Accessibility Strengthening Act (BFSG) Series 2/3 – Testing and Audit
The Barrier Freedom Strengthening Act (BFSG)Barrier Freedom Strengthening Act (BFSG) sets the European Directive 2019/882 (European Accessibility Act) into German law and obliges companies to make digital and physical products and services barrier-free. This guide shows how companies can optimally prepare, what requirements must be met and how compliance can be ensured.
Companies and public institutions are facing new challenges because they must adapt their products and services to the new legal requirements by June 28, 2025.
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Self-assessment and audit: How barrier-free is your company?
The first step to successfully implementing the BFSG is a detailed analysis of the current accessibility status.
Accessibility check for websites and apps
- Checking the user-friendliness for people with visual, hearing or mobility impairments.
- Ensuring compatibility with screen readers.
- Use of clear and high-contrast design elements.
- Structured content that can be operated using the keyboard.
Test procedures & Tools
To ensure digital accessibility, the following tools can be used:
- WAVE (Web Accessibility Evaluation Tool): Automatic analysis of websites.
- Lighthouse (Google tool): Tests accessibility, performance and SEO.
- BITV test (Barrier-free Information Technology Ordinance Test): Evaluates compliance with German accessibility standards.
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Requirements according to urgency levels
Accessibility requirements are divided into three levels based on the WCAG standards:
A – Basic requirements (mandatory according to BFSG)
- Text alternatives for non-text content: Images, icons and diagrams must be provided with alternative text.
- Keyboard usability: All interactive elements must be usable without a mouse.
- Avoid flickering and flashing: Content must not flicker more than three times per second.
- Accessible documents and forms: PDFs must be structured correctly, forms must be usable with assistive technologies.
AA – Extended requirements (largely mandatory according to BFSG)
- Color contrasts: Minimum contrast ratio of 4.5:1 for normal text.
- Responsive design: Content must not become illegible on Zoom (up to 200%).
- Subtitles and Audio Descriptions: All video content must contain subtitles and/or audio descriptions.
- Error messages and notes: Clear and understandable information in the event of incorrect form entries.
AAA – Maximum level of accessibility (Recommended, but not mandatory)
- Extended audio descriptions for videos
- Sign language videos for important content and services
- Explanations in simple language for people with cognitive disabilities
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Legal framework & Exceptions
Are there exemptions for small businesses?
- SMEs with fewer than ten employees and an annual turnover of less than two million euros may be exempt in certain cases.
- However, it is recommended that voluntary adjustments be made.
How is control and enforcement carried out?
- Authorities can carry out tests and require companies to make improvements.
- Failure to comply may result in fines and other sanctions.
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Tips for companies for early implementation
- Incorporate accessibility as an integral part of the digital strategy.
- Obtain user feedback and integrate it into development.
- Make gradual optimizations instead of a complete change.
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To-do list for companies
- Internal training & Raising awareness: Train employees on the topic of accessibility.
- Assignment of experts: Collaboration with accessibility experts for analysis and optimization.
- Development of a barrier-free strategy: Define accessibility as a long-term corporate goal.
Conclusion
The implementation of the BFSG is not only a legal obligation, but also an opportunity to reach more customers and create a positive user experience. Companies that prepare early not only avoid legal risks, but can also secure competitive advantages through barrier-free offerings.
Do you need support with your websites to make them barrier-free, to check them or would you like to take the opportunity to make your websites more convertible? Contact us here!
Overview of our series of articles “Accessibility Strengthening Act”:
- Accessibility Strengthening Act – Basics (02/13/25)
- Accessibility Strengthening Act – Audit / Examination (02/20/25)
- Accessibility Strengthening Act – Requirements Details (02/27/25)