The most important thing in brief
- The German Accessibility Strengthening Act (BFSG) implements the European Accessibility Act (Directive (EU) 2019/882) into German law and has been in effect since then June 28, 2025.
- It imposes obligations on manufacturers, importers and retailers of certain products as well as providers of certain consumer services - such as banking services, electronic commerce and passenger transport services.
- PDF documents are affected as soon as they are part of such a service: contracts, forms, invoices, product and service information.
- The technical benchmark is EN 301 549, which refers to the WCAG; For PDFs, the PDF/UA standard specifies the implementation.
- Violations result in market surveillance measures and fines of up to €100,000 (Section 37 BFSG).
What is the BFSG?
The German Accessibility Strengthening Act (BFSG) is the German implementation of the European Accessibility Act (EAA, Directive (EU) 2019/882). For the first time, it legally obliges private economic actors to offer certain products and services in an accessible manner. The relevant legal regulation (BFSGV) regulates which requirements apply in detail.
The law has been in effect since then June 28, 2025. Products that have been placed on the market since then and services that have been provided to consumers since then must meet accessibility requirements. There is no general grace period - only narrowly limited transitional regulations for individual cases (more on this below).
Who does the BFSG apply to?
The BFSG does not apply to all companies, but to clearly defined product and service categories (§ 1 BFSG). What matters is your specific offer, not your company size or industry alone.
Affected products
Manufacturers, importers and dealers, among others, of:
- computers and operating systems
- Self-service terminals, such as cash and ticket machines
- Smartphones, tablets and other devices with interactive functions
- E-book readers
Affected Consumer Services
Providers of, among other things:
- Consumer banking services
- electronic commerce – i.e. practically every online shop and every online contract route for consumers
- Services in national passenger transport, such as booking portals and electronic tickets
- Telecommunications services and e-books
A mechanical engineer in pure B2B business is generally not subject to the BFSG. However, a bank that provides account statements and contract documents digitally does. An overview of typical affected industries can be found at Industries.
Exception: micro-enterprises
Micro-enterprises – fewer than ten employees and a maximum of 2 million euros in annual sales or annual balance sheet total – are subject to the requirements Services excluded (Section 3 Para. 3 BFSG). This exception does not apply to products: Anyone who manufactures or sells affected products must meet the requirements regardless of the size of the company.
Why does the BFSG affect your PDF documents?
Accessibility doesn't end at the website. A service must be accessible, including the information required for its use - this also includes documents. In practice, this means: contracts, forms, invoices, price sheets and product information in PDF format are part of the service when consumers receive or access them during the ordering, contracting or service process.
An inaccessible PDF can therefore question the conformity of the entire digital offering - even if the website is implemented in an exemplary manner. This also applies to older documents, provided they continue to be part of your ongoing offer. We explain in detail what makes a PDF technically accessible PDF accessibility with AI.
What technical standard applies to PDFs?
The BFSG itself does not specify any technical standards. In practice, implementation is based on the European standard EN 301 549, which describes the accessibility requirements for IT products and services - including documents outside the web. The content of the standard refers to the Web Content Accessibility Guidelines (WCAG); The current state of the art is WCAG 2.2.
The ISO standard specifies this for PDF documents PDF/UA – currently PDF/UA-2 – how these requirements are to be implemented technically: with complete tags, correct reading order, alt text for images and clearly marked tables and form fields. You can find more in-depth information in our articles Understanding PDF/UA and WCAG for PDF documents.
What sanctions are there for violations?
The BFSG is enforced at three levels:
- Market surveillance: The market surveillance authorities of the federal states examine products and services - also on an ad hoc basis, for example after complaints from consumers or associations. You can request that violations be remedied within a set deadline.
- Fines: Depending on the offense, violations of the obligations of the BFSG can result in fines of up to 100.000 € be punished (§ 37 BFSG).
- Prohibition: If a violation persists, the authority can restrict or prohibit the provision of the service or stop the distribution of a product.
In addition to the official measures, the practical damage also weighs in: If you do not make documents accessible, you exclude customers with visual or reading impairments from central processes - from the conclusion of the contract to the invoice verification.
What transitional regulations are there?
The BFSG provides for a few, narrowly defined transitional regulations in Section 38. Two examples:
- Service contracts, which were closed before June 28, 2025, may continue to exist unchanged until June 27, 2030 at the latest.
- Self-service terminals, which were lawfully used before the deadline, may continue to be operated until the end of their useful life, but no more than 15 years after they were put into operation.
Important: There is no comparable grace period for PDF documents that are part of currently provided digital services. You must meet the requirements today.
BFSG and BITV 2.0 in comparison
The BFSG addresses the private sector. For authorities, universities and other public bodies, BITV 2.0 applies additionally or primarily - with the same technical foundation.
| feature | BFSG | BITV 2.0 |
|---|---|---|
| addressees | Private economic actors: manufacturers, importers, traders, service providers | Federal public bodies; The states have their own, largely parallel regulations |
| Legal basis | European Accessibility Act (Directive (EU) 2019/882), BFSG with BFSGV | Directive (EU) 2016/2102, Equal Opportunities for Persons with Disabilities Act (BGG) |
| Object | Certain products and consumer services | Websites, mobile applications and electronic documents of public bodies |
| Valid since | June 28, 2025 | 2011; New version 2019 |
| Technical scale | EN 301 549, WCAG; for PDFs PDF/UA | EN 301 549, WCAG; for PDFs PDF/UA |
| enforcement | Market surveillance, fines of up to €100,000 (Section 37 BFSG), prohibition | Monitoring bodies, enforcement and arbitration procedures |
The guide covers the obligations of public bodies in detail BITV 2.0: Accessible PDFs in the public sector; You can read about what this means in concrete terms on our pages Authorities and Higher education.
What you should do now
The path to BFSG-compliant PDF holdings can be structured in four steps:
- Inventory: Identify which PDF documents are part of your affected services - from contract documents to forms to product and pricing information. Check the current status; Automated tests typically deliver results in seconds.
- Prioritization: Start with the documents that consumers actively need in the order, contract or service process. This is where the legal and practical relevance is greatest.
- Automated correction: Manual rework does not scale for larger document collections - the comparison shows which methods are available and when which one is suitable Make PDF accessible. Accessful automatically audits and remediates PDFs at the structural level - tags, reading order, alternative text - while leaving the layout and content unchanged. Batch processing of thousands of documents is also possible. The page shows how this works in detail How it works.
- Evidence: Document the implementation. Accessful creates an audit-proof audit trail for each remediated document, which you can use with inspection bodies and in an audit. In addition, our remediation guarantee applies: If a document remediated by Accessful is not recognized as accessible during an accessibility audit, we will remediate it free of charge - quickly, easily and at no additional cost.
This turns the legal obligation into a plannable process - and your documents become usable for all customers, regardless of restrictions.