The 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.

1. Severity levels of accessibility requirements

The requirements can be divided into the following categories based on the WCAG standards:

• A (basic requirements): Essential accessibility functions without which use would be impossible or very difficult.
• AA (Advanced Requirements): Standard level that ensures largely barrier-free use.
• AAA (highest level of accessibility): Recommended, but not mandatory.

2. Requirements according to urgency levels

A – Basic requirements (mandatory according to BFSG)

1. Text alternatives for non-text content
   • Images, icons, diagrams and other visual content must be provided with alternative text.
   • Text alternatives should describe the purpose of the image and be readable by screen readers.
2. Keyboard operability
   • All functions and interactive elements must be operable without a mouse, only with the keyboard.
   • Focus indicators must be visible and logically navigable through the page.
3. Waiver time restrictions or offer alternatives
   • Content must not automatically disappear after a set time or offer an option to extend/deactivate the time limit.
4. Avoid flickering and flashing
   • Content must not flicker more than three times per second to avoid seizures in epileptics.
5. Accessible documents and forms
   • PDFs and other documents must be correctly structured and usable with a screen reader.
   • Forms must be clearly labeled and usable with assistive technologies.

AA – Extended requirements (recommended and largely mandatory according to BFSG)

1. Color contrasts and readability
   • Minimum contrast ratio of 4.5:1 for normal text and 3:1 for large text.
   • No exclusive use of color to convey information.
2. Responsive design and adaptability
   • Content must not become illegible or unusable when zoomed in or enlarged (up to 200%).
3. Subtitles and audio descriptions for videos
   • All video content must have subtitles and/or audio descriptions.
4. Error messages and notes
   • Clear and understandable information in the event of incorrect or incomplete form entries.
   • Automatic correction suggestions if possible.
5. Flexible layout and easy navigation
   • Navigation must be consistent and intuitive.
   • Multiple ways to find content (e.g. search, sitemap) should be provided.

AAA – Maximum level of accessibility (not mandatory, but recommended)

1. Extended audio descriptions
   • Videos and multimedia content should contain detailed audio descriptions.
2. Advanced contrast settings
   • Contrasts even higher than AA requirements, especially for users with limited vision.
3. Alternative communication methods
   • Provide sign language videos or chats for important content and services.
4. Explanation in simple language
   • Providing plain language versions of the content for people with cognitive disabilities.

3. Conclusion and recommendations for action

Companies should implement at least the requirements of levels A and AA in order to comply with the legal regulations of the BFSG. The implementation of the AAA criteria can further improve user comfort and offers significant advantages, especially for companies with a broad target group.

It is strongly recommended:

• Conduct regular accessibility tests using tools such as WAVE or Lighthouse.
• Provide training for developers, designers and content managers on the topic of accessibility.
• Include users with disabilities in the testing processes to obtain realistic feedback on usability.

With early and strategic planning, companies can not only avoid legal risks, but also increase their digital reach and create a better user experience for everyone.

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”:

1. Accessibility Strengthening Act – Basics (02/13/25)
2. Accessibility Strengthening Act – Audit / Examination (02/20/25)
3. Accessibility Strengthening Act – Requirements Details (02/27/25)