Digital accessibility as a consulting mandate: BFSG overview for law firms

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With the Accessibility Strengthening Act (BFSG) New obligations for digital providers will come into effect from June 2025 – particularly in the B2C sector. What does this mean for law firms that offer their services via a website?
Marcel Zirkel OMmatic speaks with Specialist lawyer for intellectual property law Alexander Schupp about the legal implications of the BFSG, implementation hurdles and opportunities for advising lawyers.

Digital participation becomes law – what is the BFSG about?

Marcel ZirkelMr. Schupp, lately there's been a lot of talk about the Accessibility Strengthening Act (BFSG). What exactly is it about?

Alexander SchuppFundamentally, it's about digital inclusion. The Federal Social Security Act (BFSG) obliges certain providers to design their digital products and services in such a way that they can be used without restrictions by people with disabilities. The focus is particularly on online services aimed at consumers – for example, law firm websites that facilitate contact.

What's new is that these requirements now also apply to many **private sector providers**, meaning companies and self-employed individuals who operate commercially and offer their services on the market rather than under public contract – such as retailers, travel portals, or other service providers. Previously, such accessibility requirements primarily applied to public bodies under the Disability Equality Act (BGG). The Federal Disability Equality Act (BFSG) now extends these obligations to the broader private sector. This is a true milestone in legislation.

What does this mean for your law firm's clients?

CircleWho exactly needs to take action? Does this apply to all websites?

ScalesNot quite. The law primarily targets providers whose target group is end consumers – i.e., B2C. Small businesses with fewer than ten employees and less than two million euros in annual revenue are formally exempt. However, anyone who wants to remain competitive today should address the issue voluntarily – even if they fall under the exemption.

What requirements must clients implement?

CircleWhat exactly do I, as a law firm, have to do?

ScalesThere's quite a bit to consider. The entire process – from initial information to the client request – must be accessible. This means, for example, easily readable text, structured page navigation, alternative text for images, and no barriers for screen reader users, etc. The requirements are based on WCAG 2.1, specifically at level AA.

Need for advice during renovations: general or individual?

CircleSounds like a lot of work. Do they all have to completely rebuild their websites now?

ScalesNot necessarily. It depends on the current situation. Many modern CMS systems already offer a good foundation. But there are also areas for improvement – especially in the concrete implementation, for example with images, forms, or dynamic elements. The important thing is: don't just blindly rebuild, but proceed in a structured way – with technical and legal support.

What legal risks exist if there is inaction?

CircleAnd what if I ignore that?

ScalesThis can get expensive. Market surveillance authorities can take far-reaching measures. Furthermore, consumers or associations can issue warnings or even file lawsuits for violations. The consequences are real – even if some might still underestimate them.

How should law firms deal with this issue?

CircleI'm hearing in the industry about expensive certifications and emergency packages. Is there any truth to that?

ScalesUnfortunately, there's a lot of fear-mongering going on right now. Some providers are sensing a big business opportunity and offering overpriced, sometimes dubious "certifications" that aren't even legally required. I always tell my clients: Stay calm, get good advice – and don't waste money on gimmicks.

Are there any trustworthy implementation partners?

CircleDo you have any suggestions on where one can turn for help?

ScalesYes, indeed. I've had very good experiences with OMmatic. They have excellent technical expertise, fair pricing, and deliver practical solutions, not "rip-off packages." I regularly recommend them – with consistently positive feedback.

What about the accessibility statement?

CircleDoes an accessibility statement also need to be published?

ScalesYes, that's mandatory. It must be easily found on the website and explain, among other things, the extent to which accessibility has been implemented.

What advice would you give to colleagues in the consulting field?

Circle: Your most important piece of advice for law firms?

Schupp: Start now – with careful consideration, but decisively. Bring someone on board who is competent both legally and technically. Acting early not only reduces legal stress, but also demonstrates a strong stance – and may even open up entirely new customer groups.

Conclusion for legal practice

Accessibility is not only becoming legally mandated, but also offers potential for client retention and firm positioning. The Federal Law on the Protection of Victims of Disability (BFSG) is an ideal opportunity to combine technical expertise with legal advice – competently, pragmatically, and with a future-oriented approach.


About Alexander Schupp

Alexander Schupp He is a lawyer and a specialist in intellectual property law. Since 2005, he has advised well-known companies and associations in the following areas: Competition law, trademark law, copyright law and IT law.
He is the founder of the lawyers' cooperative. IT law Germany and co-founder of the service provider specializing in legal certainty in online commerce IT Law Plus.

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