(Digital) accessibility from 2025

From 28 June 2025, the European Accessibility Act (EAA) will oblige companies to make certain products and services accessible for the EU market. This applies to products for consumers with digital components, such as smartphones, e-books or self-service terminals, or certain digital services such as B2C online shops or access services for audiovisual media services, such as streaming providers.

However, according to the coalition agreement of the new German government between the Christian Democratic Union (CDU), Christian Social Union (CSU) and der Social Democratic Party (SPD), the EAA is not the end of the road when it comes to (digital) accessibility.

Under the leadership of the new German Chancellor Friedrich Merz, who was sworn in in early May, further existing barriers for people with disabilities are to be gradually removed. Companies, platform operators and public authorities should therefore stay up to date in this regard. It is quite possible that accessibility, especially in the online market, could develop into a relevant compliance criterion in the long term, such as data protection or sustainability.

In the article, we present the coalition’s most important plans for accessibility:

• General guidelines: The inclusion of people with disabilities should be improved, both in public spaces and in the private sector. To this end, existing laws should be reviewed for barriers to accessibility and new public centres should be created that can promote social inclusion, such as a competence centre for easy language and sign language. Bureaucratic hurdles should be removed, and the Federal Participation Act (Bundesteilhabegesetz) should be further developed without creating gaps in coverage. Ideally, the rehabilitation and participation of people with disabilities should be provided ‘from a single source’.
• Labour market and training: Workshops for the disabled are being reformed with the aim of making it easier for people with disabilities to transition into the general labour market. To this end, placement services between employers, the Federal Employment Agency and contact points for employers are being optimised. Furthermore, the representatives of severely disabled persons (Schwerbehindertenvertretung) are to be strengthened. The acquisition of digital skills by people with disabilities will be supported and an accessible digital infrastructure will be created on the labour market and in educational institutions. The protection against discrimination provided by the General Equal Treatment Act (Allgemeines Gleichbehandlungsgesetz) will be improved. Finally, the labour cost subsidy that employers can receive when employing a person with a disability is to be made more attractive.
• Digitisation of the administration: The administration is to be digitised in the coming legislative period. This also includes ensuring that these digital services are accessible for citizens. The disabled person’s pass is to be digitalised.
• Digital accessibility: As part of a cross-age digital skills campaign, everyone should be able to participate digitally without barriers. What this means in specific terms is only addressed very sporadically, for example in the “age digital package”, which is intended to remove digital participation barriers for older people. Furthermore, the interests of people with disabilities are also to be considered in the development of AI systems. Finally, consumer rights in the digital space are to be strengthened and digital services are to be designed to be consumer-friendly “by design” and “by default”, which could also include an accessible design.
• Healthcare and protection against violence: Healthcare and care provision should be further developed to be accessible and inclusive. Disabled people should be better protected against (violent) assaults.
• Building and housing: All publicly accessible government buildings must be accessible by 2035. In general, homes are to become accessible and age-appropriate; social housing will be improved. Railway stations and sports facilities will also be made more accessible.

It should be noted that the coalition is striving for change in many areas, but there are few concrete projects. However, one project that has already been implemented and is about to come into force on 28 June is the accessibility of certain digital products and services as stipulated by the EAA:

The EAA covers digital products offered to consumers, such as smartphones, smart TVs, bank and ticket machines, and e-book readers. It also covers services, such as electronic communication services (e.g. messengers), access services for audiovisual media services (e.g. streaming services), ticket sales for passenger transport, banking services, and e-commerce services. The latter include B2C online shops in particular. There are a few exceptions for micro-enterprises and certain types of website content, such as archives, as well as transitional periods. However, it should be noted that not all websites have to comply with the EAA, but only those offering certain types of content, such as that listed above.

Various requirements must be met to ensure accessibility. For example, providers must offer information via multiple sensory channels, such as haptic and visual. The WCAG Level AA can be used as a guide for website design. Failure to comply with EAA requirements may result in fines of up to EUR100 thousand under Germany’s “Barrierefreiheitsstärkungsgesetz”, which implements the EAA. Products can also be withdrawn from the market and services banned.

What do you need to do now? If your website or product is affected by the EAA, it must be made accessible by 28 June 2025. Furthermore, this blog will keep you up to date with the new German federal government’s other plans regarding accessibility, particularly those relating to digital accessibility.