Deadlines and Obligations
2025 is an important year for accessibility and there are legal deadlines and obligations to consider. Here's an overview.
Accessible websites
Digital accessibility will become mandatory for many companies from 2025 onwards. Specifically, as of June 28, 2025, a legal obligation comes into effect in Germany requiring websites and mobile apps to be made accessible. The legal basis for this is the German Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG), which transposes the EU’s European Accessibility Act (EAA) into national law. This establishes uniform rules across Europe—aligned with the EN 301 549 standard and the international Web Content Accessibility Guidelines (WCAG 2.1 AA). In this article, you will learn which deadlines and legal obligations regarding accessibility apply to you and your website, who is affected (and who isn’t), and what needs to be done by 2025 to meet these requirements.
From June 2025 onwards, an accessible website is no longer merely "nice to have" but a legal requirement for many providers. Web accessibility ensures that all users—with or without disabilities—can fully use digital services.
Legal Foundations for Web Accessibility
Mandatory rules on web accessibility for public institutions have been in place for several years already. In Germany, the Barrier-Free Information Technology Regulation (Barrierefreie-Informationstechnik-Verordnung, BITV 2.0) stipulates that websites and mobile apps of federal authorities must be accessible. These requirements are also based on the European EN 301 549 standard, itself derived from the WCAG guidelines. For new public sector websites, these obligations applied EU-wide as of September 2019, for existing public websites from September 2020, and since June 2021 also for mobile apps. Thus, for public institutions, accessibility has already become a “must-have.”
Now, the private sector is following suit: With the adoption of the European Accessibility Act, the EU decided in 2019 that certain digital products and services must be offered accessibly for consumers. This directive had to be transposed into national law by June 2022. In Germany, this happened through the Accessibility Strengthening Act (BFSG), which will become enforceable on June 28, 2025. Similar laws will apply from 2025 in all EU member states (in Austria, for instance, through the Accessibility Act (Barrierefreiheitsgesetz, BaFG)). This means that, starting from the deadline of June 28, 2025, digital accessibility also becomes a legal obligation for private companies.
Important note: The new rules do not apply to all websites, but specifically to those services falling under the categories defined in the law. In the following sections, we’ll examine in detail which websites must comply with accessibility obligations, what deadlines must be observed, and which exceptions exist.
Which websites must comply by June 28, 2025?
As of June 28, 2025, all websites and online services falling within the scope of the BFSG must be accessible. The law specifically targets “private market operators” offering digital products or services to consumers. The crucial criterion is whether your online presence qualifies as a “service provided via electronic commerce”—in simpler terms: whether you provide products or services for end consumers (B2C) through your website, enabling contract formation online. Typical examples include online shops and booking portals. But many other websites also fall into this category, as soon as they offer interactive features for consumers, such as an online order form, contact form, or appointment-booking tool on a local business website. Even if your business mainly operates as a local storefront, your website will still be subject to the BFSG once consumers can, for instance, book appointments or order products online.
However, websites exclusively targeting business-to-business (B2B) interactions or purely informational websites without consumer interaction (no shopping, ordering, or booking functions) are not affected by the law. Personal websites (e.g., purely personal or family-run sites) are also exempt. Nevertheless, it’s important to clearly verify that supposed B2B offerings indeed exclusively address business users—if a site in practice targets consumers, it cannot be exempted.
Deadlines at a glance
For all relevant websites and apps, the critical date is generally June 28, 2025. Websites and services launched or provided from June 29, 2025 onward must be fully accessible from day one. There is no transitional period for existing websites—websites and online stores must be fully compliant by this date. (Although BFSG does allow certain transition periods in other contexts—for instance, some self-service terminals may continue to be used until 2040—for websites and online services, June 2025 remains absolute.)
To contextualize: Public institutions had earlier deadlines for accessibility compliance. New public sector websites have had to be accessible since September 2019, older public websites since September 2020, and public sector mobile apps since June 2021. These deadlines, however, were strictly for government agencies. For private sector companies, the requirement for accessibility only takes effect in 2025, which, given the necessary adjustments, no longer provides an extended grace period. Therefore, it is advisable to begin adapting early—ideally right now—to remove all technical and content-related barriers in good time.
Who must implement the new requirements?
All providers falling into the categories mentioned above are generally obligated, irrespective of industry or company size. The obligations equally affect manufacturers, retailers, importers, and service providers, as long as they offer relevant products or services for consumers. Examples include: a software company providing a web application for end users must ensure it is accessible; a retailer operating an online shop must ensure accessibility of their shop; and banks must make their online banking platforms accessible, among others. Even sole proprietors and freelancers are included if they offer services online to consumers. The BFSG is legally binding and must be complied with by all economic actors, regardless of whether they are a small startup or a large corporation.
Exceptions: However, there are two important exceptions
Micro-enterprises
Companies with fewer than 10 employees and annual turnover or balance sheet total of no more than €2 million are classified as micro-enterprises. These entities are exempt from BFSG requirements—the new accessibility rules do not formally apply to them. (Important: Both criteria—employee number and turnover/balance sheet—must be met.) If your company falls into this category, be prepared to provide evidence upon request from regulatory authorities. Tip: Even if legally exempt, investing in accessibility is beneficial—expanding your potential customer base and improving usability for all users.
Purely private or B2B offerings
Services exclusively targeting other businesses (B2B) or a closed, private user group are not subject to BFSG. The key factor is the target audience: as long as end consumers are not addressed, the obligations do not apply. However, if an offering is effectively open to the general public, it counts as a consumer-facing service. Similarly, internal company systems not publicly accessible are also exempt.
Undue burden or fundamental alteration
n certain cases, companies may invoke "undue burden" clauses. If compliance with accessibility requirements would result in a fundamental alteration of the product’s nature or impose a demonstrably disproportionate financial or organizational burden, companies may claim a temporary exemption. These exceptions are narrowly defined and must be documented. Criteria for such exceptions are specified in Annex 4 of the law, and any claim of exemption must be reported to the market surveillance authority. Practically, these clauses play a role only in exceptional cases—the threshold for "undue burden" is high and must be clearly justified.
What exactly must be done by 2025?
If your website falls within the scope of the BFSG, you must implement all accessibility requirements by June 2025. In practical terms, this essentially means:
Implementing technical standards
Your website or online shop must comply with the EN 301 549 standard, which refers directly to WCAG 2.1 AA for web content. Practically, this means fulfilling all success criteria of WCAG levels A and AA—such as providing alternative texts for images, ensuring sufficient color contrasts, enabling keyboard operability, and ensuring content clarity. For web services, the requirements of Chapter 9 of EN 301 549 (relating specifically to websites and documents) are particularly relevant. Those who have already designed their website according to WCAG 2.1 AA standards are thus already well prepared. (Note: While WCAG 2.2 was published in 2022, it has not yet been incorporated into EN 301 549. WCAG 2.1 remains the applicable standard for now.)*
Providing an Accessibility Statement
Your website must include an easily accessible accessibility statement clearly indicating the extent of compliance with applicable standards and specifying any areas that might not yet be fully accessible. Such statements have long been mandatory for public institutions, and will become a requirement for private providers starting in 2025. This statement should also include information on feedback opportunities.
Establishing a feedback mechanism
Your website must offer users a contact method to report barriers or provide feedback on accessibility. Typically, this is a simple contact form or a dedicated email address on the accessibility page. Crucially, this feedback channel must be accessible from every page (similar to the accessibility statement itself), and incoming messages should be promptly addressed.
Considering third-party content
If your website incorporates content or features from third-party providers (e.g., maps, videos, payment widgets), you as the website operator are responsible for ensuring these components are also accessible. Wherever possible, choose third-party solutions that are accessible. If this is not feasible, document such instances clearly in your accessibility statement and, if possible, provide alternative solutions. For example, if an embedded map widget is not accessible, you could alternatively provide a simple address list of key locations.
Consequences of Non-compliance
If an online presence is not provided in an accessible manner after June 28, 2025, serious consequences may ensue. Initially, the responsible market surveillance authorities can intervene if violations are identified. Typically, companies will first receive a notice requiring them to establish accessibility or rectify deficiencies. Should companies fail to comply with this request, authorities can initiate further steps: in extreme cases, they can order the temporary suspension of electronic commerce until accessibility is ensured. Additionally, significant fines are possible, which, depending on the severity of the violations, can reach up to €100,000 per violation.
Apart from government oversight, there is also a risk of warnings and legal actions. Violations of BFSG regulations are likely to be considered unfair competition under Germany’s Competition Act (UWG), as these constitute market conduct rules. This means competitors or recognized associations can issue warnings to companies ignoring accessibility rules, potentially leading to injunctions or court actions. Consumers also have the right to file complaints with state authorities if they encounter accessibility barriers. They may even pursue legal action—either individually before administrative courts or represented by consumer associations.
Compliance with the requirements will thus be actively enforced. Companies should therefore not underestimate the issue. From 2025 onward, accessibility will no longer be an optional bonus feature but a legal obligation, and failing to comply can have significant financial and reputational consequences.
The deadline is set:
Prepare your website for full accessibility by June 28, 2025.
The introduction of binding deadlines and obligations for web accessibility marks a milestone for digital inclusion. From mid-2025 onwards, the goal is clear: everyone should be able to fully use online services without limitations. For companies, this initially means extra effort—but it also presents significant opportunities. An accessible website reaches around 10% more potential customers in Germany alone (reflecting the proportion of officially recognized disabilities), improves usability for all visitors, and demonstrates social responsibility. Companies that take action early have sufficient time until 2025 to optimize their offerings. Use the remaining period to systematically remove barriers step-by-step—this approach ensures compliance with legal obligations and provides the added benefit of a modern, user-friendly web presence.
In short: Remember the date June 28, 2025. Make sure your website is fully accessible in accordance with the relevant standards by this date. Communicate your accessibility measures transparently (via your accessibility statement) and avoid leaving loopholes for any barriers.
This preparation will position you ideally—not only for legal compliance but also to effectively serve a diverse and inclusive customer base in the digital world.