German Accessibility Act (BFSG): what applies to PDF documents

The law in brief

The Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) of July 16, 2021 (Federal Law Gazette, BGBl. I p. 2970) transposes Directive (EU) 2019/882, the European Accessibility Act, and entered into force on June 28, 2025. The detailed requirements are in the BFSG Ordinance (BFSGV) of June 15, 2022 (BGBl. I p. 928). Its latest amendment of July 10, 2026 (BGBl. 2026 I No. 205) changes the rules for self-service terminals (§ 7(2) BFSGV) and telecommunications services (§ 14 BFSGV), not the rules for documents.

Under § 3(1) BFSG, services are accessible when persons with disabilities can find, access and use them in the usual way, without particular difficulty and in principle without help. Under § 14(1), a service provider may only offer or provide a service that meets the BFSGV requirements.

Which services are covered

§ 1(3) BFSG lists services "provided to consumers after June 28, 2025":

1. telecommunications services (except transmission services used for machine-to-machine communication),
2. certain elements of air, bus, rail and waterborne passenger transport, such as websites, mobile apps, electronic tickets and travel information; for urban, suburban and regional transport only interactive self-service terminals,
3. consumer banking services,
4. e-books and dedicated software,
5. e-commerce services.

The law targets services for consumers, meaning natural persons acting for purposes predominantly outside their trade or profession (§ 2 No. 16). Services offered only to businesses are therefore outside the BFSG. E-commerce services under § 2 No. 26 are digital services offered through websites or mobile apps and provided electronically at the individual request of a consumer with a view to concluding a consumer contract.

Exemptions

Micro-enterprises: Under § 3(3) BFSG, the accessibility obligation does not apply to micro-enterprises that offer or provide services. A micro-enterprise under § 2 No. 17 employs fewer than ten persons and has either an annual turnover or an annual balance sheet total of no more than EUR 2 million. The exemption does not cover micro-enterprises dealing with products.

Website and app content: § 1(4) BFSG excludes the following content of websites and mobile apps:

• pre-recorded time-based media published before June 28, 2025,
• office file formats published before June 28, 2025, which covers PDF, Word and similar formats,
• online maps and mapping services, provided that essential information for maps used for navigation is available in an accessible digital form,
• third-party content that the economic operator neither funds, develops nor controls,
• content that qualifies as an archive because it is not updated or edited after June 28, 2025.

Transition periods (§ 38 BFSG)

§ 38 contains no general transition period for websites or documents. For older PDFs the relevant rule is the exclusion in § 1(4) No. 2, not § 38.

What the BFSGV requires for information and documents

§ 12 No. 2 BFSGV covers information about how the service works. Among other things, it must be provided through more than one sensory channel, in text formats from which consumers can generate alternative assistive formats, with sufficient contrast and with an alternative presentation for non-text content. Under § 12 No. 2(h), the digital information needed to provide the service must be perceivable, operable and understandable and must work reliably with assistive technologies, which are the four principles that WCAG also uses. For a PDF this means in practice real text, tags with structure, alternative text and a logical reading order.

For consumer banking, information on how the service works must not exceed language level B2 of the Common European Framework of Reference for Languages (§ 17(2) BFSGV). E-books must, among other things, provide structure and navigation and must not prevent assistive technologies from working (§ 18 BFSGV).

In addition, § 14(1) No. 2 and Annex 3 BFSG require the provider to explain, in its terms and conditions or in another clearly perceivable way, how the service meets the requirements, and to name the competent market surveillance authority. This information must be made available to the public in accessible form. If you publish it as a PDF, that PDF has to be accessible.

Standards: EN 301 549 and WCAG

Under § 4 BFSG, a service is presumed to meet the BFSGV requirements to the extent it conforms to harmonised standards whose references are published in the Official Journal of the EU. For digital services the relevant standard is EN 301 549. Version V4.1.1 was adopted on August 24, 2026 and published by ETSI in September 2026. It aligns clauses 9 (web), 10 (non-web documents) and 11 (software) with WCAG 2.2 and adds Annex ZB, which maps the standard to the requirements of Directive (EU) 2019/882.

According to the standard itself, the presumption of conformity arises only once its reference is published in the Official Journal under that Directive. When this page was last updated, we found no such publication. The Commission lists harmonised accessibility standards only under Directive (EU) 2016/2102 for public sector bodies, where EN 301 549 V3.2.1 (based on WCAG 2.1) is cited through Implementing Decision (EU) 2021/1339. Until harmonised standards are published under the BFSG, Germany's Federal Accessibility Agency (Bundesfachstelle Barrierefreiheit) names the current EN 301 549 and WCAG as the main guidance for implementing the requirements. In EN 301 549, the requirements for documents are in clause 10.

Our recommendation: design new PDFs to WCAG 2.2 Level AA now, since clause 10 of V4.1.1 builds on it. PDF/UA (ISO 14289) is not named in the BFSG, but it describes the technical structure inside the PDF file and is a useful yardstick for it.

Market surveillance and fines

The market surveillance authority checks services when it has reason to suspect a failure (§ 28(1) BFSG) and in random samples (§ 28(2)); under Annex 1 No. 2(b)(ee), the sample includes at least one relevant downloadable document, where available, for each type of service. Consumers and recognised associations can apply for proceedings (§ 32). As a last step the authority can order the provider to stop offering or providing the service (§ 29(3)). The competent body for all federal states is the joint Market Surveillance Authority of the Länder for Accessibility (MLBF), a public-law institution in Magdeburg, Saxony-Anhalt. According to the Bavarian trade supervisory authority, it has been fully responsible since September 26, 2025, when the inter-state treaty establishing it entered into force.

BFSG and BITV 2.0

The BFSG applies to economic operators. Federal public bodies fall under § 12a of the Disability Equality Act (BGG) and the BITV 2.0 ordinance. Under § 2a BITV 2.0, documents are expressly part of websites, mobile apps and electronically supported administrative processes. Authorities, universities and municipalities of the federal states are subject to state law, which, like BITV 2.0, transposes Directive (EU) 2016/2102; that Directive covers regional and local authorities as well as the State. For the websites and documents of a state university, state law is therefore the primary reference.

Which PDFs are typically affected

The BFSG does not mention PDFs by name. It expressly covers e-books (§ 1(3) No. 4), electronic tickets (§ 1(3) No. 2(c)) and the Annex 3 information. Beyond that, the following list is our practical assessment under § 12 No. 2 BFSGV, for documents a covered service needs and that were published on or after June 28, 2025:

• contract documents, terms and conditions, price lists and cancellation notices in online shops and booking flows,
• product information sheets, account statements and contract information for consumer banking,
• order confirmations, invoices and tickets delivered as PDF,
• forms that consumers must complete to use the service.

How to check your PDFs

1. Inventory. Map your PDFs to services and separate documents published before and after June 28, 2025. As a precaution, treat documents revised after that date as new.
2. Machine check. Check each file against the machine-checkable rules of PDF/UA, for example with our PDF accessibility checker, to find missing tags, title or language.
3. Manual review. Check alternative text, headings and reading order, tables, form fields and contrast. Test with a screen reader.
4. Fix at the source. Correct the Word or InDesign file or the template for generated PDFs such as invoices, export again and keep the results as a basis for the Annex 3 information.

What our checker does and does not do

Our PDF accessibility checker runs the machine-checkable rules of PDF/UA-1 and PDF/UA-2 and lists every finding with the rule, the page and a plain-language explanation. The error pages explain each message and how to fix it in Word, InDesign and Acrobat.

The result reads "X of Y machine-checkable criteria met; manual review needed". It never says that a document meets the BFSG; no automated tool can confirm that. For services in the United States, see our guide to ADA Title II.

Do we have to fix all our old PDFs?

§ 1(4) No. 2 BFSG excludes office file formats published on websites and in apps before June 28, 2025. New documents for covered services must meet the requirements; as a precaution, treat revised documents as new.

Does the BFSG apply to B2B services?

The BFSG covers services for consumers as defined in § 2 No. 16. A service offered only to businesses is not covered. If a service is aimed at both businesses and consumers, have its coverage assessed in the individual case.