Accessibility in the Automotive Sector: New Requirements under BFSG and EAA

With the entry into force of the Accessibility Reinforcement Act (Barrierefreiheitsstärkungsgesetz, BFSG) on June 28, 2025, Germany implemented the requirements of EU Directive 2019/882 (European Accessibility Act, “EAA”).

The automotive industry is also affected by these new legal requirements—especially when vehicles are equipped with digital interfaces, infotainment systems, or online services.

Which vehicle functions are affected?

The BFSG primarily affects the following areas of modern vehicles and their sales:

• Manufacturer websites and online shops: If vehicles or vehicle-related services are sold directly through a website, the website must be designed to be accessible.
• Mobile apps: Many manufacturers offer apps that allow users to purchase services, configure, or control vehicles. These apps may also fall under the scope of the BFSG.
• Infotainment systems and integrated software: Especially if the infotainment system allows access to audiovisual content from third-party providers (e.g., YouTube, Spotify) or other e-commerce services, accessibility requirements also apply. In these cases, the specific requirements of the Interstate Media Treaty (MStV) for services providing access to audiovisual media services must also be observed.

The relevant standard—like for other websites covered by the BFSG—is WCAG 2.2 (AA). In addition, an accessibility statement must be published on the website.

Does the BFSG also apply to vehicle hardware?

The law generally also covers devices with interactive functionality used for telecommunication purposes or access to audiovisual media services.

According to the currently prevailing legal opinion, there are strong arguments that integrated tablets or touchscreens in vehicles do not primarily serve these purposes and therefore are not directly subject to the additional BFSG requirements.

However, a certain residual risk remains, as the legal situation has not yet been definitively clarified.

What should automakers and suppliers do now?

• Check whether your digital offerings (websites, apps, infotainment systems) fall under the BFSG requirements.
• Consistently implement the technical standards (for example WCAG 2.2 AA).
• Create and publish the required accessibility statements.
• Monitor further legal developments, particularly regarding the classification of vehicle hardware.

Conclusion

The new accessibility requirements present the automotive industry with new challenges but also offer opportunities for innovative, user-friendly products and access to a larger customer base. Early and careful implementation of the legal requirements is essential to avoid legal risks and strengthen customer trust. In the worst-case scenario, violations could even result in product recalls.

We are happy to support you in legally compliant implementation of accessibility requirements in the automotive sector. Contact us!