BFSG: what the German Accessibility Strengthening Act means for your PDFs

Key takeaways

• The German Accessibility Strengthening Act (BFSG) implements the European Accessibility Act (Directive (EU) 2019/882) in German law and has applied since June 28, 2025.
• It applies to manufacturers, importers and distributors of certain products and to providers of certain consumer services, including banking, e-commerce and passenger transport services.
• PDFs are covered whenever they form part of such a service, including contracts, forms, invoices, and product or service information.
• EN 301 549 is the technical benchmark and references WCAG. For PDFs, PDF/UA defines how to implement the requirements.
• Breaches may result in market-surveillance measures and fines of up to €100,000 under Section 37 BFSG.

What is the BFSG?

The German Accessibility Strengthening Act (BFSG) implements the European Accessibility Act (EAA, Directive (EU) 2019/882) in Germany. It is the first German law to require private-sector economic operators to make certain products and services accessible. The accompanying ordinance (BFSGV) sets out the detailed requirements.

The Act has applied since June 28, 2025. Products placed on the market since that date, and services provided to consumers since that date, must meet the accessibility requirements. There is no general grace period; only narrowly defined transitional arrangements apply in specific cases, as explained below.

Who does the BFSG apply to?

The BFSG does not apply to every business, but to clearly defined categories of products and services under Section 1 BFSG. What matters is your specific offering, not simply the size or sector of your business.

Affected products

This includes manufacturers, importers and distributors of:

• computers and operating systems
• self-service terminals, such as ATMs and ticket machines
• smartphones, tablets and other devices with interactive features
• e-readers

Consumer services covered

This includes providers of:

• consumer banking services
• consumer e-commerce services, including virtually every online shop and online contracting process
• long-distance passenger transport services, such as booking portals and electronic tickets
• electronic communications services and e-books

A manufacturer operating solely business-to-business is generally not covered by the BFSG, whereas a bank that provides statements and contract documents digitally is. See more examples in Industries.

Exception: micro-enterprises

Micro-enterprises with fewer than ten employees and no more than €2 million in annual turnover or balance-sheet total are exempt from the requirements for Services under Section 3(3) BFSG. This exemption does not apply to products: businesses that manufacture or distribute covered products must meet the requirements regardless of their size.

Why does the BFSG affect your PDF documents?

Accessibility does not end at the website. A service must be accessible together with the information needed to use it, including documents. Contracts, forms, invoices, price lists and product information in PDF format therefore form part of a service when consumers receive or access them during an ordering, contracting or service process.

An inaccessible PDF can therefore put the conformity of an otherwise exemplary digital service at risk. This also applies to older documents if they remain part of an active service. Learn what makes a PDF technically accessible on our page PDF accessibility with AI.

What technical standard applies to PDFs?

The BFSG itself does not prescribe a technical standard. In practice, organisations follow the European standard EN 301 549, which defines accessibility requirements for ICT products and services, including non-web documents. It draws on the Web Content Accessibility Guidelines (WCAG). WCAG 2.2 represents the current state of the art.

For PDF documents, the ISO standard PDF/UA —currently PDF/UA-2—specifies how to implement these requirements using complete tagging, a correct reading order, alt text for images, and properly marked-up tables and form fields. For more detail, see Understanding PDF/UA and WCAG for PDF documents.

What sanctions are there for violations?

The BFSG is enforced at three levels:

1. Market surveillance: The market-surveillance authorities of the German federal states inspect products and services, including in response to complaints from consumers or associations. They can order businesses to remedy breaches within a set period.
2. Fines: Depending on the offence, breaches of the BFSG may incur fines of up to €100,000 under Section 37 BFSG.
3. Prohibition: If a breach persists, the authority may restrict or prohibit the service or stop distribution of the product.

Beyond regulatory action, the practical harm also matters: inaccessible documents exclude customers with visual or reading impairments from essential processes, from signing a contract to checking an invoice.

What transitional regulations are there?

Section 38 BFSG contains only a small number of narrowly defined transitional arrangements. Two examples are:

• Service contractsentered into before 28 June 2025 may continue unchanged until 27 June 2030 at the latest.
• Self-service terminalslawfully in use before the deadline may remain in operation until the end of their economic life, but for no more than 15 years after commissioning.

Important: there is no comparable grace period for PDFs that form part of digital services currently being provided. They must already meet the requirements.

BFSG and BITV 2.0 in comparison

The BFSG applies to the private sector. BITV 2.0 applies additionally or primarily to authorities, universities and other public-sector bodies, using the same technical foundation.

Our guide BITV 2.0: accessible PDFs in the public sectorexplains the obligations of public-sector bodies in detail. For practical guidance, see Authorities and Higher education.

What you should do now

You can structure the path to a BFSG-compliant PDF collection in four steps:

1. Inventory: Identify the PDFs that form part of the services covered, from contract documents and forms to product and pricing information. Assess their current accessibility; automated audits typically return results in seconds.
2. Prioritise: Start with documents that consumers actively need during ordering, contracting or service processes. These carry the greatest legal and practical importance.
3. Automated remediation: Manual remediation does not scale to large document collections. Our comparison Making PDFs accessibleexplains the available approaches and when to use each one. Accessful automatically audits and remediates the structural layer of PDFs—including tags, reading order and alt text—while leaving the layout and content unchanged. It can also process thousands of documents in batches. See How it works.
4. Evidence: Document your implementation. Accessful provides an audit-ready report for every remediated document as evidence for monitoring bodies and audits. Our remediation guarantee also applies: if a document remediated by Accessful is not accepted as accessible during an accessibility audit, we will remediate it again free of charge—quickly and at no additional cost.

This turns a legal obligation into a manageable process and makes your documents usable by every customer, regardless of disability.