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The Accessibility Strengthening Act (BFSG) confronts micro-enterprises with new requirements that are often associated with uncertainty. This page provides a clearly structured overview of the key BFSG obligations and the applicable exemptions specifically for micro-enterprises.
You will learn how the BFSG systematically affects micro-enterprises, what the differences are compared to small enterprises, and how the legal requirements can be implemented in practice. Practical guidance and available support services will help you address the challenges of digital accessibility in a targeted way.
The Accessibility Strengthening Act (BFSG) places a particular focus on requirements for micro-enterprises. The structure of the law clearly distinguishes between companies of different size classes. Micro-enterprises are subject to specific rules, which are reflected primarily in exemptions and simplifications for implementing digital accessibility. The key provisions for micro-enterprises are found in particular in Sections 2, 3, and 14 of the BFSG and the associated ordinances.
Unlike larger companies, micro-enterprises are delineated in the BFSG through explicit definitions: micro-enterprises are businesses with fewer than 10 employees and annual turnover or an annual balance sheet total of no more than 2 million euros. This definition is decisive for applying the exemption rules and assessing the respective obligations. While extensive requirements apply to large and medium-sized companies, the BFSG provides targeted simplifications and, in some cases, exemptions for micro-enterprises.
| BFSG element | Relevance for micro-enterprises |
|---|---|
| Section 2 BFSG – Company sizes | Defines micro-enterprises and distinguishes them from larger companies |
| Section 3 BFSG – Exemptions | Regulates simplifications and exemptions for micro-enterprises |
| Section 14 BFSG – Evidence obligations | Sets lower documentation requirements for micro-enterprises |
| Definition of micro-enterprise | Fewer than 10 employees; annual turnover or balance sheet total up to €2 million |
For micro-enterprises, the BFSG takes a balanced approach: on the one hand, digital offerings should be accessible to people with disabilities; on the other hand, the legislator takes into account the limited resources of small businesses. The guiding principles of the law aim to make accessibility practical and economically feasible without placing a disproportionate burden on micro-enterprises.
In the day-to-day business reality of small companies, this means that accessibility can be understood not as a bureaucratic hurdle but as an opportunity to expand the customer base. Compared to larger companies, the requirements are deliberately reduced in order to preserve the competitiveness and innovative capacity of micro-enterprises. At the same time, the goal remains to promote digital participation for all user groups.
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For micro-enterprises, the BFSG defines specific success criteria to make compliance with accessibility requirements traceable. The assessment focuses in particular on the extent to which digital offerings are accessible to all user groups. The benchmarks are based on the general requirements of the law, but take into account the specific circumstances of small businesses. Key criteria include, for example, making digital content perceivable, operable, understandable, and robust.
In the assessment, thresholds and exemptions for micro-enterprises are given particular consideration. Certain requirements may be waived if the effort would be disproportionate or would exceed economic capacity. The assessment system provides that these simplifications are reviewed and documented on a case-by-case basis. Traceability is ensured by requiring micro-enterprises to justify their measures and any use of exemptions.
| Success criterion | Relevance for micro-enterprises |
|---|---|
| Perceivability | Digital content must be designed to be accessible to all user groups |
| Operability | Navigation and interaction must be easy and possible without barriers |
| Proportionality | Measures must not overburden economic capacity |
| Documentation of exemptions | Use of simplifications must be justified in a traceable manner |
Compliance with the BFSG by micro-enterprises is monitored by the competent market surveillance authorities. These authorities check on a random basis or in response to specific triggers whether the legal requirements have been implemented. For micro-enterprises, the focus is on the traceability of the measures taken and how any possible exemptions are handled. The checks are generally less formalized than for larger companies in order to reflect the lower administrative burden.
As part of an audit, the market surveillance authority may request documents that record the implementation of accessibility requirements. This includes, for example, evidence of measures taken, justifications for exemptions, and, where applicable, technical test reports. Documentation obligations are simplified for micro-enterprises; nevertheless, the key steps and decisions must be recorded in a traceable manner.
| Checks for micro-enterprises | Checks for larger companies |
|---|---|
| Random or trigger-based checks | Regular and comprehensive audits |
| Simplified documentation obligations | Extensive evidence obligations and detailed reports |
| Focus on traceability and exemptions | Strict compliance with all BFSG requirements |
| Lower administrative burden | Formalized audit processes |
The practical implementation of BFSG requirements in micro-enterprises primarily requires pragmatic and resource-efficient measures. Simple adjustments are often the focus, such as improving text readability, providing alternative image descriptions, or optimising website navigation. The use of templates or accessible content management systems can also significantly reduce the effort involved.
Typical practical examples include adapting forms for improved usability, integrating contrast checks, or using clearly structured headings. It is recommended to regularly test one’s own website for accessibility using simple testing tools and to seek external support where necessary. Technical and organisational aids such as checklists, self-assessment tools, or training for employees help to implement legal requirements efficiently.
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In the legal context, the BFSG occupies a special position for micro-enterprises. It clearly distinguishes the requirements from those for larger companies and defines precise thresholds, such as employee numbers and annual turnover. This distinction is crucial, as it determines specific exemptions and special provisions that apply to micro-enterprises. The regulatory classification ensures that implementing accessibility remains manageable for small businesses and does not result in a disproportionate burden.
In comparison to other regulations such as BITV or the international WCAG standards, the BFSG is less strict for micro-enterprises. While BITV and WCAG are primarily binding for public sector bodies and larger companies, micro-enterprises benefit from simplifications and targeted exemptions under the BFSG. These special provisions allow for flexible adaptation to individual operational circumstances, while still requiring compliance with the statutory minimum standards.
When implementing BFSG requirements, micro-enterprises often face typical challenges. A common misconception is that no measures are required at all or that simple technical adjustments are sufficient. Exemptions and relief provisions are also frequently misinterpreted, leading to uncertainty in practical implementation. In the area of documentation in particular, formal errors are often made, such as incomplete records or missing justifications for exemptions.
Practical issues also arise during technical implementation, for example due to outdated websites, insufficient colour contrast, or non-accessible forms. To avoid errors, it is advisable to use external tools early on and to regularly review the website. The consistent use of checklists and staff training also helps to avoid common pitfalls and to meet legal requirements efficiently.
BFSG obligations differ significantly depending on company size, particularly between micro-enterprises and small enterprises. While both groups benefit from certain simplifications, the requirements for micro-enterprises are further reduced with regard to documentation obligations, technical implementation, and exemptions. In practice, this means that the specific legal requirements change depending on threshold values, especially employee numbers and annual turnover.
Small enterprises are subject to stricter documentation and implementation requirements than micro-enterprises. For example, they must provide more extensive documentation and comply with a broader set of technical requirements. This distinction is relevant in practice, as it influences the level of effort required to implement accessibility requirements and the type of support that should be sought.
| BFSG obligations for micro-enterprises | BFSG obligations for small enterprises |
|---|---|
| Fewer than 10 employees, turnover/balance sheet total up to €2 million | Fewer than 50 employees, turnover/balance sheet total up to €10 million |
| Simplified documentation obligations, many exemptions possible | Stricter documentation obligations, fewer exemptions |
| Reduced technical requirements | Extended technical and organizational requirements |
| Lower implementation effort | Increased documentation and auditing effort |
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For micro-enterprises under the BFSG, the focus is particularly on digital services such as websites, online shops, and digital products. It is mandatory that basic functions and information are accessible to all user groups. This includes, for example, clear navigation, sufficient colour contrast, alternative text for images, and keyboard operability. Many more extensive measures, such as full compliance with all WCAG criteria, are optional for micro-enterprises or may be exempted.
In practice, this primarily affects typical digital services offered by small businesses, such as informational websites, booking systems, product catalogues, or digital service platforms. Industry-specific characteristics may lead to individual requirements being weighted differently, for example in trades businesses that mainly offer contact forms, or in retailers with simple online shops. It is advisable to regularly review one’s digital services for accessibility and to make use of industry-specific guidance.
Under the BFSG, micro-enterprises benefit from specific exemptions, particularly with regard to economic reasonableness. Measures for digital accessibility may therefore be waived if their implementation would involve a disproportionate effort. Typical cases include very simple websites without transaction-based functions or situations where technical retrofitting is not economically viable. Unlike small enterprises, these simplifications apply much more generously to micro-enterprises.
The BFSG places new requirements on micro-enterprises, but also provides targeted exemptions and simplifications to make the practical implementation of digital accessibility feasible. What matters are the clear thresholds that govern specific obligations and exemptions. With pragmatic measures, simple documentation solutions, and suitable support services, micro-enterprises can meet the legal requirements efficiently.
Key points: The requirements are less extensive than for larger companies; many additional measures are voluntary or exempt. Practical tools, checklists, and advisory services help avoid typical mistakes and ensure a targeted approach to implementation. Regular reviews and clear, traceable documentation ensure compliance with the minimum standards.
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Whether a micro-enterprise is affected by the BFSG can be determined with a simple check:
If these criteria are met, the specific BFSG rules for micro-enterprises apply. If you are unsure, it is advisable to consult subject-matter experts or chambers of commerce.
Whether a micro-enterprise is affected by the BFSG can be determined with a simple check:
If these criteria are met, the specific BFSG rules for micro-enterprises apply. If you are unsure, it is advisable to consult subject-matter experts or chambers of commerce.
Micro-enterprises are subject to the same deadlines as other affected companies: the key BFSG requirements must be implemented from June 28, 2025. However, there are sector-specific transitional provisions, for example for certain digital services. Compared to larger companies, there are no extended deadlines, but there are simplifications in implementation and evidence requirements.
Micro-enterprises document BFSG implementation most efficiently by using simple checklists, short reports on measures taken, and retaining relevant correspondence. It is important to record exemptions and justifications in a traceable manner. In the event of non-compliance, official orders or fines may follow, although sanctions for micro-enterprises are generally less severe than for larger companies. Documentation should be updated regularly and be available on request.
In the event of BFSG violations, micro-enterprises may face official orders or fines. To avoid sanctions, at least simple evidence documents such as checklists, brief logs of adjustments, or email correspondence on implementation measures should be maintained. In many cases, these pragmatic solutions meet the statutory minimum requirements and make it easier to provide evidence if needed.
