What Germany's Accessibility Strengthening Act means for PDF documents

General orientation, not legal advice. If and how far your organisation is affected should be assessed case by case with a qualified adviser. Section references are to the version published on gesetze-im-internet.de; English terms are our own descriptive translations.

The European framework (Directive (EU) 2019/882, the covered sectors, and where EN 301 549 and PDF/UA fit in) is described in European Accessibility Act and PDFs. This page is about German law.

The Act and the regulation

The BFSG sets out who is covered, which obligations apply and how compliance is enforced. The accessibility requirements themselves are in the implementing regulation (BFSGV). For services, the relevant provisions are mainly section 12 BFSGV, which contains the general requirements, and the sector-specific sections 14 to 19 BFSGV. Among other things, section 12 requires websites, online applications and mobile apps to be perceivable, operable, understandable and robust in a consistent and appropriate way. Information has to be offered through more than one sensory channel and in text formats that work with assistive technologies.

PDF does not appear in the BFSGV, and the regulation prescribes no file format. Section 4 BFSG attaches a presumption of conformity to harmonised standards whose references are published in the Official Journal of the EU, and section 3 BFSGV adds a reference to the state of the art. Audits therefore work from EN 301 549 and, through it, from the WCAG criteria applied to PDF.

Who is covered

Section 2 BFSG lists manufacturers, authorised representatives, importers, distributors and service providers as economic operators. A service provider is any natural or legal person offering or providing a service to consumers on the EU market. A consumer is a natural person who uses a product or service predominantly for purposes outside their trade or self-employed profession. Pure B2B offerings are therefore generally outside the service obligations.

The covered services are listed in section 1(3) BFSG: electronic communications services, certain elements of passenger transport (air, bus, rail and waterborne; urban, suburban and regional transport only to a limited extent), consumer banking services, e-books and dedicated software, and e-commerce services. Our industry overview breaks this down by sector.

Microenterprises

The accessibility requirements do not apply to microenterprises that offer or provide services (section 3(3) BFSG). Section 2 no. 17 defines a microenterprise as one employing fewer than ten people with either an annual turnover or an annual balance sheet total of no more than EUR 2 million.

Products get no equivalent blanket exemption. There, microenterprises are only relieved of certain documentation and notification duties. If you are just over the thresholds or belong to a group, have the classification checked carefully.

Obligations under section 14 BFSG

For most organisations that send PDFs to customers, section 14 BFSG is the provision that matters most. A service may only be offered or provided if it meets the requirements. Service providers must also:

• prepare the information set out in Annex 3 and make it publicly available in an accessible form for as long as the service is offered,
• keep meeting the requirements, including when the service or the relevant standards change,
• take corrective action in case of non-conformity and inform the market surveillance authority if the service still does not comply,
• on reasoned request, give the authority all information needed to demonstrate conformity.

Annex 3 requires you to state in your general terms and conditions or in another clearly perceivable way how your service meets the requirements. At a minimum this means a general description of the service in an accessible format, the explanations needed to understand how it works, a description of how it meets the requirements, and the name of the competent market surveillance authority. If your terms or this accessibility information are offered as a PDF, that PDF must itself be accessible. This is easily overlooked.

Exceptions for fundamental alteration (section 16) or disproportionate burden (section 17 with Annex 4) exist. They must be documented, reassessed at least every five years and notified where required. As a reason for leaving individual PDFs inaccessible, they will rarely hold up.

Which PDFs are affected and which are not

Section 1(4) BFSG excludes certain content of websites and mobile apps. Three of these exclusions are relevant to PDFs:

• office file formats (typically PDF, Word, Excel) published before 28 June 2025,
• archives whose content is not updated or edited after 28 June 2025,
• third-party content that the operator neither funds, develops nor controls.

An old product catalogue sitting unchanged in an archive may therefore be exempt. Anything newly generated or updated after the cut-off date is a different matter: monthly invoices, new contract versions, revised terms, tickets. If such PDFs belong to a covered service, the requirements apply.

Transitional periods

Section 38 BFSG contains two transitional rules. Products that service providers lawfully used to provide similar services before 28 June 2025 may stay in use until 27 June 2030. Service contracts concluded before 28 June 2025 may continue unchanged until they expire, but no later than 27 June 2030. Self-service terminals may be used until the end of their economic life, but no longer than 15 years after being put into service.

Newly created documents get no general grace period.

Market surveillance by the MLBF

Under section 20 BFSG, market surveillance is a matter for the federal states (Länder). They have set up a joint authority for it, the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF). It is a public-law institution based in Saxony-Anhalt (Magdeburg). According to the Bavarian trade supervisory authority, it has been fully operational as the enforcement authority since 26 September 2025. This is the authority you name in your Annex 3 information.

For services, the authority proceeds in stages (sections 29 and 30 BFSG). It first sets a deadline to restore conformity. If that fails, it can order the service to be discontinued after a further deadline. Purely formal non-conformity is enough, for example where the Annex 3 information is missing or not accessible.

Consumers can apply for the authority to take action (section 32). Recognised associations can bring legal challenges (section 33). A conciliation procedure is also available through the conciliation body under section 16 of the Disability Equality Act (section 34).

Fines under section 37 BFSG

Among other things, it is an administrative offence to intentionally or negligently offer or provide a service that does not meet the requirements (section 37(1) no. 8 in conjunction with section 14(1)). The fine can be up to EUR 100,000. Other offences, such as incomplete or late information to the authority, can be fined up to EUR 10,000.

Order of work

1. Confirm whether you are covered: do you provide a service listed in section 1(3) BFSG to consumers, and are you above the microenterprise thresholds?
2. Split your PDF inventory: unchanged legacy documents and archives on one side (document the exemption), continuously generated or updated PDFs on the other.
3. Check: run current PDFs through a PDF/UA check for tags, title, language and fonts, then work through the manual points in the accessible PDF checklist.
4. Fix templates and output systems: configure invoice and contract generators to produce tagged PDFs. That lasts longer than any post-processing.
5. Remediate existing files: where no source file exists, tagging the PDF after the fact creates a basic structure that is then reviewed manually.
6. Publish the Annex 3 information: accessible, naming the MLBF, and updated after every significant change.

EasyPDFUA helps with steps 3 and 5. It checks the technical PDF/UA structure and conservatively adds tags (basic tags, title, language, links, fonts/Unicode). A report or a tagged copy is not proof of BFSG compliance, though. Alternative text, reading order and plain language still need a manual review. For Austria, see our guide to the BaFG.

Frequently asked questions

Does the BFSG apply to PDFs?

Yes, if they form part of a covered consumer service, such as invoices, contract documents or e-tickets, and no exemption applies. The Act itself does not name a file format.

Do old PDFs have to be made accessible retroactively?

Usually not, as long as they stay unchanged. Section 1(4) BFSG excludes office file formats published before 28 June 2025 and archived content that is not updated after that date. Once such a document is revised or republished, the requirements apply.

How high are the fines under the BFSG?

Up to EUR 100,000 for offering or providing a service that does not meet the accessibility requirements (section 37 BFSG). Other offences, for example regarding information duties, can cost up to EUR 10,000.

Which authority enforces the BFSG?

The MLBF (Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen), a joint institution of the German federal states based in Saxony-Anhalt.

Where must the accessibility information be published?

In the general terms and conditions or in another clearly perceivable way (Annex 3 BFSG). The information must itself be accessible and name the competent market surveillance authority.