Key points at a glance
- The BFSG (Germany) and BaFG (Austria) implement the European Accessibility Act and have applied since 28 June 2025.
- They cover certain products and services; for websites, mainly e-commerce with consumers. A purely informational site is usually not covered.
- Micro-enterprises with fewer than 10 employees and no more than 2 million euros in turnover or balance sheet total are exempt for services.
- In practice the yardstick is WCAG 2.1 or 2.2, level AA: contrast, alt texts, headings, keyboard use, forms, captions.
- Accessibility pays off even without a duty: older clients, smartphone use, clearer pages and a clean foundation for search engines.
This post is general information, not legal or tax advice for your individual case. Laws, professional guidelines and chamber fees change: check the details with your chamber, the relevant authority or your professional association before you make a decision.
Why accessibility matters for professional firms
People looking for a firm are often not at their best: the widow who has to settle her late husband's estate has poor eyesight. The client recovering from an accident at work operates his phone with one hand. The business owner with a hearing impairment would rather write than call. For all of them, the website decides whether they manage to get in touch or click on to the next firm.
Accessibility does not mean building a second, stripped-down version of your website. It means that the one website works with screen readers, magnification, keyboard and voice control. Most of it is solid craftsmanship that costs hardly any extra effort if it is planned from the start.
What the BFSG and BaFG require
The basis is EU Directive 2019/882, the European Accessibility Act. Germany implemented it with the Barrierefreiheitsstärkungsgesetz (BFSG), Austria with the Barrierefreiheitsgesetz (BaFG). Both apply to products placed on the market and services provided to consumers after 28 June 2025. The laws list exhaustively what is covered, including computers and smartphones, consumer banking services, e-books, telecommunications, parts of passenger transport and e-commerce services.
For websites, the last point is decisive. It means services provided through a website or app, electronically and at the individual request of a consumer, with a view to concluding a consumer contract. An online shop is the typical example. Anyone covered must meet the accessibility requirements and provide information on how the service meets them. Compliance is monitored in Germany by the market surveillance authority of the federal states and in Austria by the Sozialministeriumservice.
Is your firm website covered?
A firm website that informs about practice areas, the team and how to get in touch is not e-commerce within the meaning of these laws: no contract is concluded through it, the engagement starts in a conversation. Things can look different as soon as consumers conclude a paid contract on the website itself. Exactly where the line runs has not yet been settled by the courts. The following overview is therefore a guide, not legal advice.
| Feature on the website | Covered? | Reason |
|---|---|---|
| Information pages, team, guide articles | usually not | No contract concluded through the website |
| Contact form, email, callback request | usually not | Initiation only, the contract comes later |
| Free online appointment booking | probably not | No paid contract; assess the individual case |
| Booking and paying for an initial consultation online | possibly | A consumer contract is concluded through the website |
| Selling templates, forms or online courses to private individuals | probably yes | Classic e-commerce |
| Services for businesses only (B2B) | no | The laws protect consumers |
If your firm employs more than nine people and lets consumers conclude contracts online, you should have the assessment checked, ideally against the guidance published by the competent ministries and authorities. In Austria, the Bundes-Behindertengleichstellungsgesetz (Federal Disability Equality Act) also prohibits discrimination in access to services available to the public. Regardless of any duty: if you are reworking your site anyway, for example during a relaunch, plan accessibility in from the start.
Why it pays off anyway
- Reach more clients: visual and hearing impairments, tremors, reading and concentration difficulties are common, and become more common with age. People who cannot read what you offer will not call you either.
- Older clients: inheritance law, care, pensions, handing over a business, a will at the notary's office: many firm topics concern people over 60 who struggle with small grey fonts and tiny buttons.
- Smartphones and everyday life: contrast helps in sunlight, large buttons help when using a thumb, captions help on the train without headphones. More in the guide to the mobile firm website.
- Search engines and AI assistants: Google does not treat accessibility as a ranking factor of its own. But clean headings, descriptive link texts, alt texts and real text instead of text in images help machines understand a page just as they help people.
- A professional impression: a firm that handles language and form with care shows it on its website too.
The key WCAG requirements
The technical yardstick is the W3C's Web Content Accessibility Guidelines (WCAG). The European standard EN 301 549, on which the laws rely, refers to WCAG 2.1 at level AA; the newer WCAG 2.2 from 2023 adds a few criteria, for example on the size of click targets. If you aim for 2.2 AA, you are on the safe side. The following points cover most of what matters on a typical firm website.
| Topic | Requirement | Typical mistake |
|---|---|---|
| Contrast | At least 4.5:1 for normal text, 3:1 for large text, icons and form borders | Light grey text on white, text on photos |
| Alt texts | Every informative image has a text describing what it shows; decorative images are skipped | “IMG_4711.jpg” or “image” as alt text, logo without the firm name |
| Headings | One main heading, below it logically structured subheadings | Bold text instead of real headings |
| Keyboard | Everything can be reached without a mouse, focus is visible | Menus that only open on mouse hover |
| Links and buttons | Link text says where it leads; click targets at least 24 × 24 pixels | “Click here”, “More”, tiny phone icons |
| Language | The page language is declared in the code so screen readers pronounce it correctly | A German page read out as English |
| Zoom | At 200 % magnification, everything stays readable and usable | Cut-off text, overlapping elements |

Plain language belongs here too, even though level AA only touches on it. Explain technical terms such as Verlassenschaftsverfahren (probate proceedings), input tax deduction or notarisation the first time they appear, write short sentences and put the most important information first. Everyone benefits, not just people with reading difficulties.
Forms, PDFs and videos
Most barriers on firm websites are not in the text, but in the elements clients are supposed to do something with.
- Contact forms: every field has a visible label, not just a grey placeholder. Required fields are named as such, error messages say in words what is missing. A CAPTCHA with distorted letters excludes many people; there are low-barrier alternatives. Tips on the whole page are in the guide to the contact page.
- Online appointment booking: third-party calendars often cannot be operated by keyboard. Test this before embedding one and always offer phone and email as an alternative. More in the guide to online appointments.
- PDFs: powers of attorney, checklists for tax returns or information sheets on starting a business should be exported as tagged PDFs with structure. A scanned page is blank for a screen reader. Better still: put important content directly on a web page.
- Videos and podcasts: videos need captions, audio content needs a transcript. That also helps everyone who watches without sound. See video and podcasts for firms.
- Cookie banners and pop-ups: they must be closable by keyboard and must not trap the screen reader. The simplest solution is a website that needs no banner at all; see cookie banners.
How to get it right
- Phone number and email as clickable text, not as an image
- Describe directions in words, not just with an embedded map
- Body text at least 16 pixels, lines not too long
- Team photos with name and role in the alt text
Better avoid
- Overlay tools promising accessibility “at the push of a button”; they do not fix the causes and often interfere with assistive technology
- Conveying information through colour alone, such as red required fields without text
- Auto-playing videos or sliders without a pause function
- Important deadlines or fees only in a graphic
Accessibility statement and feedback
Anyone covered by the BFSG or BaFG must explain in an accessible format how the service meets the requirements, in Germany under section 14 BFSG in conjunction with Annex 3. A separate “Accessibility” page linked in the footer next to the legal notice and privacy policy is the usual way to do this.
Even without a duty, a short, honest statement makes sense: what has been implemented, what has not yet, and how can people reach you if something does not work? Do not promise full conformance you have not tested. A false claim is worse than an open list of known limitations.
Contents of a voluntary accessibility statement
- Which standard you aim for, such as WCAG 2.2 level AA
- What has already been implemented and when it was last checked
- Known limitations, such as older PDFs or an external booking calendar
- Contact for feedback and alternative channels: phone, email, an appointment in person
- Information on the accessibility of the office premises
Accessibility on site: the office itself
For many clients, the most important question is not the website but: can I get into your office? Firms in old buildings with a step at the entrance and no lift to the third floor are not unusual in Vienna, Graz, Munich or Leipzig. That is no flaw, as long as you say so honestly and offer a solution.

- Access: step-free entrance or number of steps, lift and door width, doorbell at a reachable height
- On site: accessible toilet, parking nearby, public transport stop with a lift
- Communication: appointments by email or form, not only by phone, video consultations, meetings by arrangement in other rooms or at the client's home, where your professional rules and the matter allow it
- Support: companions welcome; sign language interpreting on request, if you can arrange it
The same information belongs in the Google Business Profile, which has dedicated attributes for a wheelchair-accessible entrance, parking, lift and toilet. How to maintain the profile is explained in the guide to the Google profile. For notaries: such details are objective information and therefore unproblematic even within the narrow limits of their professional rules.
A 15-minute self-test
A full WCAG audit needs experts. But you can find the biggest problems yourself, without special software:
Go through the page by keyboard
Put the mouse aside and use the Tab key to move through the home page and the contact form. Can you always see where you are? Can you open the menu and submit the form?
Zoom to 200 %
Zoom in with Ctrl and plus (Cmd and plus on a Mac). Does everything stay readable without scrolling sideways?
Check contrast
Check grey text, text on photos and coloured buttons with a free contrast checker, for example in the browser's developer tools.
Images without images
Check the alt texts of the most important images. Would someone who cannot see the image understand what it shows?
Have it read aloud
Turn on the built-in screen reader of your phone or computer (VoiceOver, TalkBack, Narrator) and try to find the phone number and the way to get in touch.
Test automatically
A Lighthouse report in Chrome or a checker such as WAVE finds missing labels and contrast errors. Automated tests only find part of the problems, though.
A firm website everyone can use
Our firm websites come with tested contrast, real headings, keyboard navigation and labelled forms from the start. Request a free preview for your firm.
A no-obligation preview of how your firm website could look with us.
Sources
- EUR-Lex – Directive (EU) 2019/882 (European Accessibility Act)
- Barrierefreiheitsstärkungsgesetz (BFSG)
- Barrierefreiheitsgesetz (BaFG), BGBl. I Nr. 76/2023
- W3C – Web Content Accessibility Guidelines (WCAG) 2.2
- W3C WAI – Easy Checks: a first review of web accessibility
- W3C WAI – WCAG overview
- § 3 BFSG – gesetze-im-internet.de
- § 14 BFSG – gesetze-im-internet.de
- § 6 BaFG – RIS
- Bundes-Behindertengleichstellungsgesetz (BGStG) – RIS



