The law that many still have not got on their radar
Since 28 June 2025, the German Accessibility Strengthening Act has been in force. In short: the BFSG (Barrierefreiheitsstärkungsgesetz). It transposes EU Directive 2019/882 (the European Accessibility Act) into German law and requires companies to make their digital products and services 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 exactly 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: anyone who sells, lets people book, or lets them enter into contracts online is, in all likelihood, affected. The full list is set out in Section 1 BFSG. In practice, it mainly applies to:
- Online shops and e-commerce – any website through which consumers can buy, book or subscribe to products or services
- Banking services – online banking, transfers, account information
- Telecommunications – providers of telephone 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 turnover 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 not directly affected. But the dividing line is thin: 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 digital services in Section 12. Two points relate directly to text quality:
- The two-senses principle: information must be accessible through more than one sensory channel. Text must be capable of being read out meaningfully by a screen reader or speech output.
- Understandability: text content must be suitable for generating "alternative assistive formats" (Section 12 No. 2e BFSGV). This calls for a clear structure, logical organisation and understandable language.
In concrete terms: convoluted administrative sentences of 40 words, where even the author loses the thread after the third comma, become a legal risk. Not because they are wrong, but because they are not accessible. This is where text optimisation 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 group 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 extends this thinking into the private sector. It does not, admittedly, require Easy Language from online shops, but it does require accessible communication. And anyone who has their texts checked for understandability often finds that the step towards Easy Language is not so far at all.
What happens in the event of a breach?
Whether and how strictly this will be enforced is still open. The law has been in force for less than a year. But the legal basis is in place, and formal warnings (Abmahnungen) in the e-commerce sector are a well-established business model. Anyone who is serious about accessibility does not wait for the first penalty notice.
What companies should do now
Accessibility is not a one-off 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 check-out process, customer information. Where does a screen reader stumble? Where does someone with a B1 language level lose the thread?
- Text optimisation: 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 group is particularly broad, or you are legally required (public contracts, communication with authorities), key content should also be available in Easy Language.
Sources
- German Accessibility Strengthening Act (BFSG), Federal Law Gazette, in force since 28 June 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 – rehadat-statistik.de
- BITV 2.0, Annex 2: duty to provide Easy Language and Sign Language for public bodies – gesetze-im-internet.de
- FAQ from the Federal Agency for Accessibility (Bundesfachstelle Barrierefreiheit) on the BFSG – bundesfachstelle-barrierefreiheit.de
- IT-Recht Kanzlei: fine of up to EUR 100,000 for breaches – it-recht-kanzlei.de
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