Compliance · BFSG · WCAG 2.2 AA
BFSG: Make your website accessible — without missing the law.
The Barrierefreiheitsstärkungsgesetz has been in force since 28 June 2025. First Abmahnungen are already circulating. We audit your site, deliver a written WCAG 2.2 AA report, and remediate in 14 days at fixed price.
TL;DR
- ·BFSG covers e-commerce, banking, ticketing, transport, telecoms — but the safe assumption is "your site too" if you sell online.
- ·WCAG 2.2 Level AA is the technical standard. 50 success criteria across perceivable / operable / understandable / robust.
- ·Fines: up to €100,000 per violation. Verbraucherzentralen and competitors can both file Abmahnungen.
- ·Our delivery: 7-day audit (€2,400) → 14-day fixed-price remediation → Erklärung zur Barrierefreiheit + ongoing monitoring.
Who actually has to comply?
BFSG applies to digital products and services sold to consumers (B2C) — including online shops, banking apps, ticketing platforms, e-book readers, transport platforms, and any digital service provided in the course of commerce. Micro-enterprises (under 10 employees AND under €2M turnover) are exempt for services but not for products. If your site sells anything to consumers, assume you are in scope.
What WCAG 2.2 AA actually requires
WCAG 2.2 has 86 success criteria total. Level A is 30, Level AA is 50, Level AAA is 86. The legal standard is AA. Common gaps we find on real audits:
- —Color contrast ratios below 4.5:1 for body text and 3:1 for large text
- —Form fields missing visible labels and aria-describedby for errors
- —Focus indicators removed by CSS reset and never replaced
- —Image alt text either missing or set to filename ("IMG_7878")
- —Skip-to-content link missing or not visually exposed on focus
- —Modals that trap focus permanently or release it incorrectly
- —Video content with no captions or transcript
- —Dynamic content updates not announced via aria-live
- —Touch targets smaller than 24×24 CSS pixels (WCAG 2.2 new)
- —Cognitive load: forms that auto-submit or aggressive timeouts
What enforcement actually looks like
Three risk vectors. First: BaFA / Marktüberwachungsbehörden can issue fines up to €100,000 per violation. Second: Verbraucherzentralen are filing Abmahnungen — published amounts so far range €595–€2,500 plus remediation. Third: After BGH I ZR 186/17 (27 March 2025), competitors can file UWG-Abmahnungen for GDPR violations, and the same logic is being tested for BFSG. Don't bet on the third remaining theoretical.
How we run a BFSG project
- 01
Audit (7 days): manual + automated WCAG 2.2 AA evaluation across 12+ representative pages. Output: written report scored by criterion, severity-ranked.
- 02
Remediation plan: fixed-price quote against the report. Critical issues prioritized. Sign-off before work starts.
- 03
Build (10–14 days): code-level fixes deployed to staging. Daily progress on Slack.
- 04
Verification audit: re-run WCAG check, NVDA + VoiceOver pass, real keyboard-only walkthrough.
- 05
Erklärung zur Barrierefreiheit: legally required accessibility statement, drafted and published.
- 06
Monitoring: optional retainer (Operator tier) includes monthly automated WCAG sweeps + quarterly manual review.
BFSG — frequently asked questions
Do micro-enterprises need to comply?+
Companies under 10 employees AND under €2M annual turnover are exempt for services. Products are still in scope regardless of size. If you sell physical or digital products to consumers, assume in scope.
What is the difference between BFSG and WCAG?+
BFSG is the German law (in force 28 June 2025). WCAG 2.2 AA is the technical standard the law references via EN 301 549. You comply with BFSG by meeting WCAG 2.2 Level AA on every consumer-facing digital surface.
Is an Erklärung zur Barrierefreiheit mandatory?+
Yes — every covered website must publish a public accessibility statement linking to a feedback mechanism. We draft it as part of remediation.
Can I just install an overlay tool?+
No. AccessiBe / UserWay / Equalize and similar overlay scripts have been ruled inadequate by multiple US courts and German legal commentary. They mask access issues without fixing them and frequently break screen readers. We never use them.
How long does a typical BFSG audit + remediation take?+
7 days audit + 10–14 days remediation = ~3 weeks end-to-end for a typical marketing site or e-commerce store. Larger platforms (50+ pages, custom UI components) can run 4–6 weeks.
How much does it cost?+
Audit only: €2,400 fixed price. Audit + remediation: typically €4,500–€18,000 depending on site size and number of issues. Configure exact pricing in the calculator.