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2026-06-02•8 min read•navable Team•
BFSG ChecklistWCAG 2.1EN 301 549Business AccessibilityBFSG

BFSG Checklist: How to Implement Website Accessibility for Your Business

Since June 28, 2025, the Barrierefreiheitsstärkungsgesetz (BFSG) – Germany's Accessibility Strengthening Act – applies to many digital products and services. For businesses, this means: accessibility is no longer just a UX or SEO concern, but an operational and legal obligation.

This BFSG Checklist covers what businesses should be checking right now – from WCAG-based website requirements and EN 301 549 compliance to documentation, accessibility statements, and ongoing monitoring.

1. Does the BFSG Apply to My Business?

The BFSG implements the European Accessibility Act (EAA) into German law and primarily affects digital products and services aimed at consumers. It's relevant for:

✔ E-commerce and online shops – Web stores, booking portals, and digital marketplaces

✔ Banking services – Online banking, financial apps, and digital payment services

✔ Telecommunications services – Websites and apps from electronic communications providers

✔ E-books and digital media – Publishers and platforms with digital content

✔ Passenger transport – Digital booking and information services in transportation

Microenterprises (fewer than 10 employees and max. €2M annual turnover) providing services may be exempt under certain conditions. This exemption does not apply to products. When in doubt, seek individual legal advice.

2. Which Standards Apply: BFSG, EN 301 549, WCAG 2.1, and WCAG 2.2

The interplay of standards can be confusing at first. Here's how they relate:

✔ BFSG + BFSGV – The law and its implementing regulation define what must be accessible and which requirements apply.

✔ EN 301 549 – The harmonized European standard specifies the technical requirements. For web content, it essentially references WCAG 2.1 Level AA.

✔ WCAG 2.1 Level AA – The core technical reference framework for websites in Germany. 78 success criteria across four principles: Perceivable, Operable, Understandable, Robust.

✔ WCAG 2.2 – Official W3C standard since October 2023 with 9 additional success criteria. Not yet formally referenced in the BFSG, but recommended as best practice and future-proofing.

3. The 10 Most Important BFSG Checkpoints for Websites

Perceivability

✔ Alternative text for all non-text content – Images, icons, graphics, and videos need meaningful text alternatives that screen readers can announce.

✔ Sufficient color contrast – At least 4.5:1 for normal text and 3:1 for large text as well as UI components and graphical objects (WCAG 1.4.3, 1.4.11).

✔ Reflow and responsive design – Content must be usable at 320px width without horizontal scrolling (WCAG 1.4.10). Text spacing must be adjustable without loss of information.

✔ Captions and audio description – Videos need captions; pre-recorded video content should offer audio description.

Operability

✔ Full keyboard accessibility – All functions must be reachable and operable without a mouse. No keyboard trap risk (WCAG 2.1.1, 2.1.2).

✔ Visible focus indicator – Interactive elements must have a clearly recognizable focus state so keyboard users know where they are.

✔ Consistent, understandable navigation – Navigation mechanisms must be predictable. Skip links, landmarks, and a logical tab order make orientation easier.

Understandability

✔ Clear forms with error messages – Labels, input instructions, and understandable error messages with correction suggestions (WCAG 3.3.1–3.3.4).

✔ Consistent naming and language – Page language is declared in HTML, controls are consistently named.

Robustness

✔ Valid HTML and ARIA – Clean code that assistive technologies can correctly interpret. Name, role, and value are programmatically determined (WCAG 4.1.2).

4. What Businesses Often Forget: Documentation, Statements, Evidence

Implementing accessibility is one part – documenting it verifiably is another. Authorities and market surveillance expect traceability:

✔ Publish an accessibility statement – Businesses must provide a publicly accessible statement on the current state of accessibility. It should include known limitations, planned measures, and a feedback mechanism.

✔ Set up a feedback channel – Users must be able to report barriers. The channel itself must be accessible.

✔ Document measures and timeline – Show that you're actively working on improvements. A documented roadmap with prioritization strengthens your position in case of complaints.

✔ § 17 BFSG – Disproportionate burden – Under certain conditions, businesses can claim disproportionate burden. Prerequisite: you must demonstrate that you've made genuine efforts toward accessibility. Without documentation, no proof.

5. Quick Wins for Today

These measures can be implemented quickly and have immediate impact:

✔ Add alt texts – Check all images for meaningful alternative texts. Decorative images get an empty alt="".

✔ Check contrasts – Use the navable Contrast Checker to identify critical color combinations.

✔ Enable focus styles – Make sure outline hasn't been removed via CSS. A visible focus indicator is mandatory.

✔ Link form labels – Every input field needs a programmatically associated label (via for/id or wrapping <label>).

✔ Set page language – Declare <html lang="de"> (or appropriate language) in the document.

✔ Check heading hierarchy – Only one H1 per page, then H2, H3, etc. without skipped levels.

6. How Automated Audits and Monitoring Help

Automated tools identify most of the WCAG 2.1 AA violations – providing a solid foundation for systematic improvement:

✔ Regular audits – Automated scans uncover technical barriers often missed during manual checks. Tools like axe-core test against WCAG criteria.

✔ Prioritization by severity – Not all violations are equally critical. A good audit tool prioritizes by user impact and compliance risk.

✔ Dev-ready fix prompts – Modern audit platforms deliver concrete guidance developers can act on directly – such as copy-prompts for AI-powered IDEs.

✔ Monitoring over time – Accessibility isn't a one-time project. New content, redesigns, or plugin updates can cause regressions. Regular monitoring catches these early.

✔ Compliance documentation – Audit results and progress reports serve as evidence for market surveillance and support your accessibility statement.

With the navable Accessibility Audit, you can automatically scan your website, prioritize violations, and document progress over time. Combined with the navable Statement Generator, you can create a compliant accessibility statement based on your actual audit results.

Sources

FAQ – Frequently Asked Questions about the BFSG Checklist