EAA Check: Does my website need to be accessible?

The European Accessibility Act has applied since June 28, 2025 (implemented in Germany as the BFSG). Answer three short questions to get an initial assessment of whether your website is affected – free and without registration.

The legal texts

Germany's Barrierefreiheitsstärkungsgesetz (BFSG, Accessibility Strengthening Act) transposes EU Directive 2019/882 – the European Accessibility Act (EAA) – into national law. The EAA quotations below are taken verbatim from the official English language version published on EUR-Lex. The BFSG is only legally binding in German, so its provisions are summarised here in English with exact section references.

BFSG: Scope

Section 1(2) BFSG lists the products covered by the Act – including consumer computer hardware and operating systems, self-service terminals such as ATMs and ticketing machines, interactive consumer terminal equipment and e-readers – provided they are placed on the market after 28 June 2025. (Paraphrase; authoritative text in German: § 1 Abs. 2 BFSG.)

Section 1(3) BFSG lists the covered services provided to consumers after 28 June 2025: telecommunications services, certain elements of passenger transport services, consumer banking services, e-books and dedicated software, and – decisive for websites and online shops – services in electronic commerce ("Dienstleistungen im elektronischen Geschäftsverkehr", § 1 Abs. 3 Nr. 5 BFSG). In practice this covers virtually any online sales or booking process aimed at consumers. (Paraphrase; authoritative text in German.)

BFSG: What "accessible" means

Section 3(1) BFSG contains the central obligation: products placed on the market and services offered or provided by an economic operator must be accessible. It defines products and services as accessible when persons with disabilities can find, access and use them in the customary manner, without particular difficulty and, as a rule, without assistance from others (§ 3 Abs. 1 BFSG). The detailed technical requirements are laid down in a statutory ordinance based on Annex I of Directive (EU) 2019/882. (Paraphrase; authoritative text in German.)

BFSG: Exemption for microenterprises

Section 3(3) sentence 1 BFSG exempts microenterprises that offer or provide services from the accessibility obligation of Section 3(1). The exemption applies only to services, not to placing products on the market (§ 3 Abs. 3 Satz 1 BFSG). Section 2 no. 17 BFSG defines a microenterprise as an enterprise which employs fewer than 10 persons and which has either an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million (§ 2 Nr. 17 BFSG). (Paraphrase; authoritative text in German.)

BFSG: Fines

Violations are administrative offences. Under Section 37(2) BFSG, offering or providing a non-compliant service (Section 37(1) no. 8 in conjunction with Section 14(1) BFSG) can be punished with a fine of up to EUR 100,000; other listed infringements, mostly information and documentation duties, with a fine of up to EUR 10,000 (§ 37 Abs. 2 BFSG). (Paraphrase; authoritative text in German.)

The European basis: Directive (EU) 2019/882 (EAA)

The Directive's scope matches that of the BFSG – e-commerce services are expressly covered:

"Without prejudice to Article 32, this Directive applies to the following services provided to consumers after 28 June 2025:"

1. electronic communications services;
2. services providing access to audiovisual media services;
3. certain elements of passenger transport services (air, bus, rail, waterborne);
4. consumer banking services;
5. e-books;
6. "e-commerce services."

Art. 2(2) Directive (EU) 2019/882

Article 4 obliges the Member States to enforce the accessibility requirements of Annex I:

"Member States shall ensure, in accordance with paragraphs 2, 3 and 5 of this Article and subject to Article 14, that economic operators only place on the market products and only provide services that comply with the accessibility requirements set out in Annex I."

Art. 4(1) Directive (EU) 2019/882

The exemption for microenterprises providing services is already laid down in the Directive itself:

"Microenterprises providing services shall be exempt from complying with the accessibility requirements referred to in paragraph 3 of this Article and any obligations relating to the compliance with those requirements."

Art. 4(5) Directive (EU) 2019/882

Recital 70 explains why: for microenterprises, even the proportionality assessment itself would be a disproportionate burden.

"The requirements and obligations of this Directive should therefore not apply to microenterprises providing services within the scope of this Directive."

Recital 70 Directive (EU) 2019/882

Deadlines and transition until 2030

Article 31 required the Member States to adopt their transposition laws by 28 June 2022 – and fixes the date from which they apply:

"They shall apply those measures from 28 June 2025."

Art. 31(2) Directive (EU) 2019/882

Article 32 grants a transitional period: products already in use and existing service contracts are protected – at the longest until 28 June 2030:

"Without prejudice to paragraph 2 of this Article, Member States shall provide for a transitional period ending on 28 June 2030 during which service providers may continue to provide their services using products which were lawfully used by them to provide similar services before that date. Service contracts agreed before 28 June 2025 may continue without alteration until they expire, but no longer than five years from that date."

Art. 32(1) Directive (EU) 2019/882

For self-service terminals, Article 32(2) of the Directive permits continued use until the end of their economically useful life, but no longer than 20 years after their entry into use.

Official sources

• Barrierefreiheitsstärkungsgesetz (BFSG), full text in German – gesetze-im-internet.de
• Directive (EU) 2019/882 (European Accessibility Act) – EUR-Lex, English language version
• German Federal Agency for Accessibility (Bundesfachstelle Barrierefreiheit): information on the BFSG (German)

Frequently asked questions about the EAA

Learn more

You can find detailed background in our knowledge base: The European Accessibility Act: who must comply, and by when? , The EAA across Europe and How to test your website for accessibility.