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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
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.

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.