The BFSG for websites: an opportunity or an overreach in the name of regulatory compliance?
In 2023 and 2024, there was a great deal of hype surrounding the Accessibility Enhancement Act (BFSG), reminiscent of the introduction of the General Data Protection Regulation (GDPR). The Act has been in force since 28 June 2025. It is time for a sober assessment of how it is working in practice.
Who is affected, and why this remained unclear for so long
The BFSG applies to services for consumers; in the case of websites, this primarily concerns e-commerce. Anyone who sells online or facilitates bookings falls under its scope, as do, for example, telecommunications, banks, e-books and passenger transport. Micro-enterprises in the service sector are exempt if they have fewer than ten employees and a turnover of no more than two million euros.
Nevertheless, it remained unclear for a long time whether, for example, a contact form on a standard corporate website would already be considered electronic commerce. There was hardly any definitive answer for each individual case. In cases of doubt, it was therefore recommended to implement the requirements across the entire website.
The situation is clear where the law specifically names the sector. For a transport company we have been working with for over ten years, there was never any question as to whether it was affected. We have ensured that its websites are accessible across all brands and languages.
Customers are sceptical at first
The argument in favour of inclusion was less convincing to some clients once the costs of implementation were laid out. Some postponed measures and chose to monitor the market for the time being. Since July 2025, none of our clients has received a warning letter, correspondence from the authorities or a complaint. What remains, above all, is the impression of a regulatory behemoth, much like the GDPR. However, accessibility does not primarily mean additional forms, but rather websites that more people can use. Improved contrast, keyboard navigation and a clear heading structure help all users.
What is required from a technical perspective. The Act does not contain a specific checklist. The BFSG refers, via a regulation, to the state of the art, the EN 301 549 standard and, consequently, to the Web Content Accessibility Guidelines (WCAG) at Level AA. This is underpinned by around 50 success criteria. We encounter the following particularly frequently:
- A contrast ratio of at least 4.5:1 for normal text and 3:1 for large text and control elements
- Text alternatives for informative images; decorative images with deliberately blank alternative text
- Full keyboard navigation with visible focus
- A complete, semantically marked-up heading hierarchy
- Form fields with linked labels and clear error messages
The accessibility statement is often overlooked. Those affected must provide publicly available and accessible information on how the requirements are being implemented. Consumers can lodge a complaint with the market surveillance authority. In theory, fines of up to 100,000 euros are possible.
Craft CMS as the foundation
Accessibility ultimately comes down to the HTML that is delivered. This is where Craft CMS offers the necessary flexibility. Instead of customising ready-made templates or themes, we write the markup ourselves, ensuring it is semantic and free from unnecessary nesting. This allows us to implement landmarks, heading levels and focus order in a targeted manner.
Craft also supports editorial teams in the backend. Images have a field for alternative text, which Craft has been able to populate from metadata since version 5.10. The permitted heading levels can be restricted within the editor. Craft itself aims for AA compliance in accordance with WCAG 2.2 and ATAG 2.0 and transparently discloses its own status.
How we approach projects
The scope ranges from a complete relaunch, where accessibility is incorporated into the concept and design from the outset, to the targeted overhaul of existing websites. Keyboard navigation is usually the most labour-intensive aspect. Focus order and visible focus affect menus, drop-down menus and overlays. This is often followed by contrast, as brand colours do not always meet the required standards. High-contrast variants can be integrated into the design system for text and control elements.
Many problems stem from invisible details: forms must display errors clearly, drop-down menus must communicate their status to screen readers, and content such as headings or alternative text must be correctly marked up. Accessibility must therefore also be integrated into the editorial process. We would always start with an audit rather than a relaunch. Initially, axe and Lighthouse help to identify obvious errors. This is followed by manual testing using a keyboard, zoom and screen readers, as well as our own checklist. In most cases, it is just a few recurring patterns that cause the majority of errors.
If you want to know where your website stands, an accessible CMS and a thorough audit are the crucial first steps. We can assist with both.
What follows
The technical requirements have been known and well documented for years. What is new, above all, is that they are now binding on private providers and that there is an obligation to explain one’s own status transparently.
Anyone who does not know where their own website stands should therefore start by carrying out an audit rather than launching a relaunch. Those who identify recurring patterns and address them specifically often achieve significantly more than initially expected.