On 28 June 2025, the European Accessibility Act (EAA) — implemented in Germany as the Barrierefreiheitsstärkungsgesetz (BFSG) — came fully into force. Since then, many digital products and services must be designed to be accessible — including websites, online shops and mobile apps.
Almost a year later, the question is: where do companies actually stand? The honest answer is sobering.
Most Companies Are Not Yet Compliant
Shortly before the law came into force, Aktion Mensch and Google published a study with an alarming finding: roughly two thirds of major German online shops did not meet the requirements for digital accessibility. Those who had hoped that the situation would improve quickly after the deadline were disappointed. Implementation is progressing far more slowly than expected. Many companies have the topic on their radar, but have not acted consistently. Yet in Germany alone, around 13 million people benefit from accessible digital offerings — people with disabilities, age-related limitations, or temporary impairments. For companies this means: the EAA is no longer a future task. The legal requirements have been in force for nearly a year.
The Theoretical Risk Became Reality
For a long time, the EAA was treated in many companies as an "upcoming topic." But that phase is over. As early as August 2025 — just weeks after it came into force — the first warning letters for missing accessibility became public. Since then, specialist lawyers nationwide have reported a steadily rising number of such cases. At the same time, the responsible market surveillance authorities have begun pursuing violations and issuing fines. The risk has fundamentally changed: The question is no longer "whether something will happen" — but "when."
The First Wave of Warning Letters: Many Questions, but a Clear Signal
The first known wave of EAA warning letters started in summer 2025. CLAIM Rechtsanwalts GmbH sent warning letters on behalf of Christopher Liermann / "die-website-experten.de" to operators of online shops. The argument was that a non-accessible shop constitutes a competitive advantage over law-compliant competitors. The settlement amounts demanded were around €595. Many specialist lawyers assessed these cases critically. In particular, the alleged competitive relationship between a web designer and an online retailer was legally questioned. The allegations were also partly formulated very broadly. Some companies therefore saw no immediate need to act. That was a mistake.
The Second Wave Is Far More Professional
Since early 2026, a new development has become apparent. Specialist firms are acting far more professionally and substantiating violations in much greater detail. The first known cases are already in the range of over €2,000. At the same time, market surveillance authorities are working independently of potential warning letters.
This means: even if a company reaches an out-of-court settlement or successfully defends against a warning letter, that does not protect against regulatory action. The potential consequences range from fines of up to €10,000 for standard violations to fines of up to €100,000 for serious or repeated violations. In extreme cases, the continued operation of an affected online offering can even be prohibited. For companies, this is a critical insight: The real risk factor is not individual warning letters. The greater risk arises from the combination of legal enforcement, regulatory oversight, and rising public attention.
Accessibility Means Far More Than a Plugin
Numerous myths still persist around digital accessibility. The most common misconception: an overlay tool or accessibility plugin solves the problem. The reality is different. The technical requirements are based on the European standard EN 301 549 and the Web Content Accessibility Guidelines (WCAG) 2.1 at conformance level AA.
These include:
- Alternative texts for images and graphical content
- Full keyboard operability
- Sufficient colour contrast
- Understandable error messages
- Correct form labels
- Semantically clean HTML structures
- Compatibility with screen readers
- Robust technical implementation
Additionally, the EAA requires an accessibility statement in accessible form. Many of the overlay solutions currently on the market cannot fulfil these requirements, because they do not fix the underlying technical problems in the source code.
Accessibility is not created by a widget. Accessibility is created by good software development.
A Frequently Overlooked Point: The EAA Also Applies to Apps
In many companies, the discussion focuses exclusively on websites and online shops. A critical point is frequently overlooked: The EAA explicitly also applies to native apps on iOS and Android. Apps published or substantially updated after 28 June 2025 must comply with the requirements immediately. There is no transition period. This is precisely where many companies have significant catching up to do. While websites are at least checked regularly, accessibility testing of mobile applications is often insufficient.
Why Training Now Matters More Than Any Audit
Many companies still treat accessibility as a one-off project. That is a mistake. Accessibility is not a state you achieve once and then tick off. It is a continuous quality process. Every new feature, every frontend adjustment, every release can reintroduce barriers. Therefore, the critical question in 2026 is no longer: "Is our website accessible?" But: "Does our team have the competence to develop continuously accessible software?"
This includes:
- Foundational knowledge of EAA, EN 301 549, and WCAG
- Manual and automated accessibility testing
- Screen reader testing
- Knowledge of assistive technologies
- Accessibility reviews in the development process
- Credible evidence and certifications for customers and clients
Conclusion: The Grace Period Is Over
One year after the EAA came into force, the picture is clear:
Compliance rates remain low. The first waves of warning letters are already running. Authorities are issuing fines. Legal practice is becoming increasingly professional.
Anyone who continues to delay today is taking on a real economic risk. At the same time, accessibility gives companies the opportunity to develop better digital products, reach more people, and improve their software quality sustainably. The critical question is therefore no longer whether companies should engage with accessibility. The critical question is:
