Samples of the information on accessibility for the German Accessibility Strengthening Act (Barrierefreiheits-Stärkungs-Gesetz, BFSG)

Sample for websites: Information on accessibility

Note: This is fictitious information about a website that does not exist. It only serves as a template for what something like this could look like.

As of: June 25, 2025
This information applies to the demo website in the state in which it is marketed from June 28, 2025. The website can be reached under the following domains and subdomains: [list the domains and subdomains here]

General description

With the demo website you can … [describe important functions of the website here].

Information about the manufacturer and provider

Sample Company
First name Last name
Sample Street 12
12345 Sample City
Country

Phone: 01234 56789
Email: info@mustermail.de

Requirements, state of compliance and implementation

The website meets the requirements of the Ordinance on the German Accessibility Strengthening Act (Verordnung zum Barrierefreiheits-Stärkungs-Gesetz, BFSG).
The following standards and guidelines were applied:

• Harmonised European Standard (EN) 301 549, version 3.2.1
• Web Content Accessibility Guidelines (WCAG), version 2.1, levels A and AA

We continuously take measures to improve accessibility and the user experience of the website. These include, for example:

• We get advice from experts in digital accessibility.
• The website has undergone an independent external accessibility test.
• Employees have been and continue to be made aware of and trained in digital accessibility.
• Accessibility requirements have been integrated into relevant internal processes (concepts, design, development and more).
• We carry out automated and manual tests internally.
• People with disabilities test the website for its user-friendliness (usability).

Accessibility details

Basics

• You can use the website with assistive technologies without any loss of information.
• The website protects your privacy. This also applies to the accessibility features.
• You can prove your identity or authenticate yourself on the website in an accessible way. There are alternatives to biometric identification / authentication.
• Security and payment functions are accessible.

Seeing

The website works with limited vision and without vision. It requires neither vision nor the ability to perceive colours. There are also alternatives to the visual presentation.

Font, contrast, spacing

Typeface, font size and font style were chosen to be easy to read. Texts and visual content have clearly recognisable contrasts. Texts are displayed with sufficient spacing between letters, lines and paragraphs.
The presentation of the website can be customised. You can use the settings in your browser and/or your operating system for this.

Alternatives to colour cues

There are colour-independent alternatives for colour cues. For example, the website shows the status not only visually, but also with text. The same applies to warnings and delivery notes.

Alternatives for non-text content

For content that does not consist of text, there are alternatives that do not require vision. The website offers, for example, alternative texts for photos, icons and graphics. Videos contain an audio track that describes important visual content (audio description).

Magnification

You can enlarge the display of the content. You can use the settings in your browser and/or your operating system for this.

Operable with a keyboard

You can use and control the website with an external keyboard. This works for all areas and functions. Navigation follows a meaningful order.
When you select interactive elements, such as links or buttons, with the keyboard, they are visually clearly highlighted (focus indicator).

Support for non-visual output via screen reader / braille display

You can operate and output all areas, content and functions of the website with the screen reader installed on your operating system. This is done either via audio output or tactilely via an externally connected braille display.

Time limits

The website has only a few areas in which time is limited. If an area has a time limit, this is announced in good time. You can then extend, change or turn off the limit.

Headings and labels

The website contains meaningful and logically structured headings and labels.

Links

Links are easy to recognise and have meaningful labels.

Audio output

The website has audio output in several places, for example the audio description in videos. You can pause and stop it and adjust its speed and volume.

Hearing

The website works with limited hearing and without hearing. It does not require hearing. There are also alternatives for audio content.

Alternatives for audio content

There are alternatives for audio output that do not require hearing. For example, subtitles for videos, text versions of audio files and additional visual cues for audio signals.

Mobility, reach, strength

The website works with limited mobility. This also applies if you have difficulty reaching things or exerting force. You do not need these abilities to use the website.

Operable with a keyboard

You can use and control the website with an external keyboard. This works for all areas and functions. Navigation follows a meaningful order.
When you select interactive elements, such as links or buttons, with the keyboard, they are visually clearly highlighted (focus indicator).

Click targets

Click targets for interactive elements, such as links or buttons, are large and designed with sufficient spacing. This makes them easy to reach and operate.

Screen orientation

The website works in different orientations. You can turn your screen to landscape or portrait orientation. The display of areas, content and functions adapts automatically.

No complex or simultaneous movements

The website works without complex, path-based or simultaneous movements.

Time limits

The website has only a few areas in which time is limited. If an area has a time limit, this is announced in good time. You can then extend, change or turn off the limit.

Speaking

The website works with limited speech and without speech. It does not require the ability to speak. There are also alternatives that do not require the ability to speak.

Alternatives to speaking

For areas where speaking is required, there are alternatives that do not require it. You can, for example, get in touch not only by phone, but also in writing.

Cognitive, mental, neurological, neurodivergent

You can use the website with limited or alternative cognitive, mental or neurological abilities. This also applies if you identify as neurodivergent.

Clear structures

The website has a clear structure.

Headings and labels

The website contains meaningful and logically structured headings and labels.

Links

Links are easy to recognise and have meaningful labels.

Understandable texts

The texts on the website are written to be easy to understand.

Autofill

For frequently used fields, you can use the autofill feature of your browser and/or operating system. For example, for address or contact details.

Avoiding errors

The website has been designed to help you avoid errors.

Correcting errors

The website helps you correct errors.

Animations

There are only a few short animations on the website. You can deactivate or stop animations via the settings in your browser and/or your operating system.

Light/flash effects

The website does not contain any light or flash effects that could trigger photosensitive seizures.

Time limits

The website has only a few areas in which time is limited. If an area has a time limit, this is announced in good time. You can extend, change or turn off the limit.

Audio output

The website has audio output in several places, for example subtitles. You can pause and stop it and adjust its speed and volume.

Responsible market surveillance authority

Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF, the German federal states’ market surveillance authority for the accessibility of products and services) in Magdeburg (Saxony-Anhalt).

Sample for apps: Information on accessibility

Note: This is fictitious information about an app that does not exist. It only serves as a template for what something like this could look like.

As of: June 25, 2025
This information applies to the demo app in the state in which it is marketed from June 28, 2025.

General description

With the demo app you can … [describe important functions of the app here].
The app is available for the iOS and Android operating systems.

Information about the manufacturer and provider

Sample Company
First name Last name
Sample Street 12
12345 Sample City
Country

Phone: 01234 56789
Email: info@mustermail.de

Requirements, state of compliance and implementation

The app meets the requirements of the Ordinance on the German Accessibility Strengthening Act (Verordnung zum Barrierefreiheits-Stärkungs-Gesetz, BFSG).
The following standards and guidelines were applied:

• Harmonised European Standard (EN) 301 549, version 3.2.1
• Web Content Accessibility Guidelines (WCAG), version 2.1, levels A and AA

We continuously take measures to improve accessibility and the user experience of the app. These include, for example:

• We get advice from experts in digital accessibility.
• The app has undergone an independent external accessibility test.
• Employees have been and continue to be made aware of and trained in digital accessibility.
• Accessibility requirements have been integrated into relevant internal processes (concepts, design, development and more).
• We carry out automated and manual tests internally.
• People with disabilities test the app for its user-friendliness (usability).

Accessibility details

Basics

• You can use the app with assistive technologies without any loss of information.
• The app protects your privacy. This also applies to the accessibility features.
• You can prove your identity or authenticate yourself in the app in an accessible way. There are alternatives to biometric identification / authentication.
• Security and payment functions are accessible.

Seeing

The app works with limited vision and without vision. It requires neither vision nor the ability to perceive colours. There are also alternatives to the visual presentation.

Font, contrast, spacing

Typeface, font size and font style were chosen to be easy to read. Texts and visual content have clearly recognisable contrasts. Texts are displayed with sufficient spacing between letters, lines and paragraphs.
The presentation of the app can be customised. You can use the settings in the app and/or in the operating system of your mobile device for this.

Alternatives to colour cues

There are colour-independent alternatives for colour cues. For example, the app shows the status not only visually, but also with text. The same applies to warnings and delivery notes.

Alternatives for non-text content

For content that does not consist of text, there are alternatives that do not require vision. The app offers, for example, alternative texts for photos, icons and graphics. Videos contain an audio track that describes important visual content (audio description).

Magnification

You can enlarge the display of the content. You can use the settings in the app and/or in the operating system of your mobile device for this.

Operable with a keyboard

You can use and control the app with an external keyboard. This works for all areas and functions. Navigation follows a meaningful order.
When you select interactive elements, such as links or buttons, with the keyboard, they are visually clearly highlighted (focus indicator).

Support for non-visual output via screen reader / braille display

You can operate and output all areas, content and functions of the app with the screen reader of your mobile device. This is done via audio output and/or tactilely via an externally connected braille display.

Time limits

The app has only a few areas in which time is limited. If an area has a time limit, this is announced in good time. You can extend, change or turn off the limit.

Headings and labels

The app contains meaningful and logically structured headings and labels.

Links

Links are easy to recognise and have meaningful labels.

Audio output

The app has audio output in several places, for example the audio description in videos. You can pause and stop it and adjust its speed and volume.

Hearing

The app works with limited hearing and without hearing. It does not require hearing. There are also alternatives for audio content.

Alternatives for audio content

There are alternatives for audio output that do not require hearing. For example, subtitles for videos, text versions of audio files and additional visual cues for audio signals.

Mobility, reach, strength

The app works with limited mobility. This also applies if you have difficulty reaching things or exerting force. You do not need these abilities to use the app.

Operable with a keyboard

You can use and control the app with an external keyboard. This works for all areas and functions. Navigation follows a meaningful order.
When you select interactive elements, such as links or buttons, with the keyboard, they are visually clearly highlighted (focus indicator).

Click targets

Click targets for interactive elements, such as links or buttons, are large and designed with sufficient spacing. This makes them easy to reach and operate.

Screen orientation

The app works in different orientations. You can turn your screen to landscape or portrait orientation. The display of areas, content and functions adapts automatically.

No complex or simultaneous movements

The app works without complex, path-based or simultaneous movements.

Time limits

The app has only a few areas in which time is limited. If an area has a time limit, this is announced in good time. You can extend, change or turn off the limit.

Speaking

The app works with limited speech and without speech. It does not require the ability to speak. There are also alternatives that do not require the ability to speak.

Alternatives to speaking

For areas where speaking is required, there are alternatives that do not require it. You can, for example, get in touch not only by phone, but also in writing.

Cognitive, mental, neurological, neurodivergent

You can use the app with limited or alternative cognitive, mental or neurological abilities. This also applies if you identify as neurodivergent.

Clear structures

The app has a clear structure.

Headings and labels

The app contains meaningful and logically structured headings and labels.

Links

Links are easy to recognise and have meaningful labels.

Understandable texts

The texts in the app are written to be easy to understand.

Autofill

For frequently used fields, you can use the autofill feature of your browser and/or operating system. For example, for address or contact details.

Avoiding errors

The app has been designed to help you avoid errors.

Correcting errors

The app helps you correct errors.

Animations

There are only a few short animations in the app. You can deactivate or stop animations via the settings in the app or on your mobile device.

Light/flash effects

The app does not contain any light or flash effects that could trigger photosensitive seizures.

Time limits

The app has only a few areas in which time is limited. If an area has a time limit, this is announced in good time. You can extend, change or turn off the limit.

Audio output

The app has audio output in several places, for example subtitles. You can pause and stop it and adjust its speed and volume.

Responsible market surveillance authority

Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF, the German federal states’ market surveillance authority for the accessibility of products and services) in Magdeburg (Saxony-Anhalt).

Sample for hardware products: Information on accessibility

Note: This is fictitious information about a hardware product that does not exist. It only serves as a template for what something like this could look like.
The requirements for products differ greatly depending on the product type. That is why it is especially true for this sample that it is only an example. Your product is very likely subject to requirements that the sample does not cover! This applies above all to self-service terminals or other special products. It already makes a huge difference whether a product has so-called closed functionality or not. This sample cannot cover all the many possibilities. I therefore recommend that you get advice from experts in digital accessibility who are also specifically familiar with hardware products. Getting advice from legal professionals would also be very beneficial.

As of: June 25, 2025
This information applies to the demo product (placed on the market from June 28, 2025).

General description

The demo product is a [insert product type here, for example: router, smartphone, TV receiver].
With the demo product you can … [describe important functions of the product here].

You need the following to use the product:

• Internet connection
• The manufacturer’s demo app
• a mobile device, such as a smartphone or tablet, to use the demo app
• individual login details

You control certain elements of the product on your mobile device via the manufacturer’s demo app. For example, the installation and configuration of the product. The demo app has its own information on accessibility [insert link to the information on accessibility of the app].

Information about the manufacturer

Sample Company
First name Last name
Sample Street 12
12345 Sample City
Country

Phone: 01234 56789
Email: info@mustermail.de

Requirements, state of compliance and implementation

The product meets the requirements of the Ordinance on the German Accessibility Strengthening Act (Verordnung zum Barrierefreiheits-Stärkungs-Gesetz, BFSG).
The following standards and guidelines were applied:

• Harmonised European Standard (EN) 301 549, version 3.2.1
• Web Content Accessibility Guidelines (WCAG), version 2.1, levels A and AA

We continuously take measures to improve accessibility and the user experience of the product. These include, for example:

• We get advice from experts in digital accessibility.
• The product has undergone an independent external accessibility test.
• Employees have been and continue to be made aware of and trained in digital accessibility.
• Accessibility requirements have been integrated into relevant internal processes (concepts, design, development and more).
• We carry out automated and manual tests internally.
• People with disabilities test the product for its user-friendliness (usability).

Accessibility details

Basics

• You can install and configure the product with the help of assistive technologies via the associated app.
• The product protects your privacy. This also applies to the accessibility features.
• You can prove your identity or authenticate yourself on the product in an accessible way. There are alternatives to biometric identification / authentication.
• Security functions are accessible.
• The product contains no payment functions.

Instructions

There is a short quick start guide and a full version of the instructions for the product. The printed version is included in the product packaging. You can find the digital version on the product’s website. The packaging and the printed instructions have tactile labels. There is also a QR code with a tactile marking. It also takes you to the digital version.

We make sure that our instructions are accessible. For example, in the design with good contrasts, font sizes, typeface, spacing, line heights and much more.

We also pay attention to this in the content. Everything is explained for at least two different senses. There are alternative texts for graphics, icons and images. Positions of cables, ports or controls are explained in such a way that you can identify them even without vision.

We make sure that we write the instructions in an easy-to-understand way. Technical terms are replaced with simpler terms or explained.

You can use the digital version of the instructions with assistive technologies. For example, you can open, operate and perceive it with the screen reader on your mobile device. Or you can use the zoom function or voice control of your browser or operating system.

You can use our service with different senses. In the instructions you will find the necessary phone numbers, email addresses and other ways to contact us.

Seeing

The product works with limited vision and without vision. It requires neither vision nor the ability to perceive colours. There are also alternatives to the visual presentation.

Font, contrast, spacing

Typeface, font size and font style were chosen to be easy to read. Texts and visual content have clearly recognisable contrasts. Texts are displayed with sufficient spacing between letters, lines and paragraphs. This applies to the product housing, the product packaging and also the product instructions.
The presentation of the digital instructions for the product can be customised. You can use the settings in the software and/or in the operating system for this.

Alternatives to colour cues

Colour cues such as status, warnings or information are displayed in such a way that they can also be recognised independently of colour. The instructions explain which alternative ways of perceiving them are available.

Alternatives for non-text content

For content that does not consist of text, there are alternatives that do not require vision.

The product’s ports and controls can be perceived and operated by sight and by touch. In the instructions, all ports and controls are described for at least two different senses.

Magnification

You can enlarge the display of the content in the digital version of the instructions. You can use the settings in the software and/or in the operating system for this.

Operable with a keyboard

You can use and control the digital instructions for the product with an external keyboard. This works for all areas and functions. Navigation follows a meaningful order.
When you select interactive elements, such as links, with the keyboard, they are visually clearly highlighted (focus indicator).

Support for non-visual output via screen reader / braille display

You can operate and output all areas, content and functions of the digital version of the instructions with the screen reader of your mobile device or operating system. This is done either via audio output or tactilely via an externally connected braille display.

Time limits

The product has only a few areas in which time is limited. For example, for security reasons the process of connecting mobile devices to the product (pairing) is only available for a limited time. However, you can restart the process as often as you like if you need more time.

Headings and labels

The product instructions contain meaningful and logically structured headings and labels. The labels on the product itself have also been chosen accordingly.

Links

Links in the digital instructions for the product are easy to recognise and have meaningful labels.

Hearing

The product works with limited hearing and without hearing. It does not require hearing. There are also alternatives for audio content.

Alternatives and settings for audio content

There are alternatives for audio output. For example, there are visual cues for audio signals (status, warnings and other notifications). You can also follow the signals, warnings and other notifications via the product’s app. This makes them perceivable with even more senses. In the app settings, you can turn off the audio output or adjust its volume.

Mobility, reach, strength

The product works with limited mobility. This also applies if you have difficulty reaching things or exerting force. You do not need these abilities to use the product.

Product packaging

The product comes in accessible packaging. The packaging has special tabs, indentations, markings and other accessible opening mechanisms. This means you can open it with little strength and mobility.

Controls

All controls of the product are easy to reach and operate. This applies, for example, to their size, shape, position and spacing. They can be operated with little effort. There are further mechanisms that make operation easier:

• For example, a wrist strap so that the device does not fall down so easily while you operate it.
• The underside of the device has been designed to be particularly stable and wobble as little as possible during operation.
• Particularly sensitive areas, such as the function for resetting to factory settings (reset), are specially protected. This makes it unlikely that they are triggered accidentally. At the same time, there is an operating aid in case you want to trigger this function deliberately.
• The buttons are specially protected so that you do not accidentally trigger functions several times in a short time (for example, if you have a tremor).

No complex or simultaneous movements

Operating the product works without complex, path-based or simultaneous movements.

Time limits

The product has only a few areas in which time is limited. For example, for security reasons the process of connecting mobile devices to the product (pairing) is only available for a limited time. However, you can restart the process as often as you like if you need more time.

Speaking

The product works with limited speech and without speech. It does not require the ability to speak. There are also alternatives that do not require the ability to speak.

Alternatives to speaking

The product itself does not require the ability to speak.
You can also contact our service without speaking. For example, you can send us an email.

Cognitive, mental, neurological, neurodivergent

You can use the product with limited or alternative cognitive, mental or neurological abilities. This also applies if you identify as neurodivergent.

Clear structures

The product has a clear structure.

Labels

The product has meaningful labels.

Understandable texts

The texts on the product and in the instructions are written to be easy to understand.

Avoiding errors

The product has been designed to help you avoid errors.

Correcting errors

The product helps you correct errors.

Animations

The product does not contain any animations.

Light/flash effects

The product does not contain any light or flash effects that could trigger photosensitive seizures.

Time limits

The product has only a few areas in which time is limited. For example, for security reasons the process of connecting mobile devices to the product (pairing) is only available for a limited time. However, you can restart the process as often as you like if you need more time.

Alternatives and settings for audio content

There are alternatives for audio output. For example, there are visual cues for audio signals (status, warnings and other notifications). You can also follow the signals, warnings and other notifications via the product’s app. This makes them perceivable with even more senses. In the app settings, you can turn off the audio output or adjust its volume.

User interfaces and assistive technologies

The product supports the user interfaces and assistive technologies relevant to accessibility. It has the following user interfaces:

• Visual: indicator lights (LEDs) and visual labels/symbols on the product housing as well as visual displays in the instructions and the product’s app
• Auditory: audio signal tones integrated into the product
• Haptic (tactile): tactile controls, ports and symbols on the product housing as well as tactile labels and markings on the product packaging and the printed instructions
• Digital: digital interface via the product’s app, which is accessible to different senses and compatible with assistive technologies

The product has been tested with the following assistive technologies / aids: [insert applicable list here]

Responsible market surveillance authority

Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF, the German federal states’ market surveillance authority for the accessibility of products and services) in Magdeburg (Saxony-Anhalt).

Frequently asked questions

Who wrote the samples?

The samples were written by me, Nina Gerling, in my free time. I am an expert in digital accessibility with over 20 years of experience. This website and all the information on it are my private project.

Is the content derived from EN 301549 or WCAG?

The templates are a compromise: I want the information on accessibility to be of real use to its target group, people with disabilities. There is legally required information that has to be included. For the rest, I follow the usual standards and guidelines. But I don’t mention every detail. Otherwise only people with expert knowledge would understand the text.
I summarise or simplify some details to make them easier to understand. I leave out some points because they are too complicated for laypeople. Instead, there is a summary at the beginning of each sense. It states that the service or product also works if you cannot fully use all your senses.

May I use the samples for the information on accessibility?

I allow their use at your own risk and without any guarantee. I expressly recommend that you adapt the texts to your purposes before using them. You should get advice from experts in digital accessibility for this. You should also have the texts reviewed by legal professionals before publishing or passing them on.

Is it called accessibility statement or information on accessibility?

• The German Accessibility Strengthening Act (Barrierefreiheits-Stärkungs-Gesetz, BFSG) refers to the information on accessibility (Information zur Barrierefreiheit).
• The German Barrier-Free Information Technology Ordinance (Barrierefreie-Informationstechnik-Verordnung, BITV) for public bodies speaks of the accessibility statement (Erklärung zur Barrierefreiheit).

Caution: When people search for this, they often find samples for the BITV or the public sector. However, the requirements differ. Many legal professionals advise against using a BITV template for the BFSG.

That is why I make sure to use the term information on accessibility when it comes to the BFSG. However, it is probably not a problem if the term “statement” (Erklärung) is used instead of “information” (Information).

Are there other samples for the information on accessibility?

Yes, for example I know of this sample by lawyer Dr. Schwenke (in German). I cannot judge whether it meets the legal requirements.
My samples do not claim to be complete, correct or better. They show an alternative approach that puts the information value for disabled people first.

Caution: There are many samples for accessibility statements. These often have a different legal basis.

Could we be affected by both the BFSG and the BITV?

As far as I know, this could happen if a public body acts like a commercial company. For example, by selling products to consumers via a web shop. Or if a bank is largely publicly owned and offers banking services to private individuals. Whether this applies should be checked by legal professionals.

In the cases I know of, legal professionals pointed out that the requirements of both laws apply. In such complicated cases you should definitely get advice. The samples on this website are not suitable for these combinations.

Is the EU declaration of conformity the same as the information on accessibility?

No. The information on accessibility (Information zur Barrierefreiheit, IzB) is not the same as the CE declaration of conformity or the technical documentation. The target group of the information on accessibility is private individuals with disabilities in their role as “consumers”.

The EU declaration of conformity (external link, in German) is one of the prerequisites for a product to bear the CE marking and to be offered for sale. In this declaration, manufacturers describe for many important laws how their product complies with them. The BFSG is also one of these laws. If the market surveillance authority gives reasons and requests it, manufacturers must hand over documents. For example, the mandatory technical documentation according to Annex 2 (Anlage 2) of the BFSG. And probably also proof that they have internally carried out the conformity assessment procedure. With these documents, they prove to the authority that the product meets the legal requirements. You can ask legal professionals for the details.

Do I need a form for reporting barriers?

As far as I know, you do not have to offer such a form. However, I recommend providing an easy-to-find and accessible contact form for this purpose. For example, at the beginning and at the end of the information on accessibility. This way, disabled people can easily report errors they find. Ideally, no lawsuits are then necessary because you fix errors right away.

Do I have to name the standard or guideline we follow?

Opinions differ on this. The law does not prescribe that you meet the requirements with a specific standard or guideline. In theory, you can also meet them in other ways. Some legal professionals recommend that you name the standard or guideline if you meet it. Others advise against it. So get advice from legal professionals for your specific case.

Do we have to do an accessibility test, training, consulting or the like?

The BFSG does not require this. But it often makes sense.
In the sample, I give examples of how a company could proceed. Some legal professionals recommend writing this down. Whether that makes sense for you is something you should clarify in a consultation.

• With training, your employees can learn more about digital accessibility.
• An independent accessibility test helps you know how accessible your offering is.
• Experts in digital accessibility advise on correct implementation. They have experience and know suitable solutions for your field.
• Accessibility is important in all processes. Plan for it firmly from the start. That way it works in the long run and you get good results. It is also usually much cheaper than making things accessible only at the end.
• Automated tests help avoid some errors. But they only find some of the errors. That is why you should also plan manual tests.
• Disabled people deserve more than just basic accessibility. They also want your offering to be pleasant and easy to use. Usability tests with disabled people help uncover problems.

Do we need a certificate for digital accessibility?

The BFSG does not require certification. As far as I know, there is no official certificate that confirms compliance with digital accessibility requirements.

Various companies and organisations offer testing procedures, conformity assessments or certificates they have created themselves. How meaningful they are varies greatly, depending on what is tested, how and by whom.

What should I do if we have barriers?

If the BFSG applies to you, you must meet all legal requirements. If your product or service has barriers, you should first assess them. If necessary, get help from experts in digital accessibility and legal professionals:

• How serious is the problem?
• Can the problem be solved?
• Are the necessary resources available?
• By when will the problem be solved?
• Will the problem be solved before or after the legal deadline? The deadline is June 28, 2025. In some cases there are transition periods.
• Do you want to use an exemption?

If the problem will only be solved after the deadline

To my knowledge, in this case you must notify the market surveillance authority. This also applies to market surveillance authorities in other EU countries in which you offer the product or service. You must describe the problem in detail and state how and when you will fix it. If the authority gives reasons and requests it, you must provide it with further information. You must also cooperate with it.

Legal professionals recommend that you get their advice beforehand. It also makes sense to ask experts in digital accessibility for help. If you describe problems in the information on accessibility, this has legal consequences.

If you want to use an exemption

The law expects you to comply with the legal requirements. However, it allows exceptions in certain cases. For example, if implementing the requirements would lead to a fundamental alteration of the basic nature of the product. Or if implementing the requirements would impose a disproportionate burden on you.

The rules for this are very strict! You then have extensive obligations to justify and document the exception in detail. You must keep and update this information. You must also inform the responsible authority. For products, you must also state the exemption in the EU declaration of conformity.

Important: I strongly recommend that you get thorough advice from legal professionals on this. Please note that you probably cannot be exempted from all accessibility requirements across the board. The exemptions probably only apply to individual requirements.

Note on the market surveillance authority: The authority is currently still being set up. Therefore, to my knowledge, it is not yet possible to contact it. Its official name is Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF, the German federal states’ market surveillance authority for the accessibility of products and services). It is being established in Magdeburg (Saxony-Anhalt).

Should I list unmet requirements in the information on accessibility?

For disabled people, it is very important to know whether there are barriers. It would therefore be helpful for them if problems were openly communicated. As is done, for example, in accessibility statements in the public sector. With the BFSG, however, the situation is more complicated:

Important: As already mentioned, the BFSG expects you to meet all requirements that apply to you. Otherwise you risk fines or stronger measures by the market surveillance authority. In the event of non-compliance, the law also allows lawsuits by disabled people, certain associations and competitors. If you do not meet requirements, this therefore has legal consequences and considerable risks. Get advice from legal professionals on how to deal with this properly. They can advise you on whether you must and should publicly name known barriers in the information on accessibility.

Should the information on accessibility be part of the general terms and conditions?

The law mentions that the information on accessibility could be included in the general terms and conditions (Allgemeine Geschäftsbedingungen, AGB). However, many legal professionals strongly advise against this. As soon as the information is placed in the terms and conditions, additional legal requirements apply to it. That is why many experts recommend publishing it in a different place. For example:

• Websites: An “Accessibility” link could be placed in the footer of the website.
• Software/app: An “Accessibility” link could be added to the key information about the app in the app store. In addition, the link could also be placed directly in the app or software where it is easy to find.
• Hardware product: The information on accessibility could be placed on the product’s website. The link to it could be provided, for example, via a QR code on the product packaging or the device. To make it easy for blind people to find as well, a tactile label (braille or embossed lettering) could also point to it.

In what form should the information on accessibility be published?

The information on accessibility must be clearly perceivable and accessible. For this, I recommend an accessible web page in HTML format. Other formats are also possible, for example an accessible PDF. However, many disabled people say that PDFs are not as usable for them as web pages.

Can I also use the samples in other countries, for example in Austria?

The samples are geared to the German Accessibility Strengthening Act (Barrierefreiheits-Stärkungs-Gesetz, BFSG). However, I assume that large parts of them would also be suitable for the corresponding laws of other EU countries. The reason is that these national versions in the EU countries are also derived from the European Accessibility Act (EAA). But there could be important differences. Get help from experts in digital accessibility. Have the text reviewed by legal professionals who are familiar with the law in your country.

I found a mistake in this guide. How can I tell you?

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Latest notes

• April 23, 2025: Publication of the samples without any claim to completeness / correctness.