The German Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) has been in force since 28 June 2025. It transposes the European Accessibility Act into national law and obliges companies to offer certain digital services in an accessible form. For many businesses the topic stayed abstract for a long time – until a tender asked for an accessibility statement, or a customer reported that the contact form could not be completed with her screen reader. This article sets out who falls within scope, which WCAG 2.2 AA requirements actually decide the outcome in day-to-day use, and how a credible accessibility statement is structured. It closes with a working list you can use to review your own site step by step, whether you are building from scratch or repairing what you already run.
What the BFSG has required since 28 June 2025
The BFSG implements EU Directive 2019/882, known across Europe as the European Accessibility Act. It covers two areas: products such as self-service terminals, routers or reading devices for digital books, and services, including electronic commerce between companies and consumers. The technical detail does not sit in the act itself but in the accompanying ordinance (BFSGV). That ordinance points to the harmonised European standard EN 301 549, which in turn adopts the success criteria of the W3C Web Content Accessibility Guidelines at conformance level AA. In practice this means that anyone who wants to know what is expected of a website reads the WCAG. The current version, WCAG 2.2, has been an official W3C Recommendation since October 2023 and adds nine success criteria to its predecessor (W3C). If a new company website is on your roadmap, build that foundation in from the outset; the XICflow service overview is designed around exactly that.
Supervision sits with the joint market surveillance body of the German federal states for the accessibility of products and services. It reviews cases on a sample basis and after complaints, demands remediation and can, in extreme situations, prohibit a service outright. Fines reach up to 100,000 euros (BFSG Section 37), although deadlines and corrective action come first in everyday enforcement. On top of that, recognised associations may bring collective actions and competitors can examine unfair-competition claims. Contracts concluded before 28 June 2025 benefit from a transition period running until 27 June 2030 (BFSG Section 38), and longer periods apply to self-service terminals. Setting a project up now therefore means working against a continuing obligation rather than a single cut-off date. Other legal topics behave the same way: how consent and cookie banners are handled correctly depends just as much on sensible defaults as accessibility does.
Micro-enterprise exemption
Who falls within scope – and who does not
The most common misreading is that every website has to be accessible from now on. That is not the case. The BFSG addresses services in electronic commerce, meaning websites through which consumers can enter into a contract: purchases, bookings, appointment scheduling, contract signing, account opening. A purely informational site with no transaction usually stays outside the scope, as does an offer aimed exclusively at business customers. Public sector bodies, by contrast, have been subject to their own and in parts stricter rulebook for years. The boundary is blurrier than it sounds, though: a trade business with online appointment booking, a restaurant with table reservations or a medical practice with prescription requests moves into scope very quickly. If you are unsure, walk through the functions of your own site one at a time. The overview of how a XICflow site is assembled helps you place your own requirements.
| Type of website | BFSG relevance | Practical consequence |
|---|---|---|
| Purely informational site with no transaction | usually not covered | Accessibility stays voluntary, yet remains commercially sensible |
| Online appointment booking for consumers | covered | Review the booking flow and all forms against WCAG 2.2 AA |
| Purchase flow for consumers | covered | Selection, payment and confirmation page have to be operable |
| Offer aimed exclusively at business customers | usually not covered | Contractual commitments may still require accessibility |
| Website of a public sector body | separate rulebook | BITV 2.0 with accessibility statement and feedback mechanism |
| Service of a micro-enterprise | exempt under BFSG Section 3 | Check the exemption, document it and reassess it as you grow |
Regardless of the legal classification, the sheer scale makes the case. Germany is home to around 7.9 million people with a recognised severe disability (Federal Statistical Office of Germany), roughly nine percent of the population. Across the European Union the Commission estimates around 87 million people with some form of disability (European Commission). Add temporary and situational limitations: a broken arm, harsh sunlight on a display, a noisy environment without headphones. Accessibility is therefore a question of reach rather than a fringe concern. The side effect is measurable, too: clean heading structures, descriptive link text and robust forms improve operation for everyone and make a page easier for machines to interpret. If a new site is on the agenda anyway, both can be handled in one pass – the article on building a website with AI shows how that plays out.
WCAG 2.2 AA in everyday practice
The WCAG rest on four principles: perceivable, operable, understandable and robust. Beneath them sit success criteria at levels A, AA and AAA. Level AA, which includes level A, is the relevant benchmark for the BFSG. That sounds like a great deal of paperwork, yet in practice most websites stumble over a handful of recurring issues. The annual analysis of the one million most visited home pages finds that around 95 percent contain automatically detectable WCAG failures, with roughly 50 errors per home page on average (WebAIM Million). The distribution is remarkably stable: insufficient text contrast, missing alternative text, unlabelled form fields, empty links and missing language declarations account for the largest share. Removing those five patterns clears the bulk of the automatically measurable problems. The XICflow feature overview describes how such a foundation is produced.
Contrast
Body text needs a contrast ratio of 4.5:1, large text 3:1, and interface components and meaningful graphics 3:1 as well (WCAG 1.4.3 and 1.4.11).
Visible focus
Every focusable element shows a clearly recognisable focus indicator that is not obscured by headers or banners (WCAG 2.4.7 and 2.4.11).
Keyboard operation
All functions are reachable without a mouse, in a comprehensible order and without keyboard traps (WCAG 2.1.1 and 2.1.2).
Alternative text
Images that carry information get a descriptive text alternative; purely decorative graphics get an empty alt attribute (WCAG 1.1.1).
Form errors
Errors are identified in text, associated with the field concerned and accompanied by a correction suggestion (WCAG 3.3.1 and 3.3.3).
Target sizes
Interactive elements measure at least 24 by 24 CSS pixels or keep sufficient spacing between them (WCAG 2.5.8).
Contrast, focus and keyboard operation
Contrast is by far the most frequent defect: around 79 percent of the home pages analysed contain text with insufficient contrast (WebAIM Million). The rule is unspectacular and consequential all the same. Regular text needs a ratio of 4.5:1 against its background; large text from 24 pixels, or from 18.66 pixels in bold, gets by with 3:1. Since WCAG 2.1 a minimum ratio of 3:1 also applies to user interface components and meaningful graphics. In practice the usual offenders are pale grey on white, placeholder text inside form fields, buttons that look disabled, and copy set over photographs without a darkening layer. The second perennial issue is focus. Many designs strip the browser default focus indicator without supplying a replacement, which leaves the page effectively unusable for anyone navigating by keyboard. The example sites in the demo gallery show how a clean baseline looks in practice.
- Measure text contrast instead of estimating it: check design system colours against every background they appear on and record the results.
- Placeholder text is not a label: a visible label stays in place even once the field has been filled in.
- Keep the focus indicator visible or replace it deliberately, with sufficient contrast against the background and the unfocused state.
- Design sticky headers so that they do not obscure focused elements (WCAG 2.4.11).
- Align source order with visual order so that movement via the Tab key stays comprehensible.
- Offer a skip link to the main content so that repeated navigation blocks can be bypassed.
/* Keep focus visible instead of setting outline: none */
:where(a, button, input, select, textarea, summary, [tabindex]):focus-visible {
outline: 3px solid #aca316;
outline-offset: 2px;
border-radius: 4px;
}
/* A sticky header must not obscure the focus (WCAG 2.4.11) */
:root { scroll-padding-top: 6rem; }
/* Minimum target size 24 x 24 CSS pixels (WCAG 2.5.8) */
.icon-button { min-inline-size: 24px; min-block-size: 24px; }The keyboard check takes two minutes and replaces no audit, yet it surfaces a great deal: load the page, press the Tab key and move through every element without touching the mouse. At any moment it has to be visible where the focus sits. Menus should open with Enter or Space and close with the Escape key. Dialogs trap the focus while open and hand it back to the triggering element when closed. Carousels, disclosure panels and filters need reachable controls instead of mouse-only logic. WCAG 2.2 sharpened this area: the additions include criteria on focus that must not be obscured, on alternatives to dragging movements and on minimum target sizes. It also matters that the page structure holds up when heavy scripting does not run. Static delivery has structural advantages here, as the article on PageSpeed 100 and static delivery explains.
Alternative text and form errors
Around 55 percent of the home pages analysed contain images without a text alternative (WebAIM Million) – a figure that has barely moved for years. The rule itself is simple: if an image carries information, it needs a description that replaces that information. If it carries none, it needs an empty alt attribute so that assistive technology skips it. An alternative text does not describe the motif in detail; it conveys the function in context. For a product photo the product name works, for a chart the key message, for a logo in the header the company name, and for a linked icon the destination of the link. Forms are the second focus area: roughly 48 percent of home pages lack labels for input fields (WebAIM Million). A field without an associated label is an empty text box to a screen reader, and the person filling it in has no way of knowing what belongs there. The association is created through the for attribute of the label and the id of the field, complemented by aria-describedby for hints and error messages.
<label for="mail">Email address</label>
<input
id="mail"
name="mail"
type="email"
autocomplete="email"
aria-describedby="mail-hint mail-error"
aria-invalid="true"
required
/>
<p id="mail-hint">We reply to this address.</p>
<p id="mail-error" role="alert">
Please add the @ character - for example: name@company.com
</p>Error messages are where well-meaning forms fall apart. The WCAG require that an error is identified in text and associated with the field concerned (3.3.1) and that a correction suggestion follows where one can be determined (3.3.3). A red outline on its own is not sufficient, because colour must not be the only carrier of information. If the message appears dynamically, it has to be announced through a live region using role='alert' or aria-live. An error summary at the top of the form that links to the individual fields has proven useful as well. WCAG 2.2 adds two criteria that noticeably relieve forms: information already entered should not be requested again within the same process (3.3.7), and authentication steps must not force cognitive tests such as transcribing distorted characters when no alternative is offered (3.3.8). If you handle enquiries through a central inbox anyway, the matching building blocks are part of the XICflow workflow.
Accessibility lives in the building blocks
The accessibility statement
The BFSG requires providers of covered services to explain how the service meets the accessibility requirements (BFSG Section 14). That information belongs in the terms and conditions or in a comparably findable place, and it has to be accessible itself. In the public sector the accessibility statement under the German accessible information technology ordinance has been established for years and serves as a practical template: it states the degree of conformity, lists content that is not accessible, gives reasons, records the date of creation and of the last review, and provides a feedback mechanism with a contact route. Private providers are well served by the same structure, because it documents in a comprehensible way what was actually tested. Honesty matters here: declaring a site fully conformant while known gaps exist creates more risk than an open list with a schedule attached. The German Federal Agency for Accessibility publishes practical guidance on this (Bundesfachstelle Barrierefreiheit).
- Name the scope: which website, which applications and which documents does the statement cover?
- State the degree of conformity: fully, partially or not conformant, each with reference to WCAG 2.2 AA.
- List known limitations, explain them in plain language and attach a realistic schedule for fixing them.
- Describe alternatives: how do affected users obtain the information or service by another route, for instance by phone or email?
- Document the creation date and the test method: self-assessment, external review or a combination of automated testing and manual checks.
- Set up a feedback mechanism: a reachable contact option for reporting barriers, with a stated response time.
- Update the statement at least annually and after larger changes to the site.
Link the statement where people look
Testing: automated and manual
Automated testing tools are the fastest way in, yet they cover only part of the ground: practitioners estimate that roughly 40 percent of WCAG requirements can be checked by machine at all (WebAIM). A tool detects a missing alt attribute but cannot judge whether the alternative text present matches what the image conveys. It measures contrast, yet it does not assess a sensible focus order. Every review therefore needs a manual part: full keyboard operation, a pass with a screen reader, the layout at 200 percent zoom, the reflow check at 320 pixels width and a test with enlarged text spacing. It also pays to test user journeys rather than isolated pages: from the home page through the services overview to a submitted contact form. That is where the barriers that matter in daily use appear. Document every pass with date, tool and result – this is the basis for the statement and for later evidence.
Accessibility decides whether an enquiry can be sent at all. That makes it less a question of visual design than a question of whether the site functions.
Accessible from the start instead of retrofitted
Retrofitting is the most laborious route. When contrast values, focus indicators and form patterns are adjusted only after launch, every change touches all subpages and usually the design system as well. XICflow works the other way round: pages are assembled from a catalogue of reviewed blocks whose contrast values, focus indicators, heading hierarchy, labels and status messages rest on a WCAG 2.2 AA foundation. Interactive building blocks such as tab panels, process steps or sliders ship with the matching ARIA patterns and keyboard handling. Output is static HTML, so the page structure holds up even when scripts do not run. Legal pages and the accessibility statement are generated alongside and can be extended with project-specific details. None of this replaces a review of your own content – alternative text for your own photographs and plain language remain editorial tasks – but it shifts the effort from repairing to maintaining. The pricing overview shows what the build costs.
Accessibility is closely tied to other foundational decisions. A multilingual site needs correct language declarations so that screen readers pick the right pronunciation – the article on multilingual sites and hreflang covers the technical side. A consent banner has to be keyboard operable itself and must not lock the focus in place. And fast delivery helps precisely those people who work with magnification software or older devices. Handling these topics separately builds contradictions into the project; planning them together saves rounds of coordination and duplicated corrections. Further articles on structure, law and technology are collected in the XICflow blog.
How to approach it
- Clarify the scope: can consumers enter into a contract through your site? Then the BFSG applies.
- Run an automated test across your five most important pages and sort the findings by frequency.
- Carry out a keyboard check and a screen reader pass along the path from the home page to a submitted enquiry.
- Correct the contrast values of the design system centrally once, instead of recolouring individual pages afterwards.
- Rework forms: visible labels, associated hints, identified errors, correction suggestions, announced status messages.
- Capture alternative text editorially and anchor it in the maintenance process so that new images do not appear undescribed.
- Write the accessibility statement, link it in the footer and name a contact route for feedback.
- Define a testing rhythm: annually and after larger rebuilds, each time with a documented result.