the BFSG’s remit.
  • Urban, suburban, and regional public transport services — although some elements still fall under accessibility obligations. For example, self-service terminals for ticketing or check-in must comply, while the associated websites and mobile apps are usually regulated under the Public Sector Web Accessibility Directive (2016/2102).

The BFSG also avoids certain broader equality objectives found in other German laws, such as specific protections for women with disabilities or the expanded anti-discrimination grounds listed in § 1 of the General Act on Equal Treatment (AGG).

Exemption for Microenterprises

Microenterprises — defined as having fewer than 10 employees and an annual turnover or balance sheet total under €2 million — are exempt from the BFSG’s mandatory requirements.

This exemption narrows the law’s reach for the smallest businesses, while leaving SMEs and large enterprises fully accountable for compliance.

Controlled Exemptions for Legacy Systems and Contracts

Germany has also introduced targeted transitional provisions to avoid immediate disruption:

  • Service contracts signed before 28 June 2025 can continue without modification until they end, but no later than 27 June 2030.
  • Self-service terminals (e.g., ATMs, ticket machines, kiosks) installed before 28 June 2025 may remain in operation for up to 15 years from installation, provided they met applicable standards at the time.
  • Existing devices and software are not subject to retroactive changes — but any new deployment after June 2025 must meet BFSG requirements immediately.

These measures create phased compliance pressure: companies have more time to address older assets, but cannot delay upgrades indefinitely.

Considerations for Medical and Digital Health Products

Medical devices themselves are generally excluded from the BFSG. However, exceptions apply if:

  • The device’s software is accessed via a covered product, such as a smartphone or tablet.
  • An online platform sells medical devices or provides related services directly to consumers — such as registration, appointment booking, or e-commerce transactions.

In these cases, the digital interface must meet BFSG accessibility requirements.

Other Notable Exemptions

The BFSG also recognises situations where accessibility obligations do not apply, including:

  • Third-party content not funded, developed, or controlled by the economic operator.
  • Certain local and regional public transport services, unless other German or EU laws impose accessibility requirements.
  • Medical devices, unless accessed through a covered consumer-facing interface, in which case the interface must still comply.

Disclosure Rules for Digital and Physical Accessibility

While the BFSG mandates accessibility, it references “essential requirements” in EU law and harmonized standards rather than prescribing every technical detail.The BFSG applies to a wide range of products and digital services offered to consumers. Two standards are central for proving compliance:

  • EN 301 549 – Harmonized European ICT accessibility standard.
  • WCAG 2.1 AA – International benchmark for digital accessibility, incorporated into EN 301 549.

These standards define measurable requirements for:

For Physical Products:

  • Labels and instructions must have adequate font size, colour contrast, and spacing.
  • Information must be available in multiple sensory forms — supporting users with visual, auditory, or cognitive disabilities.

For Digital Documentation (including PDFs):

  • Documentation must be available online in accessible PDF format meeting WCAG and EN 301 549.
  • The link (URL) to the accessible version must be clearly printed on packaging or product materials.
  • Content must be fully compatible with assistive technologies such as:
    • Screen readers (JAWS, NVDA)
    • Braille displays
    • AAC (Alternative and Augmentative Communication) systems

What are Penalties for BFSG Incompliance?

Germany has introduced clear enforcement mechanisms. Non-compliance can result in administrative fines of up to €100,000, as well as potential market restrictions or product bans. Enforcement will be overseen by designated national authorities – such as market surveillance bodies and state-level regulators (Länder) – who may monitor compliance and act on violations under general fair trading rules.

Businesses should also be aware that failure to comply could invite legal challenges or reputational risks, especially in sectors with high public visibility.

What is a Transitional Periods for Accessibility Act in Germany?

The BFSG enters into force on 28 June 2025, with the following transitional arrangements:

  • Existing service contracts signed before 28 June 2025 can remain unchanged until they end, but no later than 27 June 2030, including streaming subscriptions and similar services
  • Service providers may continue using older products, such as tablets, smartphones or e-book readers, that were lawfully in use before 28 June 2025, until 27 June 2030
  • Self-service terminals installed before 28 June 2025 may remain in use for up to 15 years from their installation date, provided they complied with the rules in force at the time

For example, a telecom provider offering self-service kiosks for SIM registration installed in 2022 can continue using them until 2030, while a new installation after 2025 must meet accessibility requirements from day one. Similarly, online service contracts signed before June 2025 need not be retroactively updated for compliance.

These transitional measures are intended to give businesses time to phase in upgrades without disrupting service continuity.

How Quertum supports your Accessibility Journey and Compliance with EAA?

Navigating accessibility requirements under the European Accessibility Act (EAA) doesn’t have to be overwhelming. Quertum helps you make sense of technical standards like WCAG, PDF/UA, and EN 301 549 — and puts them into action, across your real-world documents and systems.

Whether you’re in banking, insurance, telecom, or the public sector, we help ensure your communication channels are compliant, user-friendly, and ready for the new legal landscape in Germany and across the EU.

With Quertum, you get:

✅ Document audits you can act on
We don’t just flag issues — we tell you what they mean and how to fix them. From PDF templates to legacy systems, we identify the gaps and help you close them fast.

✅ Accessibility retrofitting that fits your stack
We integrate with your existing Document Management Systems & Customer Communication Management systems and your workflows — no need to rebuild from scratch.

✅ Compliance that scales with your DMS & CCM
Accessibility is not a one-time project. We help you set up repeatable, scalable processes to ensure ongoing compliance — across teams, channels, and output.

From legal interpretations to tech implementation, our cross-functional team supports you in translating regulations into practical solutions — without the jargon. Start your accessibility journey with confidence.

Summary

Germany’s implementation of the European Accessibility Act offers clarity and consistency, staying faithful to the original directive while acknowledging industry realities through exemptions and phase-ins. For businesses operating in Germany or serving German consumers, the upcoming enforcement date presents both a legal obligation and an opportunity to embed accessibility into product design, customer experiences, and digital infrastructure.

Taking action now means not just avoiding penalties, but building more inclusive services that meet evolving customer expectations.

Next steps for businesses:

  • Audit your current digital products and services
  • Identify contracts, platforms, and hardware in use before June 2025
  • Begin planning for technical upgrades, staff training, and documentation
  • Monitor upcoming guidance from German authorities

EU Accessibility Act in Poland: Details Business Should Know

Written by Kateryna Klynovska on . Posted in EEA.

The European Accessibility Act (EAA) is reshaping how businesses in Europe design and deliver digital services. In our previous article, we shared the main pillars and risks of being incompliant with the European Accessibility Act. Let’s go beyond the common European directive and dive deeper with state-centred approaches.

In this article, we share all you need to know to operate in an EAA-compliant way in Poland, despite being a local or global company.

How European Accessibility Act Affects Poland Business?

Poland’s national implementation of the European Accessibility Act (Directive 2019/882) goes well beyond the EU baseline — introducing stricter obligations, more detailed formatting rules, and a robust enforcement framework. Businesses operating in Poland must prepare not only for compliance with the directive, but also with a more prescriptive and locally integrated legal environment.

What EAA or PAD (Polski Akt Dostępności) in Poland Requires?

  • Digital content must comply with WCAG 2.1 AA (e.g., readable PDFs, accessible websites)
  • Products and services must work with assistive technologies
  • Clear labelling and instructions with adequate font size, spacing, and contrast
  • Online documentation must be publicly available and accessible
  • Businesses must show evidence of accessibility efforts (technical documentation, testing, declarations)

Exemption for Microenterprises

While the EU directive gives Member States the option to exempt microenterprises, Poland applies this exemption across the board. 

This means:

  • Businesses with fewer than 10 employees;
  • Either less than €2 million in turnover or balance sheet total.

This narrows the scope considerably for very small businesses, while placing greater responsibility on SMEs and large enterprises. 

Controlled Exemptions for Mapping and Navigation

While the EU directive allows certain exemptions for mapping and navigation systems, the Polish Act narrows these significantly. 

Interactive maps and geoportals are only exempt if:

  • The data present is already available in a digitally accessible format, and
  • The service complies with Poland’s separate Digital Accessibility Act (2019), which governs public sector websites and apps.

This layered approach ensures that accessibility gaps aren’t created through overly broad expectations. The relevant provisions are found in Article 4(2)(a).

Other Exemptions 

The Act also outlines specific cases where accessibility obligations do not apply. These include:

  • Third-party content not funded, developed, or controlled by the economic operator;
  • Public transport services and local administrative services at the municipal, metropolitan, county, and county-municipal levels, unless otherwise required under other Polish or EU regulations.

These limited exemptions recognize practical constraints while maintaining the overall intent of the law — ensuring accessibility is the rule, not the exception.

Disclosure Rules for Physical and Digital Accessibility

The Polish Accessibility Act does more than require accessibility — it defines how accessibility must be implemented. However, it stops short of listing exact technical specifications. Instead, it refers broadly to “essential accessibility requirements defined in EU law and harmonized standards.”

To navigate this ambiguity, we recommend aligning with the two primary standards recognized across the EU for demonstrating compliance:

  • EN 301 549 – the harmonized European standard for ICT accessibility
  • WCAG 2.1 – the global benchmark for digital content accessibility (incorporated within EN 301 549)

These standards outline specific, testable criteria across both physical and digital domains:

For Physical Products

  • Labels and instructions must meet defined criteria for font size, color contrast, and text spacing, ensuring legibility for users with visual impairments.
  • Information must be perceivable through multiple sensory channels, supporting accessibility for people with visual, auditory, or cognitive disabilities.

For Digital Documentation

  • Documentation must be made available online in an accessible format, compliant with WCAG and EN 301 549.
  • The web address (URL) for this digital content must be clearly printed on the physical product or its packaging.
  • All content must be compatible with assistive technologies, including:
    • Screen readers (e.g., NVDA, JAWS)
    • Braille displays
    • Alternative and Augmentative Communication (AAC) systems

By proactively meeting these harmonized standards, organizations can demonstrate good-faith compliance with the Polish Accessibility Act and reduce their exposure to regulatory risk.

Tightly Defined Legal Terms

Where the EU directive leaves room for interpretation, the Polish legislation introduces precise legal definitions for key accessibility terms. These include: 

  • User interface accessibility – ensuring digital tools are operable, understandable, and robust for all users
  • Real-time communication – defined to include voice, video, and text channels that enable seamless, synchronous interaction 
  • Alternative and Augmentative Communication (AAC) – explicitly referenced, supporting individuals with speech or language impairments
  • Interoperability with assistive technologies – a requirement for ensuring systems work across platforms and devices, not just within proprietary environments

This increased specificity supports legal certainty and simplifies implementation for both product developers and compliance teams.

Multi-Institutional Enforcement Model

Enforcement in Poland will not rely on a single regulator. Instead, it is distributed across multiple institutions to ensure cross-sector compliance:

  • The Ministry of Regional Development serves as the coordinating body
  • PFRON (State Fund for Rehabilitation of Disabled Persons) supports monitoring and expertise
  • Local governments and universities are involved in outreach and technical assistance
  • NGOs focused on accessibility provide oversight and advocacy
  • Customs and market surveillance authorities handle inspections and enforcement in import/export and retail contexts
A visual diagram showing key institutions involved in enforcing the European Accessibility Act (EAA) in Poland. At the center, an icon of a police officer and a person stands beneath a security gate, symbolizing oversight. Surrounding them are five labeled segments: "Ministry of Regional Development" (oversees and coordinates enforcement nationally), "PFRON" (provides technical expertise and disability insights), "Local Governments and Universities" (implement EAA principles locally), "NGOs" (act as watchdogs and user advocates), "Customs and Market Surveillance" (ensure market compliance). Each segment includes a corresponding icon. Background is a gradient of dark blue and purple.

Monitoring begins in June 2026, following the mandatory compliance date of 28 June 2025.

Integration Across Over 10 Domestic Laws

To create a consistent and enforceable framework, Poland has embedded the a wide range of existing legislation, including: 

This cross-law integration makes accessibility a mandatory design principle — not a compliance afterthought. It introduces measurable expectations for both product and service delivery, reinforces risk exposure in regulated environments and aligns national policy with EU enforcement strategy. This integration supports systemic change and positions accessibility as a core requirement, not a side consideration.

Summary

Poland’s approach to accessibility is comprehensive and future-facing. For companies operating in Poland, or exporting to it, compliance with the Polish Accessibility Act requires more than checking boxes. It demands deliberate design choices, legal awareness, and operational readiness. Starting early will reduce risk and help businesses deliver inclusive experiences that meet both regulatory and customer expectations. 

Accessibility logo with human in the circle surrounded by EU yellow stars. All on planet background

European Accessibility Act Compliance by Sector: GDPR Lessons and What to Expect in 2025

Written by IT Administrator on . Posted in EEA, GDPR, Quertum News, Uncategorized.

When the GDPR came into force in 2018, companies had to adapt how they handled personal data. It set a new standard for privacy and introduced penalties that many businesses were unprepared for. Now, the European Accessibility Act (EAA) is following a similar trajectory – only this time, the focus is on accessibility.

The EAA takes full effect on June 28, 2025. The new Directive aims to ensure that digital products and services, such as websites, apps, documents, and ticketing systems, are accessible to people with disabilities across the EU. For many businesses, this will mean redesigning websites, rethinking digital communications, and ensuring that customer-facing services meet accessibility standards like WCAG and PDF/UA. The parallels to GDPR are clear: a sweeping EU regulation, broad applicability, and the potential for significant fines for non-compliance.

Yet few organizations have a clear plan in place to meet the upcoming requirements.

High-Exposure Sectors: Who Will Feel the EAA First?

Industries that rely heavily on digital customer interaction are the first in line. This includes finance, where online banking and digital onboarding are core to the customer journey; retail, where e-commerce platforms and checkout systems must be accessible by default; and transportation, where digital ticketing and self-check-in are now standard. Public services such as healthcare portals and government sites are also squarely within scope, especially given the public-sector accessibility precedents already in place.

In these sectors, the risks often take the shape of inaccessible platforms, customer documents, or service workflows, each of which may soon be considered a legal liability under national enforcement laws. 

What raises the stakes even further is visibility. The more essentially a service is to daily life, the more likely it is to be scrutinized, and the less tolerance regulators will have for inaccessible touchpoints.

One Directive, 27 Penalty Systems

Just like with the GDPR, the EAA leaves enforcement in the hands of EU Member States. This means companies must pay close attention to the specific penalties and compliance expectations in each country where they operate.

Some countries have already outlined substantial fines. In Spain, Ley 11/2023 introduces penalties of up to €1 million per infringement, explicitly covering electronic documents like PDFs. Germany’s Barrierefreiheitsstärkungsgesetz allows for fines of up to €500,000, and in severe cases, non-compliant digital products or services can even be removed from the market.

Elsewhere in the EU, the landscape remains just as serious. France imposes fines of up to €300,000, Czechia up to €400,000, and Hungary has set penalties as high as €1.26 million or 5% of annual net turnover. In Italy, fines can reach €40,000, or up to 5% of turnover under the Stanca Law for private entities.

Enforcement isn’t uniform, and that’s the point. While the EAA sets a harmonized baseline, the risks vary dramatically by jurisdiction. Businesses with operations or customers across multiple countries must be proactive in tracking national developments to avoid falling foul of country-specific enforcement actions. 

For a quick overview of the already established EAA penalties across EU markets, see the table below.

CountryFines
AustriaFines range up to EUR 80 000
CzechiaFines range up to EUR 400 000
FranceFines range up to EUR 300 000
GermanyFines range up to EUR 500 000
HungaryFines range up to EUR 1 261 164 or 5% of the annual net turnover
ItalyFines range up to EUR 40 000 or, for private entities that fall within the scope of the Stanca Law, up to 5% of turnover
The NetherlandsFines range up to EUR 103 000
SlovakiaFines range up to EUR 200 000
SpainFines range up to EUR 1 000 000

From Privacy to Accessibility: How GDPR Prepared Us for the EAA

The GDPR era taught businesses several hard-earned lessons. Some of them can be directly applied to the EAA:

✅ Compliance is a continuous process, not a single deadline

✅ User expectations evolve, and meeting them consistently builds trust

✅ Regulatory alignment can become a competitive advantage

✅ One-size-fits-all solutions rarely work in complex, multi-market operations

✅ Technology alone isn’t enough – internal processes and policy need to support it

Perhaps most importantly, GDPR showed us that EU legislation doesn’t stay theoretical for long. Once enforcement begins, regulators act – especially where clear obligations have been set and ignored.

The EAA will likely follow a similar trajectory. Companies that treat accessibility as a long-term priority, and can demonstrate visible progress, will be in a much stronger position than those that scramble to catch up. Building capability early helps reduce risk, avoid reputational damage, and respond confidently as national enforcement frameworks mature.

EAA Day One: What Happens After June 2025?

The EAA becomes enforceable on June 28, 2025 – but that date doesn’t mark the end of the road. It marks the beginning of active enforcement and increased scrutiny. Compliance won’t be measured by a single audit on that day, but by how well your organization is prepared to show progress, intent, and structure.

Just as with GDPR, regulators are unlikely to expect flawless implementation on day one. What they will expect is a demonstrable plan – evidence that your company understands its obligations and is actively working to meet them. That includes documented audits, defined roles and responsibilities, and timelines for remediating accessibility gaps.

The most resilient companies will treat this moment not as a finish line, but as the launch of a more permanent phase of compliance. Laws will evolve, interpretations will shift, and enforcement will likely become more consistent over time. Establishing regular review cycles, tracking relevant country-level legislation, and integrating accessibility into procurement and development processes will be essential to keeping pace.

June 2025 isn’t the point where you need to have everything perfect. It’s the point where you need to have a credible, visible path forward – and the ability to prove that accessibility is already part of how your organization operates.

Set the Standard, Don’t Chase It

If GDPR taught us anything, it’s that the cost of inaction grows fast. The companies that took early, practical steps toward compliance were the ones that avoided penalties and earned long-term trust. The same holds true for the EAA.

At Quertum, we can help you take those early, practical steps, by making your digital communications accessible, efficiently and at scale. Whether you need support implementing PDF/UA standards or ensuring your customer-facing content meets EAA requirements, we’re here to help you get it right from the start.

Accessibility doesn’t have to be overwhelming.

Quertum helps make it manageable. See how we can support your accessibility implementation.

Summary

The shift from GDPR to the European Accessibility Act (EAA) marks a new phase in EU regulation, this time focused on digital accessibility. Like the GDPR, the EAA has a broad scope and serious penalties, yet many organizations remain unprepared. Industries that depend on digital customer interaction, including finance, retail, transport, and public services, are especially exposed. The more essential and visible the service, the greater the risk of regulatory scrutiny. While the EAA provides a shared EU framework, each Member State sets its own penalties, resulting in varied enforcement across countries. This variation is intentional, which makes staying informed about local requirements essential. A key lesson from the GDPR still holds true: compliance is not a one-time task. Companies that take early steps toward accessibility will be better equipped to manage risk and build long-term trust. June 2025 is not the point when everything must be perfect, but the moment when meaningful progress must be visible.