Since June 28, 2025, Germany's Barrierefreiheitsstärkungsgesetz, or BFSG, has been in force. It is the German Accessibility Strengthening Act and implements a European directive, the European Accessibility Act. So far, attention has focused on websites and apps. But documents are included just as much, and PDF is the format companies use to publish their documents.
Who it affects
The law applies to products and services aimed at consumers. These include e-commerce, banking services, passenger transportation, and e-books. If your company sells something to consumers online, you are generally affected.
There is an exception for microenterprises providing services: fewer than ten employees and annual revenue or a balance sheet total of no more than two million euros. It does not apply to products. If you are just below the threshold, keep an eye on it, the exception no longer applies once your company grows.
Important context: The BFSG applies to the private sector. Public bodies remain subject to the Barrierefreie-Informationstechnik-Verordnung, or BITV 2.0, Germany's Accessible Information Technology Ordinance, which is stricter in some respects.
What makes a PDF accessible
The relevant standard is called PDF/UA, short for “Universal Accessibility.” It is defined in ISO 14289. Its requirements can be summarized in a few points.
- Structure. The document needs tagging that identifies what is a heading, a paragraph, a table, or a list. Without this tagging, a PDF is an unorganized collection of text fragments for a screen reader.
- Reading order. It must be defined and match the logical order of the content. This is not a given in multi-column layouts, the order in the document often follows the order of layout, not the reading order.
- Alternative text. Every image that conveys information needs a description. Purely decorative images are marked as such and skipped.
- Language. The document language must be specified so pronunciation is correct. Sections in other languages must be tagged separately.
- Contrast and font. Sufficient contrast, real text instead of text in an image.
- Title. A descriptive document title in the properties, not the file name.
The most important point first
Accessibility is created during authoring, not afterward. A PDF created from a properly formatted Word document, with real heading styles, real lists, real tables, and alternative text on images, already carries most of the necessary structure.
A PDF produced from a layout program without tagging, or even a scan, must instead be built manually. The effort is many times greater. If you publish documents regularly, you will save the most by getting your templates in order.
For the conversion itself, our Word to PDF is all you need. What matters is what is in the Word document: Were headings formatted as headings, or just made bold and larger? One carries structure, the other is only visual styling.
The special case of scans
A scanned document is an image. A screen reader sees nothing in it. That is why the first step is always text recognition: It adds a text layer beneath the image so the content is present at all.
That does not make the document accessible yet, structure and reading order are still missing. But without this step, every further step is pointless.
How to check its status
Free tools are available for a formal check: the PDF Accessibility Checker from the Swiss foundation “Zugang für alle” and the checking function in Adobe Acrobat. Both report which PDF/UA requirements are violated.
There is one simple check that no software can replace: Have a screen reader read the document aloud. If columns get mixed up or a table is read as a sequence of numbers, you know where the problem is, regardless of what a test report says.
Where to start
- Take stock: Which documents actually go to consumers? Usually, the list is shorter than you fear.
- Start with templates: Anything created in the future should be correct from the start.
- Catch up on scans: Apply text recognition so text is present at all.
- Work through existing documents by importance, not by their order in the folder.
This text does not replace legal advice. Whether and to what extent the BFSG applies to your company depends on your business model, discuss that with someone who knows the details.