Web accessibility: New legal requirements from 28 June 2025
Why accessibility is important now
From 28 June 2025, new legal regulations on digital accessibility will come into force. The EU Directive 2019/882 ("European Accessibility Act"; EAA) has been transposed into national law - including in Germany with the Barrierefreiheitsstärkungsgesetz (BFSG) and in Austria with the Barrierefreiheitsgesetz (BaFG). Companies that offer electronic services or products for consumers must ensure that their digital offerings are accessible.
But what does this mean in concrete terms for your company? What measures should you take now? Who is affected?
Not every company is directly affected by the new regulations. In principle, the law applies to companies that offer electronic services or digital products to consumers (B2C). This includes:
- Websites and online shops that enable consumers to interact directly with the company, e.g. by concluding contracts, booking appointments or making specific enquiries via forms. This also includes online portals that can be used to book services, take out subscriptions or place orders. Pure information websites without interactive functions are not affected.
- Digital services, e.g. banks (online banking), telecommunications, ticket bookings, e-books or video-on-demand platforms.
- Companies that are not micro-enterprises - this means: micro-enterprises (less than 10 employees & less than €2 million annual turnover) are exempt from the obligation for digital services, but not for digital products.
My B2C website has been affected, and I would like to conduct an audit!
Our accessibility experts will be happy to help you carry out an accessibility audit.
Important to know: B2B companies are not affected!
The law only applies to offers aimed at consumers (B2C). A pure B2B online shop or a website that only addresses companies is not covered by the regulation.
If your company is affected, it makes sense to take initial measures at an early stage. But don't worry - not all requirements have to be fully implemented by the deadline. The important thing is that you show that you are working on it.
How to make your website accessible - step by step
1. Carry out a website audit
The first step is to take stock. Have your website checked for accessibility requirements - either with special tools or by experts. This will determine which aspects are already accessible and where there is still some catching up to do. Such a check will give you a clear list of to-dos.
2. Implement improvements step by step
It is not necessary to perfect everything overnight. Start with the most important measures:
- Ensure keyboard operability - all functions must be usable without a mouse
- Optimise colours & contrasts - a minimum contrast of 4.5:1 is required
- Provide alternative texts for images and videos
- Provide structured content for screen readers
- Make forms understandable and accessible
3. Publish a declaration on accessibility
It is mandatory for affected companies to publish an accessibility statement on their website. This should:
- Describe the current status of accessibility
- List barriers that still exist
- Provide a contact option for reporting barriers
- Include information on the responsible enforcement body
- This declaration not only shows that you are complying with the requirements, but also that you are actively working on improvements.
4. Ongoing optimisation & regular updates
Accessibility is not a one-off project. Websites and digital offerings are constantly changing - new content, new functions. It therefore makes sense to regularly check whether new elements have also been designed to be accessible.
What are the requirements for an accessible website?
The legal requirements are based on the WCAG 2.1 AA (Web Content Accessibility Guidelines). These define various criteria for accessibility. Here are some key points:
1. Perceivable
- Alternative texts for images & media
- Good legibility & high colour contrasts (at least 4.5:1 ratio)
- Flexible font sizes & zoom function (up to 200 % without loss of quality)
- Structured content for screen readers
2. Operable
- Navigation via keyboard possible
- No forced mouse operation
- Comprehensible & skippable navigation ("Skip to Content" function)
- No annoying time limits or uncontrollable flashing
3. Understandable
- Simple language & clear formulations
- Predictable navigation & consistent structure
- Error messages with comprehensible help
- Supporting functions for form fields (auto-complete, help texts)
4. Robust
- Clean HTML & ARIA attributes for screen readers
- Compatibility with different browsers & devices
- Avoidance of unsupported technologies (e.g. Flash)
Frequently asked questions about the Accessibility Act
Are B2B websites and online shops also affected?
No. The legal requirements only apply to digital offers aimed at consumers (B2C). Pure B2B websites are exempt.
What sanctions and penalties can be expected?
The market surveillance authorities are authorised to order measures in the event of violations of the legal requirements. This can include requests for rectification, and in serious cases fines are also possible: up to EUR 100,000 in Germany and up to EUR 80,000 in Austria. However, the exact enforcement and possible sanctions depend on the respective national authorities.
Do mobile apps also have to be accessible?
Yes, the legal requirements apply not only to websites, but also to mobile applications. Companies that offer digital services via apps must ensure that these are accessible in accordance with the WCAG 2.1 AA standards. This applies in particular to apps from banks, ticket services, e-book providers and other affected industries.
Are career websites also affected?
No, career websites are generally not affected. The law applies to electronic services and digital products for consumers (B2C). Since applicants are not considered consumers within the meaning of the law and an employment contract is not a consumer contract, a career website with an application function is not subject to the requirements of the BFSG or BaFG.
Are companies from Switzerland also affected?
Yes, as long as they offer products or services in the EU. This means that digital offers aimed at EU consumers must fulfil the requirements of national laws in order to avoid legal risks and possible sanctions.
We would be happy to carry out an accessibility audit for you!
Let us arrange an appointment as soon as possible.
Further links:
Barrierefreiheitsgesetz (BaFG) - Austrian Federal Chancellery: This site provides detailed information on the Austrian BaFG, including legal requirements and implementation guidelines.
Link: Accessibility Act - RIS
Barrierefreiheitsstärkungsgesetz (BFSG) - Federal Ministry of Labour and Social Affairs (BMAS): Here you will find comprehensive information on the German BFSG, which implements the EU Accessibility Directive (EAA).
Link: Accessibility Reinforcement Act - BMAS
European Accessibility Act (EAA) - European Commission: This page explains the EU Directive 2019/882, which serves as the basis for national laws such as the BaFG and BFSG.
Link: European Accessibility Act - European Commission
Web Content Accessibility Guidelines (WCAG) 2.1 - W3C: The WCAG 2.1 guidelines of the World Wide Web Consortium serve as an international standard for the accessibility of web content.
Link: WCAG 2.1 - W3C
Note:
This blog article is for general information and does not claim to be complete or to provide legal advice. For legal questions, please contact a specialised legal advisor.
