The Accessibility Strengthening Act – What App Developers Need to Know Now

Introduction

Accessibility simply means: digital offerings — websites, apps, payment terminals, e-books, and other technical products — should be usable by everyone, including people with visual, hearing, or motor impairments. It's not just about legal obligations — it's about enabling as many people as possible to participate in digital life without barriers. For example, a website must be designed so that a screen reader can correctly read out content, or an app must be fully operable via keyboard or, alternatively, by voice.

With the new Accessibility Strengthening Act (BFSG), these requirements are now more binding: The law implements the European directive European Accessibility Act (EAA) into German law. The goal is that in the future, many digital products and services may only be offered if they meet certain accessibility requirements — so that people with disabilities can shop, communicate, and use digital services on an equal footing.

Important for all readers: The BFSG comes into force with fixed deadlines (the key date is June 28, 2025). From this date, obligations apply to many companies and providers of digital offerings — meaning: those who do not adapt their products or services accordingly risk not only complaints but also legal consequences. At the same time, accessibility opens up new opportunities: better user-friendliness, greater reach, and a more positive brand image.

Why you should understand this as a layperson: Accessibility affects everyone who uses digital services — so practically everyone. If online shops, banking apps, or timetable systems are not accessible, they exclude parts of the population. This is not only unfair but also hinders participation in everyday life. The BFSG aims to change exactly that and ensure that digital offerings are designed so that everyone can really use them.

In this article, I explain step by step what the BFSG specifically regulates, which companies and products are affected, what concrete requirements providers face, and what steps you should take now — especially with a focus on app development. If you are a developer, product manager, or simply curious about what is changing, you will find a clear and practical introduction here.

What does the new law say?

Since June 28, 2025, it is official: The Accessibility Strengthening Act (BFSG) applies in Germany and has thus become legally binding for many companies and service providers. While it was previously known mainly as a "forthcoming EU directive," it is now a reality — and many companies are facing the challenge of making their digital products and services accessible.

The BFSG implements the European Accessibility Act (EAA) into German law. The aim of this EU-wide law is to enable people with disabilities to have equal access to digital products and services. So it's about much more than just technology — it's about social participation.

The core of the law

The law stipulates that digital products and services must be accessible if they fall within its scope. This includes, among others:

• Computers, tablets, and smartphones

• ATMs, ticket machines, and payment terminals

• E-book readers

• Telecommunications services (e.g., internet providers, telephone providers)

• Online shops

• Banking services

• Apps and websites of public and private providers

This means: If someone offers an app or website through which goods are sold, information is provided, or communication is enabled, then this application must be designed so that it can also be used by people with disabilities – for example, people with visual or hearing impairments, motor limitations, or cognitive differences.

Accessibility is not an "extra," but the standard

Importantly: Accessibility is no longer seen as a voluntary extra, but as a requirement. Digital offerings must be designed so that they are operable regardless of individual abilities.

A simple example:
An online shop must be programmed so that a screen reader can correctly read out product descriptions. Buttons must be sensibly labeled (not just "Button1"), colors must not be the only way information is conveyed (e.g., "green = available," "red = sold out" is not sufficient), and forms must be operable via keyboard or voice control.

To make this practical, the law refers to technical standards, especially EN 301 549 – which describes how digital products must be designed to be considered accessible. This, in turn, is based on the WCAG (Web Content Accessibility Guidelines), the international guidelines for accessible web design.

Who is affected?

The law affects companies that offer digital products or services to consumers. It does not matter whether it is a large company or a small start-up – what matters is whether the service offered falls within the scope.

Small businesses with fewer than 10 employees and annual sales under 2 million euros are exempt from the obligation in many cases, but they should still take accessibility seriously: firstly, because many customers value it, and secondly, because legal requirements are likely to be expanded in the future.

Why the law is so important now

The deadline was well known – since 2019 it has been clear that June 28, 2025, would be the key date. Nevertheless, many companies have postponed the issue for a long time. Now, in October 2025, it is clear that many providers are still in the middle of implementation or are receiving initial feedback from testing bodies and associations.

In practice, this means:

• Providers must be able to prove that they are making efforts towards accessibility.

• Complaints can be filed if a product or service is not accessible.

• In case of violations, fines or bans may be imposed, especially if accessibility has been deliberately ignored.

A step towards digital inclusion

Despite the new obligations, the law is a major step forward: It ensures that accessibility is finally understood as an integral part of modern digital products – not as a special requirement, but as a mark of quality.

In the end, all users benefit: clear structures, good contrasts, understandable texts, alternative ways of operation – all this makes digital offerings not only inclusive but also more user-friendly.

The BFSG is thus an important step towards a digital world that excludes no one – and shows that technology can be not only efficient but also humane.

Who is affected by the new law?

The Accessibility Strengthening Act (BFSG) is aimed at everyone who offers digital products or services to consumers – that is, those who actively participate in the market and provide digital interfaces through which customers can interact. It therefore affects not only large corporations but also small and medium-sized enterprises that work with digital offerings.

Companies and sectors in focus

The following areas are particularly affected:

• Online retail:
  Every webshop through which consumers can buy goods or services must be accessible. This applies regardless of whether it is a large mail-order company or a small niche online shop.
  Users should be able to find products, add them to the cart, and pay – even if they use screen reading software or alternative input methods.

• Banks and financial service providers:
  Online banking portals, banking apps, ATMs, and payment terminals must be accessible. This means, for example, that important information can also be captured by people with visual impairments or that machines have acoustic outputs.

• Telecommunications providers:
  Companies that provide internet or telephone services must ensure that their customer portals, contract information, and communication channels are accessible.

• E-books and reading devices:
  Publishers, e-book platforms, and manufacturers of reading devices must ensure that digital books and their software are compatible with screen readers and that font size, color, and contrast can be adjusted.

• Software and app developers:
  The law is particularly relevant for developers of digital applications. Apps intended for consumers – whether a shopping app, a booking platform, an online banking tool, or a communication app – must now be designed to be accessible.

This means not only that the app must work technically, but also that it is understandable, navigable, and accessible for various impairments. For example, controls must be large enough, labels must be meaningful, and color combinations must provide sufficient contrast.

Public and private providers

The BFSG supplements existing regulations that already apply to the public sector. Authorities, public institutions, and government portals were already required by the Equal Opportunities for Persons with Disabilities Act (BGG) to make their digital offerings accessible.

What is new now: Private providers must also comply – as long as they offer their products or services to consumers. This ends the previous separation between public and private responsibility for accessibility.

Small businesses and exceptions

Not every company is fully obligated. The law provides relief for micro-enterprises – that is, companies with fewer than 10 employees and annual sales under 2 million euros.

These companies are not necessarily required to make their digital offerings accessible if this would represent a disproportionate burden. Nevertheless, it is advisable even for small providers to implement accessibility as far as possible – because:

1. It improves overall user-friendliness.

2. It is increasingly expected by customers.

3. Funding programs and technical aids make implementation easier today than a few years ago.

Also, as soon as a small company grows or distributes an app in cooperation with larger partners, the obligation can quickly apply.

Manufacturers and retailers

Manufacturers of digital products (e.g., tablets, reading devices, terminals) and retailers who sell such products are also affected by the BFSG. They must ensure that their devices and their user interfaces are accessible and that the instructions for use are provided in an understandable and accessible form – for example, digitally readable and compatible with screen readers.

Almost all digital providers are affected

In summary:
If you offer a digital product or service that is used by end consumers, the BFSG usually affects you directly or indirectly.

Even if you are not directly obligated, accessibility will increasingly become a quality feature that is demanded – by customers, business partners, and probably also by further legal requirements in the future.

Accessibility is therefore not a "trend topic," but a new basic requirement for digital products in Europe.

What steps should you take now?

Since June 28, 2025, the Accessibility Strengthening Act (BFSG) has been in force – and now is the right time to take action. Even if you have already implemented initial measures, it is worth taking a critical look at whether your digital offering is truly accessible. The requirements are not only technical but also organizational.

Many companies are at a similar point in autumn 2025: They have heard about the new obligation but are not sure how to start or what steps are really necessary. The path to accessibility is clearly structured – if you break it down into sensible stages.

Create understanding – What does accessibility mean in concrete terms?

Before you take action, you should understand what "accessible" means in your specific case. Accessibility includes not only the visual aspect of a website or app but also structure, usability, language, and technology.

The goal is that all people can use your digital content, whether they see, hear, click, or speak.

A few examples make this tangible:

• A user with a visual impairment uses a screen reader – so all content must be accessible by voice.

• A person with motor impairments may not be able to use a mouse – so everything must be operable via keyboard or voice control.

• Color-blind people must not miss important information due to color distinctions alone (e.g., only "red = error," "green = correct" is not sufficient).

• People with cognitive impairments need clear texts, simple wording, and a clear structure.

The better you internalize this basic idea, the easier practical implementation will be.

Review existing offerings

In the second step, you should review all your digital products and services – including websites, apps, software, user interfaces, and also PDF documents or instructions.

First, create an inventory:

• What digital interfaces do you have?

• Who uses them?

• What barriers might currently exist there?

To assess this, you can refer to the WCAG 2.1 (Web Content Accessibility Guidelines). They form the basis of the European standard EN 301 549, which the BFSG refers to.

Important checkpoints include:

• Are all controls labeled and accessible via keyboard?

• Is the contrast between text and background sufficient?

• Can content be enlarged or used via screen reader?

• Are videos provided with subtitles or audio descriptions?

• Is navigation clearly structured and predictable?

For the initial analysis, you can use free tools such as WAVE, axe DevTools, or Lighthouse in Chrome. These provide a good technical basis but do not replace a real user perspective. The best approach is a combination of automated tests and manual feedback – ideally also from people with disabilities.

Create an action plan

After the inventory, you should develop a concrete action plan. It should include the following points:

• Goals: Which areas need to be adapted?

• Priorities: Which barriers are most serious and should be removed first?

• Responsibilities: Who is responsible internally or externally for implementation?

• Timeline: By when should which steps be completed?

If you operate larger applications, a step-by-step implementation is worthwhile: first core functions (e.g., navigation, login, shopping), then additional areas (e.g., FAQ, blog).

Especially for apps, it is advisable to plan accessibility directly into the next update – so adjustments can be efficiently combined with new features.

Implementation and technical adaptation

This is where the real work begins. Depending on the product, this can look very different.

• For websites: Use semantic HTML, apply ARIA roles correctly, optimize contrasts, add alt texts, and make interactive elements operable via keyboard.

• For apps: Use native accessibility APIs from Android and iOS, implement focus control, support dynamic font sizes, and check color contrasts.

• For PDF or multimedia content: Set structure tags, add alternative descriptions, and provide subtitles.

It's not about perfection, but about continuous improvement. Every barrier you remove makes your product usable for more people – and users as well as search engines appreciate that.

Documentation and proof

The BFSG requires companies to be able to prove that they are making efforts towards accessibility. This means you should document all steps:

• What tests were carried out?

• What changes were made?

• What standards were considered (e.g., WCAG 2.1 AA)?

Such documentation shows that you take the issue seriously and helps you prove compliance in the event of a complaint or audit.

Training and awareness in the team

Accessibility is not a one-time task, but an ongoing process.
Only if your team understands the principles will it be consistently considered in development.

Regularly train developers, designers, and content managers on topics such as:

• semantic HTML

• clear language

• accessible color design

• screen reader compatibility

• usability for all

Many agencies and associations now offer practical workshops and online courses on this.

Gather feedback and continuously improve

Even with tests and guidelines, not all barriers can be predicted. That's why real user feedback is invaluable.

Offer your users simple ways to report barriers – for example, via a contact form or an email address specifically for accessibility.
This way, you can identify and fix problems early.

Accessibility is not a project with an end date, but a permanent quality process – similar to security or data protection.

Small steps – big impact

Even if the topic seems complex at first glance: it's not rocket science. Even small adjustments make a big difference.
A clearly structured layout, good contrasts, clean labels, and understandable texts are quick to implement – and they help not only people with disabilities, but all users.

If you start today to see accessibility as an integral part of your digital offering, you are not only acting in compliance with the law – you are making your product future-proof, inclusive, and user-friendly.

Does this affect me as an app developer?

In short: Yes, the Accessibility Strengthening Act affects you directly – at the latest when you develop or distribute apps or digital services for consumers.
Many developers have so far seen the issue as a "requirement for large corporations," but the BFSG draws the line differently: What matters is not the size of the company, but the purpose of your application. If you offer software or apps that people use in everyday life – for shopping, paying, communicating, reading, traveling, or getting information – then you are fundamentally responsible for making them accessible.

Apps clearly fall under the law

The BFSG explicitly refers to "services and products with digital user interfaces" aimed at end consumers. This means apps are just as much included as websites or machines.
Whether you develop a shopping app, a recipe app, a booking platform, a banking tool, or a social app – as soon as it is used publicly, the accessibility requirements apply.

This affects:

• Own products that you distribute yourself (e.g., an app in the Play Store or App Store)

• Contract developments for clients (e.g., if you create an app for a client that is aimed at end users)

• Digital platforms (e.g., marketplaces, streaming or booking services)

So, for example, if you develop apps for other companies as an agency, you are part of the supply chain – and your client must be able to prove that the app is accessible.
This means: You are obliged to consider these requirements in your development and, if necessary, to be able to document them.

What does accessibility mean specifically for app developers?

Accessibility in apps does not mean you have to completely redesign your UI. Rather, it means you consciously develop so that all users can interact with the app – regardless of impairments.

A few examples to make this tangible:

1. Texts and elements must be machine-readable

All buttons, images, and icons should have meaningful labels.
Instead of "Button 1" or just a symbol like 🛒 (cart), it should say, for example: "Add to cart".
This way, a screen reader can correctly read out the function.

2. Focus control

The app must be fully usable without touch operation – i.e., via external keyboards or voice control. The focus must not move illogically or "get stuck."

3. Contrasts and colors

Text and background must have sufficient contrast (at least 4.5:1 for standard text).
Information must not be conveyed by color alone. Example: "Error in red" is not enough – there must also be a symbol or text.

4. Dynamic font sizes

If a user increases the system font size on their smartphone, the layout must not break.
Use relative units (e.g., em, sp, rem) instead of fixed pixel sizes.

5. Alternative texts for images and media

Images, icons, or graphics must have descriptive alternative texts.
Videos should be provided with subtitles or audio descriptions if they contain essential information.

6. Clear structure and simple language

Navigation, texts, and error messages must be understandable and consistent.
Avoid overly technical terms and ensure users know where they are and what they can do.

Technical implementation in practice

The good news: Android and iOS offer extensive tools and interfaces for integrating accessibility easily.

• For Android:
  Use accessibility services such as TalkBack, AccessibilityNodeInfo, and ContentDescription.
  Google also offers the Accessibility Scanner, which analyzes your app and provides suggestions for improvement.

• For iOS:
  Use VoiceOver, Accessibility Labels, and Traits.
  With Xcode, you can simulate and check barriers directly.

If you work with cross-platform frameworks – such as Flutter, React Native, or Ionic – you are not at a disadvantage.
Flutter, for example, offers many accessibility features out of the box (Semantics, FocusNode, MergeSemantics, dynamic text scaling, etc.).
You just have to use them actively and consciously.

Developer obligations

As a developer, you have a shared responsibility – especially if you publish apps or develop them on behalf of clients.
This means concretely:

1. Check and document accessibility
   You should be able to prove that you have followed the guidelines (e.g., WCAG 2.1, EN 301 549).

2. Advise your clients
   If you develop apps for other companies, you must inform them of their legal responsibility. Many clients are not yet aware that they have been obligated since June 2025.

3. Ongoing maintenance and updates
   Accessibility is not a one-off project.
   New features or design changes must be regularly checked to ensure that no new barriers arise.

What happens if you don't take care of it?

Since the law has been in force since June 2025, consumers can now file complaints if they cannot use digital offerings.
In such cases, the market surveillance authorities check whether the product or app violates the BFSG.
If so, fines, warnings, or in extreme cases even sales bans may be imposed.

App stores such as Google Play or the Apple App Store could also pay more attention in the future to whether apps are accessible – similar to data protection or youth protection. So it's not just a legal, but also an economic necessity to take the issue seriously.

Accessibility as a competitive advantage

Many developers initially see accessibility as extra effort. But on closer inspection, it is a real competitive advantage.

Apps that are accessible

• have better ratings,

• are more intuitive and less error-prone,

• are preferred by search engines and app stores,

• and reach a much larger target group – for example, older people who benefit from clear structure and high readability.

Accessibility is therefore no longer a "requirement without benefit," but "quality with impact."

Yes, you are affected and that's a good thing

As an app developer, you have the chance to actively shape digital inclusion.
The Accessibility Strengthening Act forces the industry to finally think consistently user-centered.
If you now firmly integrate accessibility into your development process, you are not only legally on the safe side, but you are creating modern software that works for everyone – as it should have from the start.

Conclusion & Outlook

The Accessibility Strengthening Act (BFSG) marks a decisive turning point in Germany's digital development. What was often just a recommendation or moral obligation in the past has been binding law since June 28, 2025: Digital products and services must be accessible if they are intended for consumers.

Germany has thus not only implemented an EU directive but has taken an important step towards a digital society in which everyone can participate – regardless of physical, sensory, or cognitive limitations.

A win for everyone

Accessibility is often seen as a technical hurdle or extra effort. In reality, it is the opposite: it improves the overall quality of digital products.
An app that is clearly structured, remains readable, provides understandable error messages, and can be operated by keyboard or voice is not only accessible but simply better.

Accessibility means:

• less frustration for users,

• fewer support requests,

• higher user retention,

• and a more modern brand image.

It makes digital offerings more accessible, understandable, and user-friendly – and that benefits everyone, not just people with disabilities.

The new responsibility of developers

Especially for app and web developers, the law brings a new but also exciting responsibility.
Those who develop software today influence who can use digital offerings – and who is excluded.
Accessibility is therefore not only a legal obligation but also a sign of professional and responsible work.

In the coming years, developers, designers, and companies who have addressed this issue early will have a clear advantage:

• They know the standards (e.g., WCAG 2.1, EN 301 549).

• They have proven workflows.

• And they can offer accessibility as a competence and quality feature.

This ability will soon be as naturally expected as data protection or performance optimization.

Challenges still to be addressed

Of course, implementation is still at the beginning in many places.
Many small companies still do not know that the law affects them or how to check accessibility at all.
Even authorities are sometimes unsure how strictly controls will be enforced and what deadlines apply if adjustments are needed.

But this is exactly the phase in which things are moving. Many industry associations, design systems, and frameworks are currently working on accessible standards, components, and training materials. The tools are getting better, and accessibility is increasingly being integrated into development processes – often without even being seen as a separate discipline anymore.

A look ahead

In the coming years, accessibility will become an integral part of digital quality.
It is likely that app stores, web certificates, and government funding programs will require accessibility as a mandatory criterion.
Artificial intelligence will also help to automatically identify and remove barriers – for example, through intelligent text descriptions, automatic subtitling, or adaptive user interfaces.

But in the end, one thing remains crucial:
Accessibility is not just a technical issue, but a matter of attitude.

It expresses the will to design digital products so that they exclude no one.
And that is the core of good software development – creating products that really help people.

The Accessibility Strengthening Act is not an obstacle, but an invitation:
an invitation to design digital experiences so that they are accessible to everyone – clear, understandable, and inclusive.
Those who seize this opportunity are not only developing in compliance with the law, but also in a future-oriented way.