Digital accessibility from 2025: laws and practical requirements at a glance

In this article, we explain how the laws and guidelines on digital accessibility relate to each other and what specific requirements result from them for your website. All this in case you are obliged to implement accessibility.

The basis for the legal obligation for digital accessibility is Directive (EU) 2019/882, also known as the European Accessibility Act (EAA). It was adopted at EU level and obliges all member states to create regulations that ensure barrier-free access to digital products and services.

There are two central sets of regulations for implementing this EU directive into German law:

• The Barrierefreiheitsstärkungsgesetz (BFSG) regulates accessibility for private companies, e.g. online stores, banks or platform operators. It comes into force on June 28, 2025.
• The Barrier-free Information Technology Ordinance (BITV 2.0) applies to public bodies such as authorities, schools and ministries. It has been in place since 2011, but was amended in 2019.

Both regulations stipulate that digital products and services must be designed to be accessible. What they do not provide, however, is a detailed technical description.

Both the BFSG and the BITV refer to so-called harmonized European standards - and this is where EN 301 549 comes into play. As a technical standard, it defines how accessibility is to be implemented in concrete terms.

EN 301 549 is therefore regarded as a practical guide when it comes to making digital content such as websites, apps, software, documents or hardware accessible to everyone.

A central chapter of EN 301 549 is Chapter 9, which deals specifically with web content. This is where the Web Content Accessibility Guidelines (WCAG) are incorporated.

The WCAG were developed by the World Wide Web Consortium (W3C) and are considered the global standard for accessible web design. The current version WCAG 2.1 contains 78 success criteria, which are divided into three levels:

• A: Basic requirements (e.g. alternative text for images)
• AA: Recommended standard (e.g. color contrasts, keyboard operability)
• AAA: Advanced requirements (e.g. particularly simple language)

Levels A and AA are mandatory for legal accessibility. These requirements are technically specified in EN 301 549.

Imagine you are a medium-sized company in Germany that operates an online store. You would like to know whether you are obliged to implement accessibility and, if so, what exactly you have to implement.

For private providers like you...

• the BFSG applies because it is a private-sector offering (provided there are no exceptions).
• will be subject to the legal obligation to make digital offerings accessible from June 28, 2025 as a result of the BFSG.

If your online store falls under the BFSG, you must meet the following requirements as of June 28, 2025 for your website to be considered accessible according to EN 301 549:

Compliance with WCAG 2.1 at level AA

This includes, for example:

• Contrasts: Texts must be easy to read (e.g. no light gray on white)
• Alternative texts for images
• Keyboard operability for all functions
• Forms with labels and meaningful order
• Clear page structure and navigation

What does Level AA mean in detail?

You can find a complete list of all Level AA requirements of WCAG 2.1 directly from the W3C (World Wide Web Consortium) in a well-structured overview - including filter options by level, technology and content type. There you can specifically check which points are relevant for your website.

Provide accessible documents

All PDFs or other downloads must be provided with tags, alternative texts and a logical reading order.

Make videos accessible

• Subtitles (synchronous and permanently visible)
• Audio descriptions if required
• Operable video players with keyboard accessibility

Publish an accessibility statement

An easy-to-find page that provides information about this:

• Which content is accessible (and which is not)
• Date of last check
• Contact option for feedback

Set up a feedback option

Users must be able to report barriers - e.g. via a form or an email address.

Accessible support

Your help pages, chats, FAQs and support channels must also be accessible to all.

The following table provides a clear summary of all relevant legal principles. This will give you a quick overview of the most important regulations in the area of digital accessibility. If you as a company have to comply with the obligation under the BFSG, it is not enough to just be “somehow accessible”.

You must comply with EN 301 549 - and thus also implement WCAG 2.1 at Level A and AA.

This turns an EU directive into a clear roadmap with concrete measures - and your digital offering is not only legally compliant, but also fully accessible for all users. At the same time, you create the basis for an inclusive user experience, strengthen trust in your digital solution and position yourself as a responsible and future-oriented company in the digital space.