Accessibility Strengthening Act (BFSG)

BFSG Check: Clarify scope, then technical next steps

The BFSG has been in force since 28 June 2025 for many digital B2C offerings. Our check helps you narrow down whether your offering typically falls in scope — and which technical tests (WCAG/EN 301 549) are useful next. Not legal advice.

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BFSG Scope

Website Check

WCAG 2.1 AA

Next Steps

The free questionnaire provides an initial estimate based on your answers. This guide explains scope and the technical steps that follow.

Open the BFSG questionnaire

Background

Why You Must Clarify BFSG Scope First

The BFSG has been in force since 28 June 2025. An unclear classification leads to wasted effort or gaps in technical testing.

In force since 28 June 2025

The BFSG covers the consumer products and services listed in § 1. Also check the transitional provisions in § 38; the date alone does not determine whether your offering is in scope.

Reduce barriers, spend effort where it matters

A guided check helps you invest effort where your offering typically falls in scope — and reduce barriers for visitors with disabilities.

Precise Resource Allocation

The exemption in § 3(3) concerns micro-enterprises providing services. Under § 2(17): fewer than ten employees and annual turnover or a balance-sheet total of no more than EUR 2 million. This is not a blanket exemption for products.

Sources for scope assessment

Checked on 1 October 2026

Scope of Check

What Factors Determine BFSG Applicability

Applicability is not just determined by your homepage, but by the entire nature of your digital operations.

Consumer Services (B2C)

Verifies whether your digital service directly targets consumers, as pure B2B marketing sites are generally not directly subject to BFSG obligations.

E-Commerce & Bookings

Checks whether your offering is aimed at concluding a consumer contract. Record what customers book or buy and which contract the flow concerns.

Customer Portals & Logins

A login alone does not determine scope. Classify the underlying service first, then list its authenticated user flows for technical testing.

Media, Telecom & Transport

Covers specific EAA/BFSG categories such as telecommunications, electronic books (e-books/software), and digital ticket or travel booking platforms.

Target Audience

Who Needs a Scope Assessment

Different departments face distinct web accessibility goals. The BFSG check ensures clear, cross-functional alignment.

SMBs & Founders

Gather details about your offering, audience, and the micro-enterprise criteria. The check supports an initial assessment; take unresolved legal questions to a qualified adviser.

E-Commerce Teams

Learn whether your checkout flows, product filtering, cookie banners, and payment methods must comply with BFSG/WCAG standards.

SaaS Product Teams

Determine if customer-facing web apps and subscription platforms fall under the guidelines of the European Accessibility Act.

Web Agencies

Use the scope check as a standardized first step in client consulting to clarify technical next steps before design work starts.

Compliance & Legal Teams

Establish a documented risk assessment as the base layer for generating your statutory accessibility statement.

Common Scenarios

Typical Cases in BFSG Evaluation

Accessibility obligations often hinge on specific details of your digital service. Here are typical practical examples.

E-commerce Shop with B2C Checkout

Typical Case: Sells physical or digital goods directly to consumers.

BFSG Relevance: A typical case of electronic commerce services (§ 1(3), point 5). Check possible exemptions. For the audit, list product selection, cart, checkout, and payment.

Pure B2B Marketing Site

Typical Case: Presents company details without online booking or contract signing.

BFSG Relevance: A company presentation without a consumer-contract process is not in scope solely because it is a website. Assess additional services separately; other obligations may apply.

SaaS Customer Portal (B2C)

Typical Case: Allows consumer end-users to manage subscription plans online.

BFSG Relevance: Not every SaaS portal is automatically covered. The underlying service determines scope. For a covered service, include login, contract management, and forms in technical testing.

Service Business with Booking Flow

Typical Case: Enables consumers to schedule and pay for appointments online.

BFSG Relevance: Check whether the booking process is aimed at a consumer contract (§ 2, point 26). An appointment form alone is not enough to classify scope. Document the contract flow and possible exemptions.

Roadmap

From scope check to technical testing — 6 steps

Clarifying applicability is the first step. Here is how to structure the technical follow-up.

1. Clarify BFSG Applicability

Use the BFSG check to verify if your company, website, or mobile application is legally subject to the Act.

2. Map Out Critical User Flows

Identify which pages and interactive states (e.g. cookie consent, account settings, search filters) are critical to test.

3. Launch Technical WCAG Audit

Run a comprehensive WCAG 2.1 AA audit to pinpoint technical accessibility barriers in your source code.

Technical testing with Audit

4. Remediate & Fix Issues

Address code issues like keyboard traps, contrast ratios, and screen reader labels using precise developer guides.

Test and fix in your IDE

5. Publish Accessibility Statement

Document the current status and compile a structured accessibility statement draft for your website.

Create a statement draft

6. Score history & alerts in Audit

Compare current and earlier findings in Audit. Recheck the same pages and user flows after releases, and use alerts as a prompt to investigate regressions.

To Audit · Alerts & score history

The navable Platform

How navable Extends the BFSG Check

navable is more than a simple scope checker — it connects technical audits and documentation in one workflow.

BFSG Check & Scope

Begin by clarifying the applicability of the law to your digital assets and highlighting key timelines.

Automated Auditing

Scan protected login panels, cookie banner overlays, and dynamic UI elements for WCAG 2.1 AA criteria.

Accessibility Statement

Use our AI generator to compile a fully updated accessibility statement directly from your audit records.

Score history & alerts

Compare audit results over time. Use alerts to identify changes and investigate the affected findings in Audit.

Frequently Asked Questions about the BFSG Check

Your specific offering and the products and services listed in § 1 BFSG determine scope. Micro-enterprises providing services have the exemption in § 3(3). The criteria in § 2(17) are fewer than ten employees and annual turnover or a balance-sheet total of no more than EUR 2 million. This is not a blanket exemption for products.

An informational website is not covered solely because it is a website. Check whether it offers a service listed in § 1 BFSG or enables a consumer contract. Record these functions separately. Accessibility also helps visitors when a BFSG obligation does not apply.

The BFSG Check helps you gather details about your offering, audience, and business size for an initial assessment. A technical audit looks for specific barriers in selected pages and states. Automated findings replace neither a legal assessment nor complementary manual checks.

No. The check provides orientation and points to technical audits and documentation. It makes no binding legal decision and guarantees neither conformity nor freedom from liability. Record unresolved questions about your offering, contracts, and exemptions, and consult a qualified adviser when needed.

Yes. If your service or shop falls in scope, you are legally required to publish an Accessibility Statement (Barrierefreiheitserklärung) documenting your compliance level since June 28, 2025.

Yes. If the underlying service itself falls in scope, all related interfaces—including customer portals, settings, and payment details behind a login wall—must be accessible.

References

Standards and Official References

Use these official resources and guidelines to deepen your compliance knowledge.

WCAG 2.1 Quick Reference (W3C)WCAG Evaluation Methodology (WCAG-EM)German Federal Office for Accessibility (BFSG)MDN Web Docs Accessibility Guide

Act Now

Clarify Your BFSG Scope Today

Since the law is already in force, start with our free BFSG Check — then continue to Audit and a statement draft.