Since 28 June 2025, the German Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) has been in force. It transposes the European Accessibility Act into national law and obliges many providers to make their digital offerings accessible. For care services, day-care providers and residential facilities the topic is doubly relevant: they may be legally affected - and their audience disproportionately consists of people who, without accessibility, never reach the website in the first place. Germany recently counted around 7.8 million (Destatis) people with a recognised severe disability, many of them older. This article explains who is affected by the BFSG, what the WCAG 2.2 standard actually requires, and why the effort pays off especially in care.
Key takeaways
- The BFSG has applied since 28 June 2025 and mainly takes effect where a website offers business functions such as booking, contract conclusion, payment or a customer account.
- The decisive standard is WCAG 2.2 at level AA with the four principles: perceivable, operable, understandable and robust.
- Micro-enterprises may be exempt for services – but the substantive benefit of accessibility remains unaffected.
- The older audience of care benefits directly from high contrast, large controls and a clear structure.
- Plain overlay widgets do not replace genuine accessibility; the criteria must be implemented in the structure, code and design itself.
What the BFSG Is and Since When It Applies
The Accessibility Strengthening Act implements the European directive on accessibility requirements for products and services (European Accessibility Act, EAA) into German law. The Bundestag passed the act back in 2021, but the obligations have only applied since 28 June 2025 (German Federal Ministry of Labour and Social Affairs). This ended a multi-year transition period in which companies had time to adapt their offerings. The act is supplemented by the BFSG ordinance (BFSGV), which specifies the technical requirements in more detail.
Unlike the Accessible Information Technology Ordinance (BITV), which only obliges public bodies, the BFSG addresses the private sector. It covers certain products and, above all, services that are provided electronically. These include e-commerce - that is, websites and apps through which contracts can be concluded or orders placed. For care providers, the decisive question is therefore whether their website goes beyond pure information and offers functions such as online appointment booking, contract conclusion or a customer account.
The act does not define its own detailed rules but refers to recognised technical standards. In practice this means the European standard EN 301 549, which in turn builds on the Web Content Accessibility Guidelines (WCAG). Anyone who designs their care website according to WCAG 2.2 at level AA meets the core of the legal requirements. Market surveillance in Germany is carried out by the state authorities; violations can be penalised with fines after a request to remedy them.
BFSG, BITV and WCAG - how they relate
Which Care Services Are Affected by the BFSG
The most important distinction under the BFSG lies between pure information pages and websites with business functions. A classic business-card website that only informs about services, team and contact options often does not fall within the scope of e-commerce under the current interpretation. However, as soon as a contract can be initiated or concluded via the website, an online booking system for consultation appointments runs, a payment process is possible or a customer account is offered, the act applies.
For care services this boundary is fluid. Many providers now add functions to their website that fall precisely into the regulated area: booking initial consultations online, a care-level calculator with a contact step, a recruiting portal with a login for care staff or a protected area for relatives. Anyone who offers such functions, or plans to in the foreseeable future, should not treat accessibility as an optional extra. Whether a specific offering is affected belongs in a legal review - the technical implementation, by contrast, belongs in experienced hands, as in our care website projects.
An important exception concerns micro-enterprises: anyone who, when providing a service, employs fewer than ten people and has an annual turnover or balance sheet total of no more than two million euros is exempt from the BFSG obligations for the provision of services (BFSG, section 3). However, this exception expressly does not apply to products. Many small home-care services thus formally fall outside the obligation - but the substantive reason for accessibility does not disappear, quite the opposite. The audience benefits regardless of company size.
Online appointment booking
A booking system for consultations or initial meetings is an electronic service. It must be keyboard-operable, high-contrast and usable with a screen reader.
Contract and registration
If a care contract or registration can be initiated or concluded online, the process falls under e-commerce and therefore under the BFSG.
Recruiting portal
A login area for care staff with an application function is a business function. Recruiting also benefits from accessible forms.
Online payment
As soon as payments or co-payments are processed via the website, the requirements for accessible e-commerce apply.
Area for relatives
A protected login area for relatives with documents or care reports is a service within the meaning of the act and should be accessible.
Pure information
A website without business functions may lie outside the scope. The assessment in an individual case belongs in a legal review.
WCAG 2.2 AA: The Four Principles Explained Simply
The Web Content Accessibility Guidelines in the current version 2.2 have been the official recommendation of the World Wide Web Consortium (W3C) since October 2023. They assign all requirements to four principles, often summarised with the English mnemonic POUR: perceivable, operable, understandable and robust. For meeting the BFSG, conformance level AA is usually decisive. Level A covers the basics, AA is the practical standard for broad application, and the strictest level AAA is not consistently achievable for many types of content.
The principle of perceivability requires that all content is accessible to the senses. This includes sufficient colour contrasts - at least 4.5:1 (WCAG 2.2) for normal body text and at least 3:1 for large type. Images need alternative texts so that screen readers can read them aloud. Videos need captions, and text must be able to be enlarged to up to 200 percent (WCAG 2.2) without losing content or breaking the layout. This point is central, especially for older people with declining eyesight.
Operability means that the entire website can be controlled without a mouse, using the keyboard alone - important for people with motor impairments or tremor. Interactive elements such as buttons and links need a visible focus indicator and a minimum target size; WCAG 2.2 requires an area of 24 by 24 pixels (WCAG 2.2) for most controls. In addition, no content may flash or change too quickly, and enough time must remain for time-critical actions. These aspects belong in any solid technical implementation.
Understandability aims at clear language and predictable operation. Texts should be plainly worded, forms need understandable labels and helpful error messages, and navigation must work the same way on every page. Finally, robustness requires clean, standards-compliant code with correct ARIA roles, so that assistive tools such as screen readers interpret the page reliably. The new version 2.2 added criteria on consistent help, visible focus indicators and avoiding cumbersome login procedures, among others.
| Principle (WCAG 2.2) | What it means | Example for care websites |
|---|---|---|
| Perceivable | Content accessible to all senses | Contrast 4.5:1, alt text, type scalable to 200% |
| Operable | Fully controllable by keyboard | Booking form without a mouse, visible focus, large buttons |
| Understandable | Clear language and operation | Simple form labels, clear error messages, optional easy language |
| Robust | Clean, compatible code | Correct ARIA roles, screen-reader friendly, valid HTML |
Why Accessibility Matters Most for an Older Audience
Care services have a special audience: people in need of care, their relatives and care staff. Those in need of care themselves are disproportionately very old. At the end of 2023, around 5.7 million (Destatis) people in Germany were in need of care within the meaning of the long-term care insurance act - a large share of them at an advanced age. With age, impairments in seeing, hearing and fine motor skills statistically increase. A website that uses small type, low-contrast colours and tiny click targets excludes precisely the people it wants to reach.
On top of this, the decision for a care service is often not made by the person in need of care alone, but together with relatives. These too are frequently no longer young - the caring son or daughter is not seldom over sixty. An accessible website lowers the barrier for this group to inform themselves, get in touch and arrange an appointment. Those who focus here on readability, large controls and a clear structure do not give away prospects to competitors with more accessible offerings.
Accessibility also has an effect far beyond the audience with permanent impairments. Captions also help in noisy environments, high contrast also in sunlight on a smartphone, and logical keyboard operation also power users. This effect - accessibility benefits everyone - is well documented and one of the reasons why the effort pays off even independently of the legal obligation. An accessible offering is simply a better offering that fits seamlessly into a well-thought-out content strategy for relatives.
Accessibility is not a niche topic
A website with small type, weak contrast and tiny click targets excludes precisely the people a care service wants to reach.
The Most Common Barriers on Care Websites
In practice, the same problems appear on many care websites. They usually arise not from negligence but because accessibility was simply not a topic when the site was originally created. A systematic review reliably uncovers these weaknesses - most can be fixed with manageable effort once you know about them. From our project experience with more than 50 website projects (project experience), certain patterns recur particularly often.
- Insufficient colour contrast, such as light-grey text on a white background below the 4.5:1 value
- Images without alternative text, so that screen readers cannot describe them
- Forms without clear field labels or without understandable error messages
- Operation possible only with the mouse, without a visible focus indicator for the keyboard
- Buttons and links too small, hard to hit on a smartphone
- Missing structure through headings, so that orientation with a screen reader suffers
Another widespread problem is cookie banners and pop-ups that cannot be closed with the keyboard or that do not trap the focus correctly. It is precisely here that many sites fail at basic operability before the actual content is even reachable. Embedded content such as maps or third-party videos also frequently brings barriers. A clean solution takes these elements into account from the start and tests them, instead of accepting them as given - an aspect closely interlinked with data protection on care websites.
Plain overlay tools do not solve the problem
What Distinguishes a BFSG-Compliant Care Website
An accessible care website starts with the design. As early as the concept stage, contrasts, font sizes and controls are chosen to meet the WCAG criteria. This is not a sacrifice of aesthetics but a deliberate design decision: clear typography, a calm colour scheme with sufficient contrast and generous spacing appear high-quality and trustworthy to all visitors. Implementation uses semantic HTML, sensible heading levels and correctly marked-up forms, so that the site is accessible from the ground up even for a new care website.
Compliance also includes an accessibility statement. The BFSG expects providers to inform about the state of accessibility and to provide a feedback mechanism through which users can report barriers. This statement names the standard applied, the date of the review and a contact option. It is not a mere obligatory document but a signal of trust - it shows that the provider takes the topic seriously. How such a statement is structured is shown on our page on accessibility in care.
Finally, accessibility is not a one-off project but a state that must be maintained. Every new page, every new image and every functional extension can introduce new barriers. That is why regular review belongs in ongoing website maintenance. Automated tests cover part of the criteria, others - such as whether alternative texts are meaningful or whether language is understandable - require manual assessment. The combination of both keeps the level permanently stable.
Readable design
High contrast, sufficiently large type and calm colour areas make content easy to grasp even with declining eyesight.
Fully operable
Keyboard navigation, a visible focus and large click targets ensure that people with motor impairments also reach their goal.
Clearly worded
Plain language, unambiguous forms and comprehensible error messages noticeably lower the barrier for all visitors.
Cleanly coded
Semantic HTML and correct ARIA roles make the page reliably interpretable for screen readers.
Statement included
An accessibility statement with a feedback channel transparently informs about the status and builds trust.
Continuously reviewed
Regular automated and manual tests during maintenance keep the accessibility level stable.
Six Steps to an Accessible Website
The path to a BFSG-compliant website is well plannable. Instead of viewing the topic as an unmanageable hurdle, a structured approach in clearly delimited steps pays off. For many care services a targeted revision of the existing site is enough; for older or technically outdated websites a rebuild is often the more economical option. In both cases, an honest assessment of the status quo stands at the beginning.
- Legal classification: clarify whether and to what extent the website falls under the BFSG - with legal advice where needed.
- Status assessment: review the current site with automated tools and manually against WCAG 2.2 AA and document all barriers.
- Prioritisation: order the findings by severity and effort - critical operability problems first.
- Implementation: adjust contrasts, structure, forms, keyboard operation and code, or rebuild the site.
- Accessibility statement: publish a statement with the standard, review date and feedback channel.
- Ongoing maintenance: review new content regularly and secure accessibility permanently during maintenance.
It is important not to consider accessibility in isolation. It interlocks with other quality features of a care website: with mobile usability, with loading time, with data protection and with local findability. A site that is cleanly structured according to WCAG 2.2 often also benefits in local visibility, because search engines value clear structures and semantic HTML. Anyone revising the website anyway should think these aspects together rather than tackling them one after another.
From more than 50 website projects (project experience) across different sectors, we know that the greatest leverage lies not in expensive special technology but in solid fundamentals: a well-thought-out design, clean code and consistent care with images and forms. Most WCAG criteria are not rocket science but craftsmanship. Anyone who plans them in from the start achieves a high degree of accessibility without blowing the budget - and lays the foundation for a website specifically for care services that convinces both legally and on a human level.
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