A BFSG accessibility statement for a covered service must publicly explain, in accessible form, what you offer, how people use it, how you meet the requirements and which market surveillance authority is responsible. The basis is section 14 BFSG and Annex 3, point 1. This guide turns those provisions into a practical information page for your shop or online booking service in Germany.
As of: 15 October 2026.
Which businesses must provide this information?
The duty concerns providers of services within the BFSG's scope. Having a business website is not sufficient on its own: section 1(3) BFSG covers specified consumer services, including electronic commerce.
For shops and booking pages, examine the actual transaction. The definition in section 2, point 26 concerns digital services supplied at an individual consumer's request with a view to concluding a consumer contract. Assess a consumer shop accordingly; for an appointment page, consider the purpose of the booking. A calendar for internal meetings differs from private customers booking a service.
Section 3(3) BFSG provides an exemption for microenterprises offering or providing services. Under section 2, point 17, they must employ fewer than ten people and have either annual turnover or an annual balance sheet total of no more than €2 million. Headcount alone therefore does not settle the question.
Keep an internal record of your assessment: which service, which customers and which exemption? Our guide to accessible websites under Germany's BFSG provides broader orientation. The rest of this article focuses on the information for a covered service.
What must the BFSG accessibility statement contain?
Annex 3, point 1 lists four elements, where applicable. Its introductory wording also requires a description of the applicable requirements; include service design and delivery where relevant to the assessment.
The outline below translates those provisions into writing tasks. These invented examples illustrate wording for services that actually work as described. They make no claims about your business.
| Annex 3 element | Content for a shop | Content for a booking service |
|---|---|---|
| a: Describe the service | “Our shop enables private customers to buy spare parts. You select suitable items and order the quantity you need.” | “Our booking page lets private customers reserve a workshop appointment for their chosen service.” |
| b: Explain how it works | “You can change quantities in your basket. Then enter delivery details, choose payment and review your order.” | “Choose a service and appointment, enter your contact details and review the summary before submitting.” |
| c: Explain how requirements are met | Describe applicable requirements and their evidenced implementation, such as operating the basket and payment without a mouse. | Explain requirements and tested functions, such as choosing appointments by keyboard and receiving clear feedback on input errors. |
| d: Identify the authority | Name the market surveillance authority responsible for your service. | Likewise, name the authority actually responsible for the service. |
Section c needs particular care. Section 12 BFSGV specifies requirements including accessible information and usable websites. For electronic commerce, section 19 BFSGV adds requirements concerning functions such as identification and payment.
Explain the applicable requirement in plain language, followed by your implementation. For example: “Our booking functions need to be operable without a mouse. Available appointments can be selected and the booking submitted using a keyboard.” Use the second sentence only if your checks support it. Merely linking to legislation does not explain how the service implements the requirements.
Why does a public-sector template need changing?
Statements for public bodies follow a different framework. For German federal public bodies, section 7 BITV 2.0 sets specific rules for content, availability, assessment and updates.
| Question | BFSG for covered services | Statement under BITV 2.0 |
|---|---|---|
| What is the focus? | The service and fulfilment of its requirements | Conformity of the website or app with accessibility requirements |
| Which structure applies? | The elements in Annex 3, point 1 | Section 7, including its referenced statement model |
| What timing rule matters? | Retain information while offering or providing the service; account for changes | Update annually and after significant changes |
| What does this mean for drafting? | Explain the service and its implementation specifically | Assess public-sector requirements before adopting them |
Under section 14(2) BFSG, you must retain the information for the entire time you offer or provide the service. Paragraph 3 requires you to account for changes. These provisions do not establish a universal annual BFSG update cycle equivalent to the BITV rule.
A test date, a monitored contact channel and understandable information about existing problems can be useful additions. Record these internally as deliberate service choices. They replace neither the four elements nor the accessible service itself.
How do you turn test evidence into reliable wording?
Start with the actual customer journey and write afterwards. We recommend a working record that connects each published assertion to a checked function.
1. Map the complete customer journey
For a shop, record search, product page, basket, customer details, payment and confirmation. For bookings, use service selection, calendar, contact details, summary and confirmation instead. Mark every transition to another provider.
Include unsuccessful journeys: what happens after an empty required field, failed payment or selection of an appointment that has become unavailable? Your explanation needs to match actual behaviour in these situations too. Our guide to online booking systems helps you plan the process.
2. Check assertions through specific tasks
Ask someone to complete the journey without a mouse. Also check enlarged display and output through a screen reader, software that presents content and controls accessibly. Combine automated checks with these manual tasks.
This suggested workflow is not a complete conformity assessment. It helps you identify unsupported wording and record where further testing is needed. Our guide to choosing brand colours also discusses contrast and interface states.
3. Put evidence beside the proposed sentence
Use internal columns for function, test result, proposed wording, responsible person and next review trigger. Suppose a calendar check finds that appointments can only be chosen by mouse. The sentence “The entire booking can be completed using a keyboard” is then unfit for publication.
The next task is to correct the calendar and test it again. Rephrasing the sentence does not repair the interaction. Section 14(1) BFSG sets two conditions: the service must fulfil the accessibility requirements, and the information under Annex 3, point 1 must be publicly available in accessible form.
4. Edit the sections
Remove interchangeable phrases such as “Accessibility matters to us”. Replace them with understandable details about your service. Describe only functions that exist, and keep customers' internal test data out of the published page.
Where should you publish the information?
Annex 3 allows the information in your terms and conditions or in another clearly perceptible way. We recommend a dedicated HTML page with a clear title and a permanently visible footer link, meaning a link in the lower section of your pages.
Where useful, point to this central version from your terms and conditions too. Maintaining independent copies creates avoidable contradictions. The footer is our implementation recommendation; the legal requirement is clearly perceptible provision.
Check the information page itself using a keyboard, enlarged display and speech output. Use proper headings and text rather than a scanned document. A PDF is not categorically prohibited, but it must also be accessibly available; we recommend HTML as the directly usable main route.
In the authority section, identify the competent market surveillance authority. Do not copy a conciliation or enforcement contact from a public-sector template. Establish responsibility using official information and record the source and check date internally.
When should you review the text again?
Review the information whenever the described service or its relevant framework changes. Section 14(3) BFSG addresses changes in delivery, requirements and referenced standards or technical specifications.
For everyday operation, we recommend these triggers:
- After a relaunch, confirm that page structure, navigation and described functions still match.
- Test a new checkout, including error and confirmation journeys.
- Review the complete payment journey when the payment provider changes.
- Test a new booking tool, including its calendar and feedback.
- Account for changed requirements or referenced technical rules.
- After barriers are fixed, update test evidence and affected statements.
- Check the responsible authority, public link and internal owner.
- Keep the approved version and its supporting evidence traceable.
This checklist connects maintenance to identifiable events. Set an additional internal review date so that quiet changes are also noticed. In particular, avoid a forgotten authority section, blanket conformity promises and wording that remains unchanged after switching providers.
Conclusion: how does the statement become useful in practice?
A useful information page connects your service, its operation and evidenced implementation. Build its outline from Annex 3 and tie maintenance to technical changes. If you need help with accessible customer journeys, see our web design and development service. Bring your journey map and existing test evidence when you start a project.
Sources and verification
The legal information was checked against primary texts on 15 October 2026:
- BFSG: scope, definitions, service exemption, provider duties and information content.
- BFSGV: general requirements and electronic commerce.
- BITV 2.0: statements for German federal public bodies.
