Accessibility Improvement Act (BFSG)

Why (almost) all companies that use payment systems need to act now and are likely to benefit from doing so

On 28 June 2025, the Accessibility Improvement Act (BFSG) came into force. This strengthens the accessibility of products and services – especially in the digital space – and standardises the requirements for this across Europe.

Accessibility means making products and services available to everyone – which is fundamentally a good idea both for affected consumers and for companies, who can make their offerings more accessible.

However, the law stipulates a whole series of technical requirements (such as voice output for terminals) and information obligations, particularly in the area of payment, both for electronic services/online shops and for stationary payment systems and vending machines. Our recommendation: Anyone who has not yet dealt with the BFSG in detail should do so as soon as possible.

The BFSG transposes the European Accessibility Act (EAA – Directive (EU) 2019/882) into German law. The corresponding law of 2021 will come into force on 28 June 2025. There is a regulation from 2022, the BFSGV, for its implementation.

If you want to read it for yourself, you can find the text of the law, the associated ordinance and a link to the Federal Accessibility Agency, which offers a FAQ section on the law, among other things, on the website of the Federal Ministry of Labour (German only).

What the BFSG has to do with payment services, POS and e-commerce

What are ‘barriers’ in everyday life? For example:

• An elderly person wants to buy a gift online, but the font at checkout is so small and low-contrast that he has great difficulty reading it.
• A person with intellectual disabilities wants to sign up for a streaming service, but the description of the subscription model is so complicated that they cannot understand it.
• A blind customer wants to check the amount on the card terminal in a shop, but there is neither Braille nor a read-aloud function with a headphone jack.

The central goal of the BFSG is to enable people with limitations or disabilities to have equal access to certain products and services – primarily through digital accessibility. It aims to reduce discrimination and promote participation in economic and social life. To this end, the law sets uniform and binding standards that are also monitored and enforceable. As the examples above show, this also has a significant impact on cashless payment service providers, both at the point of sale and in e-commerce.

And this does not only apply to the ‘big fish’: A guide published by the Federal Accessibility Agency cites the example of a hairdressing salon that offers appointment bookings on its website and sells hair care products. It thus provides what are known as ‘electronic commerce services’ (both product sales as e-commerce and appointment booking, as this serves to conclude a consumer contract). Conclusion: ‘The entire website, including the checkout process, must be designed to be accessible in accordance with the provisions of the BFSG.’ The only exceptions to this are micro-enterprises with fewer than 10 employees and an annual turnover of less than €2 million (but not if they themselves distribute products, i.e. if they are manufacturers and not retailers).

As mentioned, however, the law does not only apply to the digital world, but also to ‘self-service terminals’ such as payment terminals (hardware and software), ATMs or check-in machines – although this provision does not apply retroactively: depending on whether it is software or hardware, a different economic useful life during which it may continue to be used.

What does this mean for me and what do we have to do?

For all products and services that fall within the scope of the law, the following applies unequivocally: ‘Products that an economic operator makes available on the market and services that it offers or provides must be accessible.’ This means that they must be ‘findable, accessible and usable by persons with disabilities in the usual manner, without special difficulty and, in principle, without external assistance.’ For us, this means that the BFSG affects all touchpoints related to payments – both virtual and physical.

For online shops, this means:

• Websites, online applications and apps must be accessible. In particular, identification, authentication, security and payment functions must be designed to be perceivable, operable, understandable and robust. This means, for example, that information must be provided ‘via more than one sensory channel’ – i.e. not only in text form, but also as voice output. They must be understandable, for example in simple language. Fonts must be sufficiently large and high-contrast. This applies to the entire website and also to support services such as help desks or call centres.
• Information on accessibility must also be provided for the products and services offered.
• The obligations also include that service providers in electronic commerce (which, as mentioned above, also includes e-commerce providers) describe how they meet the requirements of the BFSG, name the competent market surveillance authority and make this information generally accessible (and accessible, of course).

In the event of non-compliance, the competent authority may demand measures, impose fines and ultimately order the discontinuation of the service.

Another challenge for retailers is comprehensive product labelling requirements, as importers and distributors are obliged under Sections 9 and 11 to only place products on the market or make them available on the market that comply with the BFSG – but this is not the subject of our article.

For the point of sale, this means:

Unless you rely exclusively on the future technology of ‘cash’, you will use card terminals in some form – including payment terminals, ATMs and check-in machines – or access payment services that are also covered by the BFSG. In addition to the general requirements, terminals are subject to additional industry-specific requirements, which we list here in accordance with BSFGV, Section 7 (1): ‘Self-service terminals’ must

1. be equipped with voice output,
2. allow the use of individual headphones,
3. alert the consumer via more than one sensory channel when the time available for the required response is limited,
4. allow the time available for the response to be extended,
5. be equipped with buttons and controls with sufficient contrast and tactile recognition […]
6. […] use audio signals or acoustic signals that are compatible with […] hearing assistance technology such as hearing aids, telephone coils, cochlear implants and technical hearing aids.

In addition, terminals must inform users how these functions can be activated (as you may have guessed: in an accessible manner, i.e. via more than one sensory channel).

Even if you are not a terminal manufacturer yourself, you must ensure that your devices, such as card terminals, comply with the new legal requirements – unless you wish to invoke the above-mentioned transition period – both in terms of hardware and software, as different providers often come together in the payment sector in particular.

Why the law is an opportunity

The BFSG came into force on 28 June 2025 and has extensive and direct implications, particularly for the payment sector. We recommend that you check as soon as possible to what extent you are affected and take immediate action.

Even if implementation sounds challenging at first, we would like to point out the opportunities that arise from the law: According to the Federal Statistical Office, almost 8 million people with severe disabilities live in Germany – that is just over 9% of the population. Among the over-65s, this figure is as high as around a quarter. Taking this growing customer group into account makes sense not only ethically, but also economically.

In addition, simplified usability also benefits non-disabled people: foreign citizens who rely on simple language, people with ‘minor’ disabilities such as impaired vision or temporary limitations (injuries, etc.). This is estimated to be every third to fourth customer – and, in general, people without any restrictions also benefit from simple, clear and easily recognisable descriptions, for example in payment transactions. The smoother the processes at the point of sale, the less manual effort is required in day-to-day business. Europe-wide standardisation also has the advantage that compliance with the BFSG requirements is sufficient for all EU countries, thus eliminating the tedious task of checking and reconciling country-specific requirements.

So: Take action – first, because you have to, and second, because you should! We would be happy to advise you on the needs analysis and integration of possible solutions for BFSG compliance.