Which products and services the Accessibility Strengthening Act (BFSG) covers, which transition periods apply, who is exempt – and when PDFs are affected.
From the European Accessibility Act to the BFSG
The European Accessibility Act is Directive (EU) 2019/882 on the accessibility requirements for products and services. Germany transposed it with the Barrierefreiheitsstärkungsgesetz (BFSG, Accessibility Strengthening Act) and the associated ordinance (BFSGV). The requirements have applied since 28 June 2025.
Who does the BFSG apply to – and who not?
The BFSG is aimed at economic operators: manufacturers, importers and distributors of products, and providers of services to consumers. The websites, apps and documents of public sector bodies, by contrast, are governed by disability equality law: at federal level the BGG (Disability Equality Act) and BITV 2.0 (the federal ordinance on accessible information technology), for the federal states and municipalities the respective state law (see BITV 2.0 for municipalities).
There is an overlap where public companies offer consumer services on the market that fall under the BFSG – such as banking services or passenger transport. Whether and to what extent a company is covered must be assessed case by case.
Which products are covered?
- Consumer computer hardware including operating systems
- Self-service terminals: payment terminals, ATMs, ticketing and check-in machines, interactive information terminals
- Consumer terminal equipment for telecommunications and for audiovisual media services with interactive computing capability
- E-readers
Which services are covered?
- Telecommunications services
- certain elements of air, bus, rail and waterborne passenger transport services (such as websites, apps, electronic tickets, travel information)
- Consumer banking services
- E-books and dedicated software
- E-commerce services – typically online shops and booking processes
Transition periods and exemptions
- Products that a service provider was already lawfully using before 28 June 2025 may continue to be used to provide comparable services until 27 June 2030.
- Service contracts concluded before 28 June 2025 may continue unchanged until they expire, but no later than 27 June 2030.
- Self-service terminals in operation before 28 June 2025 may be used until the end of their economically useful life, but no longer than 15 years after being put into service.
- Office file formats published before 28 June 2025 are exempt, as is archived web content that has not been updated since.
Exemption for microenterprises
Microenterprises that provide services are exempt from the accessibility requirements. A microenterprise is one that employs fewer than ten people and has either an annual turnover not exceeding €2 million or an annual balance sheet total not exceeding €2 million. This exemption does not apply to products.
Market surveillance and penalties
Unlike under the BITV, there is market surveillance. For this purpose, the federal states have set up a joint authority by interstate treaty: the Market Surveillance Authority of the Länder for the Accessibility of Products and Services (Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen, MLBF), based in Magdeburg. It is responsible for the whole of Germany; consumers can report barriers to it. The authority can order measures; infringements can be punished with fines of up to €100,000, formal infringements with up to €10,000. In addition, the conciliation body under section 16 BGG is also open for disputes about the accessibility of products and services.
And the PDFs?
The BFSG does not mention PDFs specifically. However, where documents are part of the service, it stands to reason that they must also meet the requirements for accessible information and content – for example account statements and contract documents in online banking, or terms and conditions, contract documents and order confirmations in an online shop. How far this extends in a specific case depends on the service and should be checked legally if in doubt.
Technically, it comes down to the same benchmark as in the public sector: the BFSG links the presumption of conformity to harmonised standards (section 4 BFSG), and in practice the technical reference point for digital services is EN 301 549. Its version V4.1.1, published in September 2026, contains for the first time a separate annex on Directive (EU) 2019/882. For documents, this leads to the WCAG criteria and, in practice, to PDF/UA; details in WCAG 2.2 and EN 301 549 for PDF documents.
Sources:
As of 09/2026. This article gives a general overview and is not legal advice. The statutory and standards texts in force are authoritative; state law may differ in individual cases.