Law / Germany

Verordnung zum Barrierefreiheitsstärkungsgesetz (BFSGV), accessibility requirements for consumer products and services

Verordnung zum Barrierefreiheitsstärkungsgesetz (BFSGV), §§ 1 bis 22

In force since 28 Jun 2025.

An accessibility requirements rule binding public and private bodies.

What it requires

If you place on the market a product listed in section 1(2) of the BFSG, or provide a service listed in section 1(3) to consumers, meet the requirements of the Verordnung zum Barrierefreiheitsstärkungsgesetz (BFSGV, s. 1; Directive (EU) 2019/882, Annex I); a microenterprise that provides services is exempt from the duty (BFSG, s. 3(3)).
Observe the state of the art in meeting the requirements; you may depart from it if the requirements are met to the same degree in another way, and the Bundesfachstelle für Barrierefreiheit publishes the standards it regards as most important on its website (s. 3). Conformity with a harmonized standard whose reference is published in the Official Journal of the European Union is presumed to meet the requirements it covers (BFSG, s. 4).
Products: give the information on the product itself (labels, instructions for use, warnings) through more than one sensory channel, in an understandable and perceivable way, in a font of suitable size and shape with sufficient contrast and spacing (s. 4(1)); make public, when the product is placed on the market, the information on its accessibility features, their activation and interoperability with assistive technologies, and on its use, in the ten ways section 4(2) lists, and give the information on the product itself where possible (s. 4(2) and (3)).
Products: put the packaging information on the packaging where its size or nature allows, and make installation, maintenance, storage and disposal instructions that are not on the product publicly available and accessible when the product is placed on the market, except for self-service terminals (s. 5).
Products: give the product, including its user interface, components, functions and features that let persons with disabilities access, perceive, operate, understand and control it (s. 6(1)), and meet the thirteen requirements of section 6(2): more than one sensory channel, alternatives to speech and voice input, flexible size, brightness, contrast and visual clarity, alternatives to colour and to audible signals, volume and speed control with enhanced audio functions, sequential control and alternatives to fine motor control with tactilely recognizable parts, no operation needing great reach or force, no triggering of photosensitive seizures, privacy when accessibility features are used, alternatives to biometric identification and control, consistency with enough flexible time, and software and hardware interfaces for assistive technologies.
Self-service terminals: provide speech output, allow individual headphones, warn through more than one sensory channel when response time is limited and allow it to be extended, provide buttons with sufficient contrast and tactile recognizability, use audio signals compatible with hearing aids, telecoils, cochlear implants and technical hearing aids, and do not require anyone to activate accessibility features before the terminal can be switched on (s. 7).
E-book readers: provide speech output (s. 8). Consumer terminal equipment with interactive computing capability for telecommunications services: support real-time text where text is used with voice, high audio quality, total conversation services where video is used, an effective wireless connection to hearing technology, and operation without interference with assistive devices (s. 9). Equipment used to access audiovisual media services: provide the accessibility components that the media service provider offers for access, selection, control, personalization and transmission to assistive devices (s. 10).
Support services such as help desks, call centres, technical support, relay services and training, where available, give accessible information on accessibility and compatibility with assistive technologies through accessible means of communication (ss. 11 and 12 item 4).
Services: the products you use to provide a service meet sections 4 and 6 to 11 (and section 5 where applicable); information on how the service works, on its connection to those products and on their accessibility features and interoperability is given through more than one sensory channel, findable, understandable, perceivable, in text formats suitable for generating alternative assistive formats, with alternatives to non-text content and in a suitable font; and websites with their online applications and mobile services including apps are perceivable, operable, understandable and robust (s. 12).
Services: provide functions, procedures, strategies and changes in how the service is carried out that are oriented to the needs of persons with disabilities and ensure interoperability with assistive technologies (s. 13).
Telecommunications services: where a service enables voice communication, provide real-time text in addition to voice, and a total conversation service where it provides video; synchronize emergency communications across voice and text (and total conversation where video is provided) and pass them on without delay to the local emergency answering point (s. 14).
Passenger transport services by air, bus, rail and waterborne transport, other than urban, suburban and regional services: provide information on the accessibility of vehicles, surrounding infrastructure and buildings and on assistance, information on smart ticketing systems such as electronic reservation and booking, real-time travel information such as timetables, disruptions, connections and onward travel, and additional service information such as staff on duty at the station, defective lifts and services temporarily unavailable (s. 15); for urban, suburban and regional transport, the interactive self-service terminals used meet sections 4, 6, 7 and 11 (s. 16).
Consumer banking services: make identification methods, authentication methods, electronic signatures, security functions and payment services perceivable, operable, understandable and robust, and keep information on how the service works at a language level no higher than B2 of the Common European Framework of Reference for Languages (s. 17).
E-books: provide synchronized text and audio where the e-book has both, do not prevent assistive technologies from working, ensure access to content and navigation including dynamic layouts, provide a structure, flexibility and choice in presentation and alternative ways of rendering the content, ensure interoperability with assistive technologies, provide metadata that makes accessibility features findable, and ensure that accessibility features are not blocked by technical protection measures under sections 95a to 96 of the Copyright Act (s. 18).
E-commerce services: provide information on the accessibility of the products and services offered, to the extent the responsible economic operator supplies it, and make identification, authentication, security and payment functions, and identification methods, authentication methods, electronic signatures and payment services, perceivable, operable, understandable and robust (s. 19).
For functions that sections 4 to 19 do not cover, meet the functional performance criteria of section 21: where a product or service offers visual operation, at least one way of use without vision, one with limited vision and one without colour discrimination; for audible operation, one without hearing and one with enhanced audio; where voice input is needed, one without it; for manual operation, one that needs no fine motor control, hand strength or simultaneous use of several controls; controls within reach of all users; no photosensitive seizure triggers; at least one way of use that eases use with cognitive limitations; and privacy when accessibility features are used (ss. 20(1) and 21); where sections 4 to 19 set a specific technical requirement, you may meet the functional performance criteria instead only if you meet the other requirements of those sections and the result is equally or more accessible (s. 20(2)).

These lines are LexLint's reading of the law's text.

If you get it wrong

Penalty structure

Breaches of the Ordinance's requirements are fined under section 37 of the Barrierefreiheitsstärkungsgesetz: up to EUR 100,000 for the offences in section 37(1), items 1, 7, 8, 9 and 10, and up to EUR 10,000 for the other offences in section 37(1).

Rule: Fixed only
As of: 4 November 2026
Currency: EUR
Fixed cap: 100,000

Who enforces it

Enforcement body

The market surveillance authorities of the Länder (Marktüberwachungsbehörden), in practice the joint monitoring body of all 16 Länder, the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF AöR)

What it reaches

Instrument type

a regulation made under an act

Applicability criteria

As of

4 November 2026

Combinator

Any of

Criteria

an economic operator that places on the market, or makes available on it, a product listed in section 1(2) of the Barrierefreiheitsstärkungsgesetz
an enterprise that offers or provides to consumers a service listed in section 1(3) of the Barrierefreiheitsstärkungsgesetz and is not a microenterprise (Kleinstunternehmen)

What this law does

Drafted with AI

Drafted with AI from the cited sources under the direction of UnGovr staff. UnGovr holds editorial responsibility for this page. How this site is made

Research summary

Legal information, not legal advice. This is LexLint's own research summary of a public legal source, and it creates no attorney-client relationship. For decisions that matter, consult qualified counsel in the relevant jurisdiction. About LexLint

The Verordnung zum Barrierefreiheitsstärkungsgesetz implements Annex I of Directive (EU) 2019/882. Section 3(2) of the BFSG authorizes the Federal Ministry of Labour and Social Affairs to set the concrete accessibility requirements for the products in section 1(2) and the services in section 1(3) by ordinance, in line with Annex I of the Directive.

Section 3(1) of the Ordinance requires the state of the art to be observed in meeting its requirements, and allows a departure from it where the requirements are met to the same degree in another way. Section 3(2) of the Ordinance requires the Bundesfachstelle für Barrierefreiheit to publish regularly on its website a list of the most important standards from which the requirements arise, conformity tables and current information on the standards to observe.

Section 4 of the BFSG presumes that products and services that conform to harmonized standards, or parts of them, whose references are published in the Official Journal of the European Union meet the requirements of the ordinance, to the extent those standards cover them. Section 5 of the BFSG gives the same presumption to conformity with the technical specifications under Article 15(3) of the Directive.

Section 5a of the BFSG presumes that features, components or functions of products or services outside the Act that meet the requirements of the ordinance, other than those for support services, meet the accessibility obligations of other Union acts, unless those acts provide otherwise.

Section 4(1) of the Ordinance requires information on the product itself, such as labels, instructions and warnings, to be available through more than one sensory channel, understandable, perceivable and set in a suitably sized and shaped font with sufficient contrast and spacing. Section 6(1) of the Ordinance requires a product, including its user interface, to contain components, functions and features that let persons with disabilities access, perceive, operate, understand and control it.

Section 6(2) of the Ordinance lists thirteen further requirements for a product, among them alternatives to speech, colour, audible signals and biometric identification, flexible size, brightness and contrast, volume and speed control, avoiding photosensitive seizures, protecting privacy when accessibility features are used, and interfaces for assistive technologies.

Section 7(1) of the Ordinance requires self-service terminals to have speech output, to allow individual headphones to be used, to warn through more than one sensory channel when the time to respond is limited, to allow that time to be extended, to have buttons with sufficient contrast and tactile recognizability, and to use audio signals compatible with hearing aids and other assistive technologies.

Section 7(2) of the Ordinance bars self-service terminals from requiring the activation of accessibility features before people who rely on them can switch the terminal on. Section 8 of the Ordinance requires e-book readers to have speech output.

Section 9 of the Ordinance requires consumer terminal equipment with interactive computing capability used for telecommunications services to support real-time text, high audio quality, total conversation services where video is used, an effective wireless connection to hearing technology, and operation without interference with assistive devices.

Section 10 of the Ordinance requires consumer terminal equipment used to access audiovisual media services to provide the accessibility components that the audiovisual media service provider makes available for access, selection, control, personalization and transmission to assistive devices.

Section 11 of the Ordinance requires support services such as help desks, call centres, technical support and relay services, where available, to give information on accessibility and compatibility with assistive technologies through accessible means of communication.

Section 12 of the Ordinance requires, for a service to meet the accessibility duty, that the products used to provide it meet sections 4 and 6 to 11, that information on how it works be provided in accessible ways, that websites and mobile apps be perceivable, operable, understandable and robust, and that support services give accessible information.

Section 14(1) of the Ordinance requires telecommunications services that enable voice communication to provide real-time text in addition to voice, and a total conversation service where they provide video. Section 14(2) of the Ordinance requires emergency communications to be synchronized across voice and text, and across total conversation where video is provided, and to be transmitted without delay to the local emergency answering point.

Section 15 of the Ordinance requires air, bus, rail and waterborne passenger transport services, other than urban, suburban and regional services, to provide information on the accessibility of vehicles, surrounding infrastructure and buildings and on assistance, information on smart ticketing, real-time travel information and additional service information.

Section 16 of the Ordinance requires self-service terminals used for urban, suburban and regional transport services to meet sections 4, 6, 7 and 11. Section 17 of the Ordinance requires the identification methods, authentication methods, electronic signatures, security functions and payment services of consumer banking services to be perceivable, operable, understandable and robust.

Section 17(2) of the Ordinance requires information on how a consumer banking service works to be understandable at a language level no higher than B2 of the Common European Framework of Reference for Languages. Section 18 of the Ordinance lists ten requirements for e-books, among them synchronized text and audio, files that do not prevent assistive technologies from working, navigation and structure, flexible presentation, and accessibility metadata.

Section 19 of the Ordinance requires e-commerce services to provide information on the accessibility of the products and services offered, and their identification, authentication, security and payment functions to be perceivable, operable, understandable and robust. Section 20 of the Ordinance treats functions for which sections 4 to 19 set no requirement as accessible if they meet the functional performance criteria of section 21. The Ordinance applies from 28 June 2025.

An ordinance of 10 July 2026 replaced section 7(2) and section 14 of the Ordinance. That ordinance was promulgated on 15 July 2026 and took effect on 16 July 2026, the day after its promulgation.

When LexLint raises it

When your app profile says your app ships a consumer interface, ships a mobile app, distributes a software product, provides telecom services or provides financial services.

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Page updated 4 November 2026.