BFSG Website Accessibility Audit Guide for Germany

If your website in Germany sells to consumers, offers online booking, or provides digital services, the BFSG and European Accessibility Act (EAA) are no longer “nice-to-know” topics – they directly affect your legal risk and your revenue. From 28 June 2025, a broad range of digital products and services in the EU must comply with accessibility rules, and Germany has implemented them through the Accessibility Improvement Act (Barrierefreiheitsstärkungsgesetz, BFSG). AccessibleEU +1 For many small and medium-sized businesses, that means one thing: you need a BFSG website accessibility audit in Germany to understand where your site stands against WCAG 2.1/2.2, how much legal exposure you have, and what it will cost to fix accessibility issues. This 2026 guide walks you through the law, scope, audit process, accessibility checklist, legal risk, remediation cost scenarios, and how to turn compliance work into an upgrade of your overall website strategy – instead of a painful last-minute expense.

From "our website works" to "why didn't anyone warn us?"

Picture a typical German SME: you have a website, maybe an online shop or booking form, money is coming in, nobody has ever complained about "accessibility". Then, sometime after June 2025, a regulator, consumer organisation, or a disability advocacy group points out that your digital services are not accessible under the BFSG – and you are suddenly facing deadlines, corrective action orders, and potentially penalties or contract issues.

The uncomfortable truth is this: the European Accessibility Act sets EU-wide requirements for selected products and services, with a hard date of 28 June 2025. National laws like Germany's BFSG must be applicable from that date. Your website and apps are no longer just a marketing asset; they are regulated services with explicit accessibility expectations.

The smart move is not to wait for a complaint. A structured BFSG website accessibility audit Germany gives you a clear map: how far you are from WCAG 2.2 compliance, what your legal risk is, and what remediation cost and timeline you should realistically plan for – before someone else forces the schedule on you.

What the BFSG and EAA actually require – and why your website is in the spotlight

The European Accessibility Act (Directive (EU) 2019/882) requires accessibility for a set of products and services placed on the EU market after 28 June 2025. These include, among others, e-commerce, banking services, e-books, telecom services, and certain digital interfaces like self-service terminals.

Germany implemented this through the Accessibility Improvement Act (Barrierefreiheitsstärkungsgesetz – BFSG). The law has been in force since 2021, but the core accessibility obligations for many digital services become applicable from 28 June 2025.

For a German SME, three points matter:

Scope: BFSG focuses on products and services that can be operated digitally and are offered to consumers – including websites and online shops.
Timing: From 28 June 2025, new and existing consumer-facing websites and online shops must be accessible. There are transitional rules for some existing contracts and use of legacy products, in some cases up to 2030 – but "we'll ignore accessibility until 2030" is a very risky interpretation.
Technical reference: For the digital part, BFSG ultimately relies on the harmonised European standard EN 301 549, which incorporates WCAG 2.1 AA for web and software. New versions are expected to align with WCAG 2.2, so aiming for WCAG 2.2 compliance is the safest target.

In simple terms: if your website or app sells to consumers, handles online contracts, or is a primary channel for your services, you should assume BFSG applies and plan accordingly.

Is your website in scope? A quick self-check for German SMEs

Use this simple test. If you answer "yes" to several of these, a BFSG website accessibility audit in Germany should be on your short-term roadmap:

Does your website offer online purchasing, booking, subscription, or account creation for consumers (B2C)?
Do you operate an online shop, SaaS subscription, or platform where individuals sign up directly?
Do you provide consumer banking, financial services, insurance, travel, or media services online?
Do you have mobile apps or web apps that complement your website (for example, a customer portal or booking app)?
Is your website a core part of your contract with larger B2B clients who themselves must comply with EAA requirements?

If any of these describe your business, you are no longer just managing "UX" – you are managing compliance. An accessibility checklist is useful, but a structured BFSG website accessibility audit is what turns that checklist into a concrete risk and cost picture.

What a BFSG website accessibility audit in Germany actually covers

A professional accessibility audit is not just running a quick automated scan. It's a structured assessment of your BFSG website against WCAG 2.1/2.2, EN 301 549, and EAA-oriented expectations.

Typical components:

Scoping and prioritisation

The audit first defines:

Which user journeys are "mission-critical" (homepage, category pages, product/service pages, registration, login, checkout, booking, contact forms, dashboard, etc.).
Which platforms are in scope: main website, mobile site, web app, mobile apps, PDFs or other downloadable content.
Whether the goal is pure compliance or strategic improvement (for example, integrating accessibility with a redesign or SEO strategy).

This step is where accessibility meets your overall website strategy. If you are planning a redesign or a new site build, it makes sense to align with how you structure costs and services.

Automated testing

Specialised tools crawl your site to flag:

Obvious code issues (missing labels, invalid ARIA attributes, incorrect heading levels)
Contrast problems between text and background
Missing or empty alt text for images
Structural issues like duplicate IDs or missing form associations

This gives a quick first picture, but automated tools typically capture only a fraction of real accessibility problems and are not enough for EAA compliance on their own.

Manual testing: keyboard, screen reader, and realistic user flows

The decisive part of a BFSG website accessibility audit is manual testing:

Keyboard navigation: Can a user complete all key tasks (navigation, forms, checkout) using only the keyboard? Is keyboard focus always visible and logical, or does it jump unpredictably? EN 301 549 contains explicit requirements on focus order and operability.
Screen reader experience: How do headings, landmarks, form labels, and dynamic updates sound with assistive technologies? Are error messages announced properly?
Forms and validation: Are fields properly labelled? Are errors shown clearly, in plain language, with guidance on how to fix them?
Dynamic content (modals, accordions, SPAs): Does focus move correctly when pop-ups open and close? Are changes announced?
Mobile behaviour: On phones and tablets, can users comfortably tap elements? Are menus and buttons usable on small screens?

Mapping findings to WCAG 2.2 and EN 301 549

All issues are then mapped to specific WCAG success criteria (2.1 and 2.2) at level A/AA and to EN 301 549 clauses where relevant.

For you as a business owner, this mapping matters for two reasons:

It shows how close you are to WCAG 2.2 compliance – a strong indicator of EAA/BFSG alignment.
It provides a defensible basis if you ever need to demonstrate due diligence to regulators or large clients.

Reporting, legal risk view, and remediation cost estimates

A useful BFSG website accessibility audit doesn't drown you in technical jargon. It should clearly present:

A prioritised list of issues: critical, high, medium, low.
For each, a short explanation of the impact on users and potential legal risk.
An estimate of remediation cost (for example, development days per category of issue).
A phased roadmap: what to fix immediately to reduce legal risk, what to align with a redesign, what to include in ongoing maintenance.

If you plan to rebuild your site or add major features, aligning these findings with the real timeline for building a website prevents nasty surprises later.

A practical accessibility checklist for your website

Here is a simplified accessibility checklist written for owners and managers – not just developers. It is not a full EN 301 549 or WCAG 2.2 compliance checklist, but it will quickly show whether you're in dangerous territory.

Structure and headings

Each page has a single clear H1 that matches the main topic.
Headings follow a logical order (H2, H3, …) rather than just "big text for design".
A screen reader user can jump through headings and understand the content structure.

Contrast and visual clarity

Text has sufficient contrast against its background; light grey on white is almost always a problem.
Buttons and links are clearly distinguishable not only by colour but also by shape or style.
On mobile in daylight, your content remains readable without zoom.

Keyboard navigation

You can navigate your entire site using only the keyboard (Tab, Shift+Tab, Enter, Space).
The focus indicator is always visible and never disappears against the background.
Menus, dropdowns, modals, and carousels are fully usable without a mouse.

Forms and checkout

Every input has a descriptive label, not just placeholder text.
Error messages explain in plain language what went wrong and how to fix it.
Errors are announced to assistive technology and clearly linked to the fields.

Images, icons, and multimedia

Important images and icons used as controls (for example, an "edit" pencil) have appropriate alt text or accessible names.
Purely decorative images are marked so screen readers can skip them.
Videos have captions; audio content has transcripts when needed.

Mobile-first, not desktop-shrunk

Your mobile layout is designed intentionally, not just a squashed desktop version.
Tap targets are large enough and spaced properly; no "tiny text link in the footer" as your main CTA.

Accessibility statement (accessibility declaration)

Your site has an accessibility statement that clearly explains: current status, target standard (for example, WCAG 2.2 AA), known gaps, planned improvements, and a contact channel for reporting problems.

If several of these points are unclear or clearly failing, a structured BFSG website accessibility audit Germany becomes less a "nice to have" and more a risk management necessity.

Legal, commercial, and brand risk – what happens if you ignore BFSG?

Legal risk

From mid-2025 onwards, BFSG requirements are enforced by market surveillance authorities of the German federal states. They can require corrective actions and, in case of non-compliance, restrict or prohibit the provision of products and services or impose other measures.

In practice, this means:

You might be ordered to fix your website or app within a specific timeframe.
In severe cases, certain services can be restricted or taken off the market until they are accessible.

Commercial risk

Even if you never receive a formal order, accessibility is increasingly written into contracts and RFPs:

Larger B2B clients (banks, public bodies, large enterprises) must themselves comply with EAA/BFSG and will expect you to provide evidence of accessibility.
A missing accessibility statement or the absence of a credible audit report can cost you tenders and strategic contracts.

Brand and PR risk

Accessibility is not only a technical matter; it is a reputation issue. As enforcement ramps up and media awareness grows, non-accessible services are increasingly seen as exclusionary. Enforcement bodies and public communication around accessibility issues will make examples of well-known brands.

An SME that can show an honest accessibility statement, a recent BFSG website accessibility audit, and transparent remediation in progress sends a very different message than a company trying to "hide" the issue until someone complains.

Remediation cost and process: what should you expect?

The remediation cost (the cost to fix accessibility issues) depends heavily on your current setup. Still, three practical scenarios can help you estimate:

Scenario 1: Small corporate website (brochure site + simple forms)

Typical profile: 5–15 key pages, a contact form, maybe a basic blog.
Common issues: heading structure, contrast, missing alt text, keyboard focus problems, problematic form error handling.
Remediation: if your CMS and theme are reasonably modern, many issues can be fixed at template level. For a small site, remediation can often be done in days to a few weeks of developer and content work.

Scenario 2: SME website with blog, multiple languages, richer forms

Typical profile: corporate site, several service/product pages, active blog, multiple languages, lead-generation forms.
Common issues: inconsistent components, legacy pages, complex menus, more forms and CTAs, translation impacts on layout and contrast.
Remediation: often includes redesigning components (buttons, forms, navigation) to be both modern and accessible. The work is usually organised into several sprints over a few weeks.

This is where the difference between cheap and professional web design becomes very visible: the more "quick hacks" your current site has, the more expensive remediation will be.

Scenario 3: Online shop or complex platform with checkout and dashboards

Typical profile: e-commerce, booking platforms, customer portals, subscription services.
Common issues: complex checkout flows, authentication, dashboards, filters, modals, dynamic content, and integration of third-party widgets.
Remediation: usually a multi-phase project, combining frontend refactoring, UX re-work, adjustments in backend error handling, and sometimes replacement of non-compliant third-party components.

In all three scenarios, timing matters. The closer you get to enforcement and contract deadlines, the less negotiation power you have on cost and scope. Starting with a BFSG website accessibility audit early allows you to integrate remediation into a normal development roadmap, instead of paying "emergency" prices.

Turning BFSG compliance into a strategic website upgrade

If you only treat BFSG and EAA as a "legal problem", you will do the bare minimum and still feel the pain. If you connect accessibility to your overall website strategy, you can turn the same budget into multiple wins.

Connect with UX and lead generation

Many classic corporate website mistakes – cluttered navigation, poor contrast, confusing forms – are both UX problems and accessibility violations. Fixing them improves conversion and compliance in one move.

Define what "modern web design" really means

A truly modern website in 2026 is not just visually trendy; it is resilient, fast, responsive, and accessible. Modern UX patterns (clear hierarchy, generous spacing, predictable interactions) map surprisingly well to WCAG 2.2 principles.

Fix your content foundations

Accessibility is not only about code. It's also about content: clear headings, understandable language, consistent calls-to-action, and well-structured pages. The same elements are crucial for SEO and for turning visitors into leads.

Plan for ongoing maintenance

Accessibility is not a one-off project. Each new landing page, feature, or redesign can introduce new issues. Building accessibility checks into your monthly website maintenance packages is far cheaper than periodic firefighting.

Action plan: how a German SME should approach BFSG website accessibility

Confirm your exposure

Map your digital services: website, apps, portals, online shops, self-service tools.
Check whether they fall into EAA/BFSG product and service categories (e-commerce, banking, telecom, media, etc.).

Run an internal quick check

Use the accessibility checklist above to identify obvious problems with contrast, keyboard navigation, forms, and mobile.
Flag everything you cannot confidently assess – that's exactly what the professional audit is for.

Commission a BFSG website accessibility audit Germany

Define the scope (which journeys, which platforms).
Request an audit that covers both automated and manual testing, mapping to WCAG 2.2 and EN 301 549, and that gives you remediation cost estimates and a phased roadmap.

Align remediation with your web roadmap

Decide whether to fix issues in place, combine them with a redesign, or plan a new website that is WCAG 2.2 compliant by design.
Use resources on cost, timelines, and modern design to shape a realistic and business-driven plan instead of a purely technical one.

Publish an accessibility statement and start ongoing monitoring

Create and maintain an accessibility statement that honestly describes your status, standard, and plans.
Build accessibility checks into your maintenance cycles so new issues are caught early.

Done this way, BFSG & EAA compliance is not just about avoiding penalties; it becomes a way to upgrade your website from "works for most people most of the time" to "works reliably for everyone – and helps your business win and keep better customers."

FAQ – BFSG website accessibility audit Germany (2026)

Q1: When do I really have to comply with the European Accessibility Act and BFSG?

A: The EAA requires national measures to apply from 28 June 2025. Germany's BFSG follows this timeline: for many consumer-facing digital products and services, accessibility requirements apply from that date, with some transitional rules for existing contracts and products until 2030.

Q2: What exactly is a "BFSG website accessibility audit Germany"?

A: It's a structured audit of your website (and optionally apps and digital content) against WCAG-based requirements used by EN 301 549, focusing on EAA/BFSG obligations. It includes automated scans, manual testing (keyboard, screen reader, mobile), mapping to WCAG 2.1/2.2, and a report with prioritised issues, legal risk notes, and remediation cost estimates.

Q3: Are automated accessibility tools enough to be compliant?

A: No. Automated tools are valuable but limited; they cannot reliably test keyboard navigation, focus handling, error messaging, or the real experience of users with disabilities. For EAA/BFSG compliance, regulators and serious clients will expect evidence of manual testing and a holistic approach, not just a tool report.

Q4: Who enforces BFSG and what can they do if my website is not accessible?

A: Market surveillance authorities of the German federal states enforce BFSG, supported by national coordination. They can demand corrective measures and, in case of ongoing non-compliance, restrict or prohibit provision of products and services on the German market.

Q5: How high are the remediation costs for a typical SME website?

A: It depends on complexity, technology stack, and current code quality. Small corporate sites can often be remediated within days or a few weeks; complex shops and platforms usually need multi-phase projects. Integrating accessibility into planned redesigns and maintenance contracts generally reduces cost compared to last-minute fixes on legacy systems.

Q6: Do micro-enterprises get an exemption from BFSG?

A: The EAA and BFSG include concepts like "disproportionate burden" and simplified procedures for micro-enterprises in certain cases, but this is narrow and does not mean "no accessibility needed." Even if you can partially rely on such provisions, you still face competitive and reputational pressure: customers and partners increasingly expect accessible digital services.

Q7: Do I need a separate accessibility statement on my website?

A: While the exact format may vary, best practice under EAA-aligned regimes is to have a clear accessibility statement explaining your status, target standards, exceptions, and contact mechanism. Templates for BFSG-oriented accessibility statements already exist and are recommended as part of showing good faith and transparency.

Q8: What is the best time to start a BFSG website accessibility audit in Germany?

A: The best time is before regulators or major clients ask questions. Practically, that means starting your audit as soon as possible after mid-2025, and ideally tying it to a website improvement or redesign cycle. This lets you negotiate realistic timelines, control remediation cost, and use accessibility as a competitive advantage rather than a last-minute obligation.

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BFSG & European Accessibility Act: Website Accessibility Checklist for German SMEs (Audit, Cost, Process) (2026 Guide)