Overview: Who must be accessible?
The Accessibility Reinforcement Act (BFSG) 2025 affects many companies and public bodies, but not all are equally obligated. Our overview table shows you at a glance which criteria are decisive and whether your website or web shop must be designed to be accessible.
Does your website need to be accessible? Find out!
Not all companies and organisations are equally obliged to implement accessibility. The legal requirements depend on various factors – from the type of your organisation to the target group of your website to the products and services you offer.
To make it easier for you to assess this, we have created a flowchart. Answer the relevant questions step by step and at the end you will receive a clear answer as to whether your website must be accessible.
Detailed overview of the criteria
Our table provides you with a comprehensive overview of the relevant accessibility criteria. It is designed to help you better understand and classify the individual aspects.
Use the flowchart above to get a good estimate of your individual commitment. The table serves as an additional guide to help you deal with the individual factors in a targeted manner.
| Criterion | Must be accessible | Does not have to be accessible |
|---|---|---|
Number of employees The BFSG targets medium-sized and larger companies that appeal to consumers. | Companies with more than 10 employees | Companies with less than 10 employees |
Business model Only offers that are directed at end consumers are covered by the law. | B2C (business-to-consumer), e.g. online shops, banks, insurance companies | B2B (business-to-business), e.g. wholesale without end consumer contact |
Annual turnover The turnover limit supplements the employee regulation in order to cover economically relevant companies. | Over 2 million euros | Up to 2 million euros |
Type of website/content Everything that is publicly accessible to consumers must be designed to be accessible. | Publicly accessible websites, apps and platforms | Internal tools, portals or applications that are only accessible to employees |
Target audience of the website Consumer protection is at the heart of the law. | End users (private individuals), e.g. online shops, booking portals | Only other companies, e.g. platforms for business customers |
Industry Digital offerings in specific B2C industries such as banking and insurance are also included. | Industries with a high proportion of end consumers, e.g. tourism, telecommunications, healthcare | Industries without direct consumer contact, e.g. mechanical engineering |
Public authorities Public authorities are fully obliged to implement accessibility. | All public bodies, e.g. authorities, universities, public transport companies | None |
Product and service use The aim is to make consumer use as inclusive as possible. | Services used by the general public, e.g. payment services, passenger transport | Services with a very limited target group, e.g. specialised business services |
Type of products Digital accessibility is the focus of the law. | Products with digital access, e.g. software, booking platforms, online shops | Products without digital access, e.g. purely physical or industrial goods |
Mobile apps Apps are considered equivalent to websites and must meet the same standards. | Apps that are publicly available in the App Store | Internal company apps |
E-commerce Smaller e-commerce offerings for consumers are also covered by the regulation if the turnover or employee thresholds apply. | Shops that sell goods or services to consumers | Wholesale or platforms with a purely B2B focus |
Accessibility of PDFs PDF documents provided via websites or apps must also be designed to be accessible. | Publicly available documents, e.g. invoices, contracts, product descriptions | Internal documents without public access |
Multimedia content Videos and audio files must be equipped with subtitles, audio descriptions or other aids, for example. | Videos, audio content or live streams relevant to consumers | Internal videos without public access |
Exceptions The burden of proof lies with the company and must be specifically documented. | If implementation is disproportionately costly, e.g. for very small businesses | No obligation in cases of proven impossibility or disproportionateness |
Technology dependency Digital accessibility is a key focus of the BFSG. | Companies that use technologies such as websites, apps or digital platforms as their primary sales or contact channels | Companies whose offerings are provided entirely offline or without digital accessibility |
Explanatory notes to the table
If different criteria give conflicting indications as to whether there is an obligation to ensure accessibility under the BFSG 2025, you should consider the following aspects in your assessment:
1. Prioritise legal requirements
The legal requirements of the BFSG are based on binding thresholds, such as the number of employees or annual turnover. These criteria are paramount and must always be observed:
- Companies with more than 10 employees or an annual turnover of more than €2 million are required to do so.
- Smaller companies or those that do not reach the turnover threshold are exempt, unless they provide public services.
Example:
Your company has 8 employees but targets end consumers (B2C). In this case, the turnover threshold applies: if your turnover exceeds €2 million, you are obliged to ensure accessibility.
2. Target audience of the website
Another key factor is the target audience of your website:
- Websites intended for end users (B2C) must be designed to be accessible.
- Pure B2B platforms (without consumer access) are generally not subject to this obligation.
Example:
A wholesale platform for business customers (B2B) is not affected, even if it has more than 10 employees. An e-commerce site for consumers (B2C), on the other hand, is affected.
3. Type of content and services
The obligation to provide accessibility also depends on the public accessibility and relevance of your content or services:
- Content that is publicly accessible and frequently used (e.g. online shops, booking platforms) must be accessible.
- Internal tools, portals or niche offerings are generally excluded.
Example:
A public travel booking portal must be accessible, whereas an internal booking system for employees is not covered by the law.
4. Disproportionate rule
The BFSG allows exceptions if implementation is disproportionate. Economic, technical and organisational factors play a role here:
- Small businesses can claim disproportionate burden, but must document this.
- Even larger companies can prove that implementation is not technically or financially feasible.
Example:
A start-up with 12 employees and minimal annual turnover could document that implementing accessibility would represent an unreasonable financial burden.
5. Case-by-case assessment in the event of conflicting criteria
If there are conflicting criteria, each case should be examined individually. The following steps will help in this process:
- First, check the legal requirements (number of employees, turnover, B2C/B2B).
- Note specific exceptions, e.g. for industries or services.
- Consider disproportionate requirements if you are a small or medium-sized enterprise.
- Document your decision so that you can argue your case in a legally secure manner in the event of a dispute.
Conclusion
In the event of conflicting criteria, the following applies:
- Legal requirements (e.g. number of employees and turnover) have the highest priority.
- The target audience and type of content determine whether there is an obligation.
- The disproportionate rule offers some leeway, but it needs to be well documented.
If you are unsure, it is advisable to seek legal advice or consult accessibility experts in order to make an informed decision.