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European Accessibility Act: Germany (BFSG)
DE- Applies from
- 2025-06-28
- Maximum penalty
- €100,000
- Enforcement authority
- Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF) — a joint authority of all 16 federal states, based in Magdeburg, operating since 26 September 2025 — https://www.mlbf-barrierefrei.de/
- Microenterprise exemption
- Yes — under the EAA's EU-wide microenterprise exemption for services
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- National law
- Barrierefreiheitsstärkungsgesetz (BFSG)
- Notes
- Fines range from €10,000 to €100,000 depending on the violation (§37 BFSG). The higher tier applies to placing non-compliant products on the market, missing CE marking, and unlawful service provision. The microenterprise exemption (fewer than 10 employees and turnover or balance sheet ≤ €2m) applies only to services — a microenterprise selling a covered product must still make that product accessible.
Who is obligated in Germany
The BFSG covers a defined list of products and services, not businesses in general: consumer computers and operating systems, smartphones, tablets, e-book readers, self-service terminals such as ATMs, ticket and check-in machines, and telecommunications and audiovisual media equipment. On the services side it covers e-commerce, banking services for consumers, e-books, telecommunications services, and passenger transport information (websites, apps, timetables, ticketing). The microenterprise exemption — fewer than 10 employees and annual turnover or balance sheet total of €2 million or less — applies only to the services obligations. A microenterprise that sells a covered product still has to make that product accessible; there is no size exemption on the product side.
What happens if you don't comply
The MLBF acts on either a complaint or its own inspection. The standard sequence is a deficiency notice giving the business a deadline to fix the problem; a fine procedure (Bußgeldverfahren) only follows if the deadline passes without a fix. Fines then range from €10,000 for most violations up to €100,000 for the more serious ones — placing a non-compliant product on the market, missing CE marking, or providing a service without meeting the requirements. In practice this means a first report rarely results in an immediate fine — the business gets a chance to remediate first.
How this differs from the EU baseline
The Directive leaves each member state to decide how to organise enforcement; Germany's distinctive choice was to pool it into one joint authority for all 16 federal states — the MLBF — rather than run 16 separate state-level regulators the way some other member states have. Germany also layered its existing BGG mediation office (originally built for public-sector accessibility complaints) on top of the BFSG, giving consumers a free, informal complaint route that the Directive itself does not require.
How to complain
Consumers can use the free Schlichtungsstelle BGG mediation service: submit a written complaint (letter, fax, or email) within two months of encountering the barrier, ideally with a screenshot or other documentation. The mediation office then contacts the business to seek a resolution. Alternatively, a complaint can be filed informally and directly with the MLBF, which is required to review it and report back to the complainant.
Frequently asked questions about the EAA in Germany
- What is the maximum EAA fine in Germany?
- The maximum penalty is €100,000. Fines range from €10,000 to €100,000 depending on the violation (§37 BFSG).
- Who enforces the European Accessibility Act in Germany?
- Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF) — a joint authority of all 16 federal states, based in Magdeburg, operating since 26 September 2025. Details are published at https://www.mlbf-barrierefrei.de/.
- Since when does the EAA apply in Germany?
- The requirements apply from 28 June 2025, the EU-wide date, transposed into Germany by Barrierefreiheitsstärkungsgesetz (BFSG).
- Are small businesses exempt from the EAA in Germany?
- Only microenterprises — fewer than 10 staff and annual turnover or balance sheet total of €2 million or less — and only for services. A microenterprise in Germany that places a covered product on the market still has to make that product accessible.
- How do I report an inaccessible website in Germany?
- Complaints go to the national complaint route at https://www.schlichtungsstelle-bgg.de/Webs/SchliBGG/DE/AS/moegliche-antragsgegner/barrierefreiheitsstaerkungsgesetz/barrierefreiheitsstaerkungsgesetz-node.html. The enforcement authority above handles market surveillance separately.
Official source: https://www.gesetze-im-internet.de/bfsg/__37.html
Verified on 2026-09-29. This page is not legal advice — verify against the official source above before making compliance decisions.