The Regulation on the Accessibility Improvement Act (BFSGV) contains the specific requirements for implementing accessibility in products and services in Germany. We explain the significance of the BFSGV and what you need to know about the implementation of assistive technologies.
In a nutshell
- The BFSGV supplements the Accessibility Improvement Act (§ 3(2) BFSG) as a statutory ordinance and came into force on 28 June 2025, alongside the Act.
- The BFSGV sets out specific accessibility requirements for products and services.
- Practical implementation of the BFSGV requires an understanding of sensory limitations and related assistive technologies.
Background: the relevance of accessibility in digital products and services
Accessibility and the participation of people with disabilities it enables, is not only a legal obligation and a means of improving individual quality of life, but also gaining quantitative significance: According to the Federal Statistical Office, 6.92 million people with disabilities lived in Germany in 2007, 7.77 million in 2017, and 7.87 million in 2023.
This is due in part to demographic change. Disabilities often result from illness and become more likely with age. For example, hearing ability declines over the course of life.
In 2023, around 59% of people in Germany with severe disabilities were 65 years of age or older. Put another way: Among those aged 65–75, 23% of men and 18% of women had a severe disability. Among those over 80, it was 35% of men and 29% of women.
Accessibility can therefore no longer be considered a niche issue. Moreover, accessibility regularly improves the user-friendliness of products and services for everyone.
What is the BFSGV
The BFSGV serves to implement Annex I of Directive (EU) 2019/882 on the accessibility requirements for products and services. The Federal Ministry of Labour and Social Affairs is authorised to issue the relevant ordinance.
A broad distinction can be made between the BFSG and the BFSGV:
- The Accessibility Improvement Act (BFSG) defines which digital products and services must be made accessible and what obligations apply to market operators.
- The BFSGV defines how products and services must be designed to be accessible.
The Regulation stipulates that products and services must comply with current technical standards to be considered accessible. In future, the German Federal Accessibility Office will provide further guidance on this.
Structure of the BFSGV
The Regulation includes specific accessibility requirements for products and services. General rules are described in the initial sections, with more detailed provisions for various product types in later sections. One section also states that deviations from the rules are allowed if they result in improved accessibility.
It is important that products or services are not designed to rely solely on a single sense (e.g. vision or hearing). Alternatives must be provided. For example, if a product offers visual controls, it must also be usable by those with limited vision.
However, exceptions apply where implementing accessibility would fundamentally alter the product or service, or where it would be unreasonable for the provider or manufacturer (more on this in our The German Accessibility Improvement Act(BFSG) guide).
Presumption of conformity
If a product or service complies with a European standard, or part of one, it is presumed to meet the BFSGV requirements – if those requirements are covered by the standard. For ICT services, the key standard is EN 301549, which references the Web Content Accessibility Guidelines (WCAG 2.1, soon 2.2).
Compliance with WCAG Level AA satisfies the requirements of EN 301549 and establishes presumption of conformity under § 4 BFSG. The same applies to technical specifications as defined in Art. 2(4) of Regulation (EU) 1025/2012 under § 5 BFSG.
Requirements of the BFSGV
The general requirements for all products are outlined in §§ 4 to 6 BFSGV. These include requirements for information provision, packaging, user instructions, user interface design, and functionality.
The following types of information must be provided:
- Information on how to use the product, displayed directly on the product.
- Published information on accessibility features, how to activate them, their compatibility with assistive technologies, and other usage information not displayed on the product itself.
For services, the general requirements are outlined in §§ 12 and 13 BFSGV. These include information on service functionality and, where relevant, how the service interacts with products and their compatibility with assistive technologies.
Specific products and services are covered by additional requirements in §§ 7 to 11 BFSGV and §§ 14 to 19 BFSGV.
Understanding the terms ‘assistive technologies’ and ‘sensory channels’ is crucial for interpreting these requirements.
Assistive technologies
In the German context, assistive technologies are tools from the IT field that enable people with disabilities to use offerings like software, websites, and apps. These include hardware or software like screen readers, voice input, speech recognition, eye trackers, and many more.
Sensory channels
The BFSGV considers the following sensory channels:
- Visual information or interaction: Accessibility must be ensured for users with limited or no vision.
- Auditory information: Accessibility must be ensured for users with limited or no hearing. Audio signals should be within commonly perceivable frequency ranges – signals outside these ranges may not be audible, particularly for older people.
- Voice input: For interactions requiring the formation of speech or sounds (e.g. speech, clicking, whistling), accessibility must be ensured for people with hearing or speech impairments.
- Tactile or manual input: This includes information or interactions requiring touch, muscle control, or fine motor skills. Accessibility must be ensured for people unable to operate controls manually.
Other recurring terms and their meaning
The following terms from the BFSGV are also the four principles of the WCAG, which serve as a basis for understanding and implementing accessibility – especially for websites and software:
Perceivable
As noted above, information and interactions must be made available through multiple sensory channels.
Operable
Interactive elements must be as accessible and user-friendly as possible. Common obstacles include lack of keyboard operability and insufficient time allowances.
- Full keyboard navigation is essential – for example, for using a website without fine motor control or a mouse, or with alternative input devices.
- Sufficient time for interaction must be provided. Flexibility is key: Users should be able to adjust or pause interactions, be informed of timeouts, and resume authenticated sessions without losing data.
Understandable
Information must be presented clearly and comprehensibly. This includes legible text, predictable interactions, and input assistance. Readability can be improved through typography, language settings, recognition of abbreviations or uncommon words, and simplified reading levels when required.
Robust
Information and interaction options must be compatible with a wide range of assistive technologies and correctly interpreted. For websites, adhering to HTML standards is critical. Assistive technologies must be able to determine names and roles for all interface components (like form fields and links) so users can navigate and access content reliably.
Information and interactive elements should also be future-proof so they have long-term compatibility with assistive tech, minimal error susceptibility, and no barriers from minor coding issues.
Conclusion
Businesses must meet specific accessibility requirements for all products and services subject to the BFSG.
Accessibility should be integrated as a dedicated requirement throughout the entire lifecycle of products and services.
Implementing all the necessary measures can involve significant effort, technical expertise, and tailored solutions. We therefore recommend training employees – particularly those involved in product development. – accordingly.
