The verdict in three sentences
Since 28 June 2025, the Barrierefreiheitsstärkungsgesetz (BFSG), Germany's transposition of the European Accessibility Act, applies to consumer digital services (e-commerce, banking, transport, ticketing) of companies with more than 10 staff and EUR 2 million turnover. For a Berlin corporate site, plan EUR 3,500 to 8,000 for an audit against EN 301 549 / WCAG 2.1 AA on 20 pages, then EUR 8,000 to 38,000 in fixes depending on an initial conformance rate that often sits around 30 to 50 %. A three-phase remediation plan reaches 75 % within a quarter and supports a defensible accessibility statement.
Who is affected and what is at stake in 2026
The BFSG extends obligations well beyond the public sector, which was already covered by the BITV 2.0. A digital director should first confirm whether services fall in scope, then document conformance.
| Situation | Obligation | Exposure if non-compliant |
|---|---|---|
| B2C e-commerce, turnover > EUR 2 M | BFSG conformance, EN 301 549 | Fines up to EUR 100,000, sales prohibition order |
| Banking, insurance, online financial services | BFSG conformance | Market surveillance authority checks |
| Any in-scope service | Accessibility information in the terms | Warning letters (Abmahnung) from competitors or associations |
| Pure B2B corporate site | No direct BFSG obligation | Commercial risk in public tenders |
| Micro-enterprise (< 10 staff, < EUR 2 M) | Exempt for services | No fine, best practice recommended |
| Companion mobile app | Same rules as the website | Cumulative exposure |
Beyond legal risk, around 7.9 million people in Germany have a severe disability, and large buyers increasingly include accessibility in supplier requirements, as they now do in France under the RGAA.
Audit and remediation costs in Berlin
The audit tests the 50 WCAG 2.1 AA success criteria (plus EN 301 549 additions) on a representative sample of pages. Remediation cost depends mainly on code quality and the design system.
| Service | Scope | 2026 budget (excl. VAT) | Timeline |
|---|---|---|---|
| Automated pre-audit + sample | 5 pages, tools + manual checks | EUR 1,000 to 2,000 | 1 week |
| Full EN 301 549 audit | 20 pages | EUR 3,500 to 8,000 | 2 to 3 weeks |
| Fixes, 50 % initial conformance | Templates, forms, contrast | EUR 8,000 to 16,000 | 4 to 6 weeks |
| Fixes, 30 % initial conformance | Component rebuild, keyboard navigation | EUR 19,000 to 38,000 | 8 to 12 weeks |
| Re-audit and statement | Verification + publication | EUR 1,500 to 3,000 | 1 to 2 weeks |
| Content team training | 1 day, 8 people | EUR 1,300 to 2,200 | 1 day |
| Annual monitoring | Control audit on 10 pages | EUR 2,000 to 4,000/year | Recurring |
A site built on a modern CMS with a clean design system is often fixed in 4 to 6 weeks. An older site with home-made JavaScript components (menus, carousels, modals) costs two to three times more.
Three-phase remediation plan
| Phase | Content | Criteria targeted | Target rate |
|---|---|---|---|
| Phase 1: blockers | Keyboard navigation, visible focus, labelled forms, image alternatives | Operable, forms, images, navigation | 55 to 60 % |
| Phase 2: structure | Headings, landmarks, tables, page language, explicit links | Info and relationships, links, tables | 70 to 80 % |
| Phase 3: polish | Contrast, animations, PDFs, captioned video | Colour, multimedia, documents | 85 % and above |
Phase 1 tackles what genuinely stops a blind or keyboard-only user completing a task. It also weighs most in an inspection. Publish the accessibility statement as soon as phase 1 ends, with an honest rate and a schedule for the next phases.
Mini case study
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Jonas, digital director of a 120-person Berlin retailer selling online (EUR 6 M web turnover), orders a 20-page audit for EUR 6,000. Result: 38 % conformance. Three-phase fixes are quoted at EUR 24,000 over 10 weeks, plus EUR 2,500 for the re-audit. Total investment: EUR 32,500. Against that, the fine exposure reaches EUR 100,000, before any warning letter costs. Another measured gain after remediation: mobile conversion rises by 0.3 points thanks to clearer forms, roughly EUR 18,000 of extra revenue a year at his volumes.
FAQ
How much does an accessibility audit cost in Berlin in 2026?
A full audit on 20 pages costs EUR 3,500 to 8,000. A 5-page pre-audit, useful to size the work, runs EUR 1,000 to 2,000.
Is my B2B website covered by the BFSG?
The BFSG targets consumer digital services. A purely corporate B2B site is not directly in scope, but a growing share of public tenders, roughly 1 in 2, now include an accessibility criterion.
What conformance rate should we target?
Aim for at least 75 % in the short term and full WCAG 2.1 AA over time. The statement must show the real rate with a dated remediation plan.
Are automated tools enough?
No, they catch about 30 to 40 % of issues. Keyboard navigation, meaningful alternatives and comprehension require manual testing.
How does this compare with France?
In Paris, an RGAA 4.1 audit on 20 pages costs EUR 3,000 to 7,000 and fines reach EUR 50,000 per service. Berlin costs are comparable, with higher maximum fines.
Let's scope your project. Send us your site URL and number of page templates and we will price the pre-audit, the full audit and the three remediation phases with a realistic timeline. Detailed quote within 48 h. WhatsApp +221 77 596 93 33.
Mohamed Bah
Fondateur, Kolonell
Passionate about digital and entrepreneurship in Africa, Mohamed has been helping Sénégalese businesses with their digital transformation since 2020. Founder of Kolonell, he believes every SME deserves a professional and accessible online présence.
