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Tag: European Accessibility Act

Graphic showing the Quertum logo, the title ‘German Accessibility Act: What Business Can Expect from BFSG?’, and a silhouette of Germany in black, red, and yellow with an accessibility symbol in the center, set against a dark blue gradient background with green outlined shapes.

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 on left-hand side. PAC app accessibility checker on right-hand side.

Is Your Business Ready for the 2025 European Accessibility Act?

Written by Kateryna Klynovska on . Posted in EEA.

The European Accessibility Act (EAA) is reshaping the digital landscape in the EU. At its core, the EAA aims to break down barriers and ensure that a wide array of products and services are accessible to everyone, including the millions of people with disabilities across the European Union (EU). This extends beyond simply using an accessibility checker; it necessitates embedding accessibility into your design thinking, from websites to all customer communications. A key challenge is that the EAA’s requirements, while comprehensive, can sometimes be perceived as broadly defined. As a result, many organizations do not realize that the EAA also applies to documents, including PDFs, which are a critical component of their communication workflows. 

While EU member states were required to transpose the EAA into national law by June 2022, the critical date is June 28, 2025, when full enforcement begins. This day marks the point when the requirements of the EAA will become legally binding for a vast number of businesses operating within the EU. The window for delaying serious action has effectively closed. Procrastination now carries significant risks, not just from a legal standpoint, but also in terms of market reach and brand perception.

Across Europe, the EAA is no longer a set of “nice-to-have” guidelines, it now carries a price tag on every website, mobile app, and PDF your company sends. Spain’s Ley 11/2023 tops the list with fines that scale up to €1 million per infringement and it explicitly names electronic documents, obliging all outgoing PDFs to meet the PDF/UA tagging standard. Germany’s Barrierefreiheitsstsärkungsgesetz lets market-surveillance authorities impose penalties of €100 000 and even ban a product or service until it is accessible. Sweden will start handing out sanctions of up to 10 million SEK (~€870 000) for inaccessible e-commerce or banking interfaces when its new law takes effect on June 28th 2025. Similarly, in Finland, Traficom can now hand out fines up to €150 000 – and escalate them daily – until defects are fixed. Taken together, these moves make one thing clear: ignoring accessibility is no longer a technical oversight, but a severe financial risk for all companies operating within the EU. 

Overlooking Digital Accessibility? You’re Ignoring 15% of the Global Market

Even if your organization believes it falls outside the direct scope of the EAA, overlooking accessibility in your communication processes is a significant strategic oversight. In today’s interconnected world, inclusivity isn’t simply a moral imperative, it’s a powerful business driver. Consider the sheer potential of reaching the approximately 15% of the global population with disabilities – a substantial market segment often unintentionally excluded by inaccessible communication.

By proactively making your websites, PDF materials, social media content, and customer service channels accessible, you unlock a wealth of opportunities. 

  • Imagine what could happen if every prospective customer could actually use your website, app, or documents without a struggle. Accessible design unlocks an entire segment of the market that might otherwise give up and look elsewhere. Simple steps like applying real heading tags or marking up lists properly can be the bridge that invites them in.
  • Accessibility also earns loyalty. When people see that you’ve taken the time to add descriptive alt-text to images and graphs, they recognize a brand that genuinely cares. That kind of respect sticks – it turns first-time buyers into long-term advocates.
  • And let’s be honest, in a crowded marketplace, “we’re easy for everyone to use” is a big differentiator. Companies that advertise their commitment to inclusive design attract customers who want to spend with businesses that share their values. Regular checks with an accessibility scanner or PDF-testing tool show you’re not only compliant today, but ready for whatever tomorrow’s standards require.
  • Finally, what helps some helps all. Clear language, logical structure, keyboard-friendly navigation – these aren’t just accessibility wins, they’re SEO boosters and usability upgrades for every visitor. Streamline the reading order, make that checkout flow effortless, and watch both your search ranking and your customer satisfaction rise together.

The Accessibility Gap Is Closing – But Not Evenly

In just two years, the share of companies actively planning for accessible PDFs and digital communications has more than tripled. According to industry data, 66% of surveyed companies now have a roadmap for PDF/UA compliance, signalling a clear shift toward inclusive design. At the same time, many public-facing websites, especially in the Nordics, are already scoring exceptionally well for Web Content Accessibility Guidelines (WCAG) compliance, showing what’s possible when accessibility is treated as a strategic priority.

Yet the distance between early movers and the rest of the market is growing. An early 2025 AbilityNet survey found that just 11% of organizations feel confident they’ll meet the EAA deadline. For many, the challenge isn’t a lack of intent, it’s about knowing where to start and how to scale accessibility across documents, channels and teams. That’s where experienced partners like Quertum can help – bridging the gap between legal requirements and real-world implementation with clear audits, hands-on remediation, and long-term support. As compliance becomes a baseline expectation, the companies that act now won’t just meet the standard, they’ll help set it.

The Urgency is Real: Take the Next Step Now

The June 2025 deadline is closer than it seems. Organizations that postpone action on the EAA risk legal penalties and, just as critically, the loss of a sizable customer segment. Whether you’re just beginning or scaling your efforts, now is the time to move beyond acknowledgement and embed accessibility – at minimum PDF/UA compliance and WCAG AA standards – into everyday processes and communications. Now is the moment to move beyond acknowledgement and weave accessibility – at minimum PDF/UA compliance and WCAG AA standards – into everyday processes and communications. Don’t just catch up – lead the way into a more inclusive digital future.