Germany and the European Accessibility Act: Key Requirements Explained

The European Accessibility Act in Germany sets harmonised accessibility requirements for certain products and services and must be transposed into German law by 28 June 2025. This article explains what to expect, which products and services are in scope, the technical references you should use, and practical steps for compliance in Germany.

What the European Accessibility Act is — quick summary

The Act is Directive (EU) 2019/882. It requires EU Member States to adopt national rules that make selected products and services accessible. The objective is a single market approach so the same accessibility rules apply across the EU for those categories.

Scope: which products and services are covered

The Directive targets specific categories rather than all products or all websites. Typical categories covered include cash machines and ticketing machines, computers and operating systems, e-books and e-readers, banking services, e-commerce and online marketplaces, audiovisual media players, smartphones and TVs, and certain transport services.

Example list (non-exhaustive)

Product or service	Why accessibility matters
ATMs and ticketing machines	Provide physical and digital access for people with vision or mobility impairments
Banking services and online banking	Ensure customers can access account services, payment tools and authentication
E-commerce platforms and online marketplaces	Allow shopping, product information and checkout without barriers
E-books and e-readers	Enable readable formats, navigation and assistive technology support

Who in Germany will be affected

Obligations fall on economic operators that place covered products on the market and on providers that supply covered services. That includes manufacturers, importers, distributors and service providers. Public bodies that buy or provide covered services should also check obligations arising from transposition.

Key technical references you should use

The Directive uses harmonised European standards as the technical basis. In practice you should map accessibility work to the European standard EN 301 549 and to current Web Content Accessibility Guidelines where applicable.

• EN 301 549 is the European ICT accessibility standard widely used for public procurement and technical specifications.
• WCAG is the international web standard. Many digital requirements reference at least WCAG 2.1 level AA.

Practical compliance steps for organisations in Germany

Follow these steps to prepare and reduce legal and operational risk.

1. Establish scope and ownership

Identify which of your products and services fall into the Directive categories. Assign a responsible person or team who will manage compliance.

2. Conduct an accessibility audit and gap analysis

Use EN 301 549 and WCAG as the mapping basis. Include automated scans, manual code reviews and real-user testing with people who use assistive technologies.

3. Prioritise fixes by user impact

Address failures that block essential tasks first, such as authentication, payment, navigation and content reading. Fixes that stop users completing transactions are highest priority.

4. Document technical evidence

Keep records of test results, design decisions and remediation steps. The Directive expects evidence that accessibility requirements were considered and met where required.

5. Update procurement and contracts

Include accessibility requirements in supplier contracts and tender documents. Require suppliers to provide evidence that their products comply with EN 301 549 where relevant.

6. Provide user support and a complaints process

Set up a clear route for users to report barriers and get help. Log complaints and remediation actions to show you acted promptly.

Common mistakes to avoid

• Assuming only websites are in scope. Hardware, consumer devices and offline functions can be covered.
• Relying only on automated tests. Many accessibility issues require manual checking and user testing.
• Failing to keep compliance evidence. Records and traceability matter for market surveillance and audits.

Enforcement and penalties — what to expect

Member States must set penalties that are effective, proportionate and dissuasive. That means Germany will publish specific enforcement rules and sanctions when it transposes the Directive. Businesses should prepare before the national law comes into force.

Short compliance checklist for Germany

• Map your products and services against the Directive categories.
• Run an EN 301 549 / WCAG gap analysis.
• Fix high-impact accessibility failures first.
• Document testing and remediation steps.
• Update procurement documents and contracts to include accessibility clauses.
• Publish an accessible contact and complaint handling process.
• Monitor for market surveillance notices after transposition.

Where to watch for Germany’s transposition details

Germany must publish the transposition law and related regulations in the Federal Law Gazette. After 28 June 2025 you should consult the official German publication and the websites of relevant ministries for the exact wording, enforcement rules and the authorities responsible for market surveillance.

Final practical advice

Start preparatory work now. Use EN 301 549 and WCAG as your technical map. Test with real users who rely on assistive technology and keep clear records of your work. That approach reduces risk and shortens the time needed to reach conformity once Germany publishes its transposition law.