Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz - BFSG)
- Bart Gosiewski
The Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz - BFSG) in Germany, based on the European Accessibility Act (EAA), will take full effect on June 28, 2025. This law mandates that digital services and products, including digital banking services, adhere to specific accessibility standards to support people with disabilities.
For digital banking services, BFSG outlines key requirements, including:
WCAG 2.1 Standards Compliance: Ensuring accessibility in websites, mobile apps, and online banking platforms, including keyboard navigation, adequate colour contrast, and screen reader compatibility.
Accessible Transactional Processes: Providing clearly labelled forms, error assistance, and other usability features to ensure payments, account management, and other banking processes are accessible to individuals with disabilities.
The act requires compliance with WCAG 2.1 AA standards as the primary guideline, though WCAG 2.0 AA remains relevant for legacy systems. While WCAG 2.2 AA compliance is not yet mandatory, it is recommended to future-proof services, as WCAG 2.2 introduces further accessibility improvements, particularly for mobile interfaces and cognitive disabilities.
The Gini’s Bank SDK is already largely compliant with the WCAG 2.1 guidelines prescribed in the BFSG. Our team is actively working to address the remaining requirements, ensuring a fully accessible experience by the 2025 deadline.
The table below outlines Gini’s current compliance with WCAG 2.1 requirements, indicating which are fully compliant, not applicable, or will be compliant in the near future:
Requirement (WCAG 2.0 AA and WCAG 2.1 AA) | Status |
|---|---|
1.3.1. Info and Relationships - Level A - Logical structures | Compliant |
1.3.2. Meaningful Sequence - Level A - Present content in a meaningful order | Compliant |
1.4.5. Images of Text, Level AA - Don’t use images of text | Compliant |
2.3.1. Three Flashes or Below Threshold - Level A - No content flashes more than three times per second | Compliant |
2.4.1. Bypass Blocks - Level A - Provide a “Skip to Content” link | Compliant |
2.4.3. Focus Order - Level A - Logical Order | Compliant |
2.4.4. Link Purpose (In Context) - Level A - Every link’s purpose is clear from its context | Compliant |
2.4.6. Headings and Labels - Level AA - Use clear headings and labels | Compliant |
2.4.7. Focus Visible - Level AA - Keyboard focus is visible and clear | Compliant |
3.1.1. Language of Page - Level A - Page has a language assigned | Compliant |
3.2.1. On Focus - Level A - Elements do not change when they receive focus | Compliant |
3.2.2. On Input - Level A - Elements do not change when they receive input | Compliant |
3.2.3. Consistent Navigation - Level AA - Use menus consistently | Compliant |
3.3.2. Labels or Instructions - Level A - Label elements and give instructions | Compliant |
4.1.1. Parsing - Level A, (This criterion has been removed from WCAG 2.2.) | Compliant |
4.1.2. Name, Role, Value - Level A | Compliant |
1.2.1. Audio-only and Video-only (Prerecorded) (Level A) - Provide an alternative to video-only and audio-only content | Not applicable |
1.2.2. Captions (Prerecorded) Level A - Provide captions for videos with audio | Not applicable |
1.2.3. Audio Description or Media Alternative (Prerecorded) -Level A - Video with an audio has a second alternative | Not applicable |
1.2.4.Captions (Live) - Level AA - Live videos have captions | Not applicable |
1.2.5. Audio Description (Prerecorded), Level AA - Users have access to audio description for video content | Not applicable |
1.3.5. Identify Input Purpose Level AA (Added in 2.1) - Ensure common names are provided using the HTML | Not applicable |
1.4.2. Audio Control - Level A - Don’t play audio automatically | Not applicable |
1.4.12. Text Spacing - Level AA (Added in 2.1) - Text spacing can be overridden to improve the reading experience | Not applicable |
2.2.2. Pause, Stop, Hide - Level A - Provide user controls for moving content | Not applicable |
2.4.5. Multiple Ways - Level AA - Offer several ways to find pages | Not applicable |
2.5.4. Motion Actuation - Level A (Added in 2.1) - Functions that are trigged by moving a device or by | Not applicable |
3.1.2. Language of Parts - Level AA - Tell users when the language on a page changes | Not applicable |
3.3.4. Error Prevention (Legal, Financial, Data) - Level AA | Not applicable |
1.1.1. Non-text Content (Level A) - Provide text alternatives for non-text content | Work in progress |
1.3.3. Sensory Characteristics - Level A - Use more than one sense for instructions | Work in progress |
1.3.4. Orientation - Level AA (Added in 2.1) - Requires authors not to rely on a screen orientation | Work in progress |
1.4.1. Use of Color - Level A - Don’t use presentation that relies solely on colour | Work in progress |
1.4.3. Contrast (Minimum) - Level AA - Contrast ratio between text and background is at least 4.5:1 | Work in progress |
1.4.4. Resize Text - Level AA - Text can be resized to 200% without loss of content or function | Work in progress |
1.4.10. Reflow - Level AA (Added in 2.1) - Your website must be responsive | Work in progress |
1.4.11. Non-text Contrast - Level AA (Added in 2.1) - High contrast between pieces of text and their backgrounds: The visual presentation of the following have a contrast ratio of at least 3:1 against adjacent color(s) | Work in progress |
1.4.13. Content on Hover or Focus - Level AA (Added in 2.1) - Ensuring content visible on hover or keyboard focus does not lead to accessibility issues | Work in progress |
2.1.1. Keyboard - Level A - Accessible by keyboard only: All functionality of the content is operable through a keyboard interface without requiring specific timings for individual keystrokes, except where the underlying function requires input that depends on the path of the user's movement and not just the endpoints. | Work in progress |
2.1.2. No Keyboard Trap - Level A - Don’t trap keyboard users | Work in progress |
2.1.4. Character Key Shortcuts - Level A (Added in 2.1) - Do not use single key shortcuts or provide a way to turn them off or change them | Work in progress |
2.2.1. Timing Adjustable - Level A - Time limits have user controls | Work in progress |
2.4.2. Page Titled - Level A - Helpful and clear page title | Work in progress |
2.5.1. Pointer Gestures - Level A (Added in 2.1) - Users can perform touch functions with | Work in progress |
2.5.2. Pointer Cancellation - Level A (Added in 2.1) - This requirement applies to web content that interprets pointer actions | Work in progress |
2.5.3. Label in Name - Level A (Added in 2.1) - The name contains the text that is presented visually | Work in progress |
3.2.4. Consistent Identification - Level AA - Use icons and buttons consistently | Work in progress |
3.3.1. Error Identification - Level A - Clearly identify input errors | Work in progress |
3.3.3. Error Suggestion - Level AA - Suggest fixes when users make errors | Work in progress |
4.1.3. Status Messages - Level AA (Added in 2.1) - In content implemented using markup languages, status messages can be programmatically determined through role or properties such that they can be presented to the user by assistive technologies without receiving focus. | Work in progress |