A law many companies still do not have on their radar
Since June 28, 2025, the German Accessibility Strengthening Act has been in effect. In short: the BFSG (Barrierefreiheitsstärkungsgesetz). It transposes EU Directive 2019/882 (the European Accessibility Act) into German law and requires covered digital products and services to be accessible.
Most people think of contrast ratios, alt text and screen-reader compatibility. That is part of it. But the law also covers the texts themselves: Are they understandable? Can assistive technologies read them out in a meaningful way? Are they suitable as a basis for generating alternative formats? Anyone who also uses AI-generated texts needs professional quality assurance on top.
This is where things get uncomfortable for many companies. The technical accessibility of a website can be tested automatically. The linguistic side cannot.
Who is affected?
In short: companies that offer certain products or services to consumers online should check whether they fall within the scope of the BFSG. The list is set out in Section 1 BFSG. In practice, this often concerns:
- Online shops and e-commerce—websites through which consumers can buy, book or subscribe to covered products or services
- Banking services—online banking, transfers, account information
- Telecommunications—providers of phone and internet services
- Passenger transport—booking systems for rail, bus and air travel
- E-books and e-readers
Companies with fewer than 10 employees and an annual revenue or annual balance-sheet total of no more than EUR 2 million are exempt, as micro-enterprises, from the BFSG service obligations (Section 2 No. 17 BFSG). This exemption does not apply to product manufacturers.
Purely informational websites with no purchasing option are generally not directly affected. But as soon as consumers can buy, book, pay or enter into a contract online, a closer check is needed to determine whether a service subject to the BFSG is involved.
What does “accessible” mean for texts?
The Accessibility Ordinance to the BFSG (BFSGV) sets out specific requirements for services in Section 12. Several points relate directly to text quality:
- More than one sensory channel: information must be provided through more than one sensory channel. Text must be capable of being read out meaningfully by a screen reader or speech output.
- Understandability: information must be presented in an understandable way (Section 12 No. 2c BFSGV).
- Alternative assistive formats: text content must be suitable for generating alternative assistive formats (Section 12 No. 2e BFSGV). This calls for a clear structure, logical organization and understandable language.
In concrete terms: convoluted sentences of 40 words, where even the author loses the thread after the third comma, can become a risk. Not because they are necessarily wrong, but because they may not be accessible or understandable enough. This is where text optimization and cutting through red tape come in.
BITV 2.0 and Easy Language: where the duty has applied for longer
For federal public bodies, BITV 2.0 (the Accessible Information Technology Ordinance) has existed since 2011. It requires federal authorities to provide explanatory notes on their websites in Easy Language and German Sign Language—on the home page and in the accessibility statement.
Easy Language is not simplified German. It is a set of rules in its own right, with specific requirements for sentence length, word choice and layout. Its target audience includes people with learning difficulties, people with dementia, people with limited German and people with reading difficulties. Together, that is considerably more than the 7.9 million people with a severe disability in the official statistics.
The BFSG now brings comparable accessibility requirements into parts of the private sector. It does not specifically require Easy Language from online shops, but it does require accessible and understandable information for covered products and services. Anyone who has their texts checked for understandability often finds that the step toward Easy Language is not so far at all.
What happens in the event of a breach?
Market surveillance is no longer theoretical: the MLBF is set up, accepts reports and has adopted market surveillance strategies for products and services in 2026. How strictly individual cases are handled depends on the specific offer and the breach identified. Anyone who may be affected should not treat accessibility as a later precaution.
What companies should do now
Accessibility is not a one-time project but an ongoing process. At the text level, I recommend three concrete steps:
- Take stock: have your most important texts checked for understandability. Product descriptions, terms and conditions, the checkout process, customer information. Where does a screen reader stumble? Where does someone with a B1 language level lose the thread?
- Text optimization: shorter sentences, a clearer structure, fewer technical terms left unexplained. This is not a loss of quality but a gain for all readers.
- Consider Easy Language: if your target audience is particularly broad, or if the contract, legal framework or funding requirements provide for Easy Language, key content should also be available in Easy Language.
Sources
- German Accessibility Strengthening Act (BFSG), in force since June 28, 2025—gesetze-im-internet.de
- BFSG Ordinance (BFSGV), in particular Section 12 on services—gesetze-im-internet.de
- Federal Statistical Office: 7.9 million people with a severe disability in Germany—destatis.de
- BITV 2.0, Annex 2: explanations in Easy Language and German Sign Language for federal public bodies—gesetze-im-internet.de
- Federal Agency for Accessibility: information on the BFSG and its scope—bundesfachstelle-barrierefreiheit.de
- MLBF: Market Surveillance Authority of the Federal States for Accessibility of Products and Services—mlbf-barrierefrei.de
- Section 37 BFSG: fine provisions—gesetze-im-internet.de
Ready to make your texts accessible?
I check your corporate communication for understandability and the linguistic requirements of the BFSG.
Request a quote