Bajorat Media
Is my website subject to the BFSG?
Whether a website is subject to the BFSG depends mainly on whether it falls under the covered B2C services and whether exemptions apply.
A website is not automatically subject to the BFSG. The German Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz) becomes relevant mainly for certain B2C products and services, especially in electronic commerce; microenterprises offering services are exempt in many cases.
The BFSG has applied since 28 June 2025 to the products and services covered by the act. These include, among others, electronic commerce, banking services for consumers, e-books, telecommunications services and certain passenger transport services; the exact scope is defined in section 1 of the Accessibility Strengthening Act (German). For websites, what matters above all is whether consumers can request, book, buy or conclude a contract for a service online.
When websites can typically be affected
Companies should review websites in particular with:
- an online shop or ordering function
- booking or reservation flows for consumers
- digital contract conclusions
- B2C customer portals
- paid digital services
- e-book, ticket, travel, finance or telecommunications offers
The exact scope depends on the individual case. Section 3 BFSG governs the accessibility obligation for covered products and services; section 2 BFSG defines terms such as microenterprise and electronic commerce. The legal texts are available at Gesetze im Internet (German).
Which exemptions matter
Microenterprises that offer services are exempt from the act. This means companies with fewer than ten employees and at most 2 million euros in annual turnover (section 2 BFSG). This exemption does not apply in the same way to microenterprises that place covered products on the market.
Purely internal systems, pure B2B offers or simple information pages without a covered digital service may also be assessed differently. In case of doubt, this classification should be checked legally. This article does not replace legal advice.
What companies should check in practice
A sensible first check:
- Is the website used by consumers?
- Are there purchase, booking, ordering or contract processes?
- Does the service fall under the services named in the BFSG?
- Does the microenterprise exemption apply?
- Which central user paths would have to work accessibly?
If an obligation is likely, the website, forms, checkout, navigation, content and documents should be checked professionally. The service page accessibility describes the technical entry point. The existing glossary article What is the BFSG? explains the term in general.
Separate the obligation from the implementation
The obligation question is not the same as the cost question. What an audit or retrofitting can cost is explained in What does an accessible website cost?. For many companies, accessibility is sensible even without a clear obligation, because it makes forms, shop flows and content more robustly usable.
