Accessible Ticket Sales in Germany: BFSG 2026

Since 28 June 2025, selling tickets online to consumers in Germany has been a service the law requires to be provided accessibly. The law is the Barrierefreiheitsstärkungsgesetz, the BFSG, and it isn't about ramps: it's about your website, your app, your seating map and your payment form.

This isn't a best-practice recommendation. §37 of the BFSG turns non-compliance into an administrative offence carrying a fine of up to €100,000, and since September 2025 a joint authority of the sixteen Länder has existed specifically to check this, even without anyone having complained.

What does the BFSG require of anyone selling tickets in Germany?

It requires that the service can be found, used and completed without outside help. §3(1) of the BFSG sets the general standard: products and services are accessible when people with disabilities can find them, access them and use them "ohne besondere Erschwernis und grundsätzlich ohne fremde Hilfe" — without particular difficulty and, in principle, without third-party assistance.

§1 of the BFSG lists five groups of services covered by the law "ab dem 28. Juni 2025" — from 28 June 2025: telecommunications, passenger transport, consumer banking services, e-books and, in the fifth category, "Dienstleistungen im elektronischen Geschäftsverkehr," e-commerce services. A ticket shop falls under that heading.

The law is Germany's transposition of Directive (EU) 2019/882, the European Accessibility Act, as its own long title states. The specific requirements aren't in the Act itself but in an implementing regulation, the BFSGV, and the technical standards are published by the Bundesfachstelle für Barrierefreiheit. Three documents, three levels of detail.

The size of the affected population isn't marginal. According to press release 246 from the Statistisches Bundesamt, dated 13 July 2026, at the end of 2025 Germany was home to "gut 7,8 Millionen Menschen mit schwerer Behinderung" — a good 7.8 million people with severe disabilities, 9.4% of the population, counting only those with a recognised degree of disability of 50 or more and a valid ID card.

Does your ticket shop fall within the scope of the law?

If you sell online to consumers in Germany and you aren't a micro-enterprise, yes. The chain of definitions is short. §2 No. 26 of the BFSG defines e-commerce services as "digitale Dienste nach § 1 Absatz 4 Nummer 1 des Digitale-Dienste-Gesetzes, die über Webseiten und über Anwendungen auf Mobilgeräten angeboten werden" — digital services as defined in §1(4) No. 1 of the Digitale-Dienste-Gesetz, offered through websites and mobile applications. §1 of the Digitale-Dienste-Gesetz, in turn, refers to Article 1.1(b) of Directive (EU) 2015/1535, the classic definition of an information society service: provided electronically, at a distance, at the individual request of a recipient and normally for remuneration.

The Bundesfachstelle's page on e-commerce puts it plainly: e-commerce services "wie Online-Shops" — such as online shops — must be accessible. And it flags the only general way out: micro-enterprises providing services are excluded.

§3(3) is explicit: "Absatz 1 gilt nicht für Kleinstunternehmen, die Dienstleistungen anbieten oder erbringen" — paragraph 1 does not apply to micro-enterprises that offer or provide services. §2 No. 17 defines a micro-enterprise as "ein Unternehmen, das weniger als zehn Personen beschäftigt" — an enterprise employing fewer than ten people — which must also have annual turnover of no more than €2 million or an annual balance sheet of that amount. These are two cumulative conditions: headcount and money.

The last row has a consequence that's easy to miss on a quick read. §1(2) of the BFSG regulates payment terminals and self-service terminals as products, including ATM-style ticket machines and check-in machines. The organiser isn't the manufacturer, but it is the one providing a service through them, and §12 of the BFSGV requires, in its first point, that products used to provide the service meet the requirements that apply to them. An inaccessible self-service kiosk stops being your supplier's problem the moment it's the only way to collect the ticket.

What exactly does the checkout have to comply with?

Two blocks: information and functions. §19 of the BFSGV, specific to e-commerce, requires providing "Informationen zur Barrierefreiheit der zum Verkauf stehenden Produkte und der angebotenen Dienstleistungen" — information on the accessibility of the products and services on offer — and that identification, authentication, security and payment functions be designed to be "wahrnehmbar, bedienbar, verständlich und robust": perceivable, operable, understandable and robust.

Above that article sits §12 of the BFSGV, the general provision for services: information about how the service works must be provided through more than one sensory channel, be available in text formats suitable for generating assistive formats, be presented with sufficient contrast and sufficient spacing between letters, lines and paragraphs, offer an alternative for non-text content, and websites and mobile apps must meet the same four principles. It adds a point almost nobody audits: support services — help desk, phone, technical support — must communicate the service's accessibility "mit barrierefreien Kommunikationsmitteln," using accessible means of communication.

There's a requirement specific to the provider that doesn't appear in the technical regulation but in §14 of the BFSG: alongside providing the service accessibly, you must draw up the information set out in point 1 of Annex 3, explaining how the service meets the accessibility requirements, make it available in an accessible form, keep it current for as long as the service is offered, and correct the service when it's found not to comply. In practice, that's a published, maintained accessibility statement.

Which technical standard do you have to comply with, if the law doesn't name one?

The law doesn't cite any particular standard, and that doesn't leave the organiser off the hook. §3(1) of the BFSGV requires observing "der Stand der Technik," the state of the art, and allows different solutions if they perform equally well. Paragraph 2 tasks the Bundesfachstelle für Barrierefreiheit with publishing and updating information on the applicable standards.

That list of standards identifies the European standard EN 301 549, version V3.2.1 of 2021, as "die zentrale technische Referenz für die Umsetzung der Barrierefreiheitsanforderungen im digitalen Bereich" — the central technical reference for implementing accessibility requirements in the digital domain — and EN 17161:2019 as the process standard for building design-for-all into development. EN 301 549 points to the Web Content Accessibility Guidelines 2.1, and its updated versions point to 2.2.

The same page flags what's still missing: the conformity tables under §3(2) of the BFSGV haven't been published, and there's no date for them. On top of that are the presumptions of conformity under §4 and §5 of the BFSG, which rest on harmonised standards and technical specifications published in the Official Journal of the European Union. Until a table exists, the practical criterion is the one the authority itself uses: EN 301 549 and the WCAG.

And there's one shortcut the Bundesfachstelle rules out explicitly: "ein Online-Shop kann mit einem Overlay-Tool nicht die Verpflichtungen zur digitalen Barrierefreiheit nach dem BFSG erfüllen" — an online shop cannot meet the BFSG's digital accessibility obligations with an overlay tool. If your supplier offers you a floating widget as a compliance solution, the federal advisory body has already put it in writing that it doesn't work.

What happens if you don't comply: fines, inspections and complaints?

What happens is that a case can be opened against you without anyone having complained. §28 of the BFSG requires the market surveillance authority to review a service whenever it has grounds to think it doesn't comply, and adds that it also reviews services "auch ohne konkreten Anlass anhand angemessener Stichproben" — even without a specific reason, through appropriate sampling. The same article requires informing any consumer who asks whether a company complies, in comprehensible language and, where needed, in plain language.

§32 of the BFSG gives consumers and recognised associations the right to have the authority open proceedings when they allege a breach, and §33 and §34 add remedies and a conciliation procedure. In other words: a buyer who can't complete a purchase can trigger an inspection without any prior lawsuit.

The authority exists and is new. According to official information from the Land of Schleswig-Holstein, when the interstate treaty took effect on 26 September 2025, the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen, MLBF, began operating as a public-law body based in Magdeburg, created by a treaty that every Land had to ratify.

The amounts are set out in §37 of the BFSG: up to €100,000 for the most serious breaches, including offering or providing a service that fails to meet accessibility requirements, and up to €10,000 for breaches of information, labelling and documentation duties. Compared with the timeline for Germany's e-invoicing rules, there's no general grace period here: the deadline fell on 28 June 2025.

Can you claim disproportionate burden?

You can, but not for free and not without paperwork. §16 of the BFSG covers cases where accessibility would require a fundamental alteration of the service, and §17 covers disproportionate burden: the requirements apply only to the extent that compliance doesn't impose a disproportionate burden "nach Anlage 4" — under Annex 4 — on the economic operator.

The price of invoking it is procedural. You must document the assessment using the Annex 4 criteria, keep it for five years from the last time the service was provided or the product made available, and notify the competent surveillance authority without delay that you're relying on this exception. Micro-enterprises working with products have a lighter obligation: they don't have to keep the documentation or notify, but they must provide the relevant facts on request.

Our reading, not the law's: for a promoter that isn't a micro-enterprise, "it wasn't in the budget" without a documented and notified Annex 4 assessment isn't an exception — it's a breach with no mitigating circumstance. The exception has to be built before the non-compliance, not after the case file is opened.

There's also a transitional rule that shouldn't be confused with a general deferral. §38 of the BFSG allows providers to keep offering their services "bis zum 27. Juni 2030" — until 27 June 2030 — using products they were already lawfully using before 28 June 2025. It covers legacy hardware — a terminal, a machine — not redesigning the website.

How many wheelchair spaces does German regulation require?

This isn't set by the BFSG but by each Land's venue regulation, which is why there's no single German figure. In Bavaria, §10(7) of the Versammlungsstättenverordnung requires, for wheelchair users, "mindestens 1 v.H. der Besucherplätze, mindestens jedoch 2 Plätze auf ebenen Standflächen" — at least 1 per cent of audience seats and a minimum of two, on level surfaces. It adds three operational duties: assigning audience seats for companions, signposting the spaces and routes with clearly visible signage, and providing accessible toilets, at least one for every ten wheelchair spaces.

Every Land has its own Versammlungsstättenverordnung, with its own numbering and nuances, as already seen in venue capacity and event safety in Germany. Before giving a figure to the client or the local authority, you need to read the regulation for the Land where the venue is located.

Alongside administrative law, there's a civil-law route that affects the box office directly. §19(1) of the Allgemeines Gleichbehandlungsgesetz prohibits discrimination on grounds including disability in contracts "typischerweise ohne Ansehen der Person zu vergleichbaren Bedingungen in einer Vielzahl von Fällen" — those typically concluded without regard to the individual, on comparable terms, in a large number of cases — mass-market transactions. Ticket sales are the textbook example. §21 of the AGG gives the affected party a right to an injunction and to compensation, including for non-material damage, and sets a short deadline for claims: "innerhalb einer Frist von zwei Monaten" — within a period of two months.

The practical difference between the two routes is who makes the call. The BFSG is enforced by an authority with sanctioning powers; the AGG is enforced by the affected individual, within two months and before a civil court. A checkout that treats the wheelchair space as a manual exception can breach both at once.

What to do before your next sale in Germany

Seven checks that don't depend on rebuilding the venue.

Decide whether you're a micro-enterprise and write it down. Headcount below ten people and turnover or a balance sheet of up to €2 million. If you're near the threshold, the previous financial year's calculation is the document you'll need to produce.

Run the entire purchase using only the keyboard, no mouse. From selecting a zone through to payment and downloading the ticket. Wherever you get stuck is the point of §19 of the BFSGV you're breaching.

Add a text equivalent to the seating map. A list of zones, available rows and prices, navigable and readable by a screen reader. It's the most direct way to meet the "more than one sensory channel" requirement in §12 of the BFSGV.

Check the captcha and the basket timer. A purely visual captcha and a timer that can't be extended are two classic barriers in a sale with a queue. Both fall under the identification and authentication functions the regulation names.

Generate the ticket as a tagged PDF, not an image. And hold the confirmation email to the same standard: contrast, heading structure and alt text.

Publish the §14 information and keep it current. What your service complies with, how it complies, and who to contact if something fails to work, in an accessible format. Without it, the authority has an information breach before it even assesses the website.

If you're going to invoke disproportionate burden, document Annex 4 and notify. Five years of record-keeping and notification to the surveillance authority without delay. Doing it badly is worse than not doing it at all.

And Futura Tickets: what part does a platform solve?

Almost everything above gets decided in the sales software, not in the venue's construction. The useful questions for any supplier — Futura Tickets included — are whether the whole purchase flow works with a keyboard and a screen reader, whether the seating map has a text alternative, whether the ticket and the email come out in tagged formats, whether the wheelchair space and companion seat are inventory types with their own price, and whether there's a test report against EN 301 549 you can attach to your §14 information. Futura Tickets is a Spanish SaaS ticketing platform for professional organisers that sells in 9 languages and across 11 country domains, and like any other, it should be judged against those questions, not a badge.

What no platform can give you is compliance itself. That's assessed against your service, your venue and your procedures. If you're choosing a supplier for the German market, how to choose a ticketing platform and the product page set out the starting criteria, and the accessibility requirement is best written into the brief before signing, not after.

Conclusion

The BFSG brings an uncomfortable idea to ticket sales: digital accessibility is an obligation with an authority, sampling and fines behind it, not an internal policy. The deadline has already passed, the authority has been operating since September 2025, and the only general exemption is for micro-enterprises providing services.

For a European organiser selling across several countries, the good news is that the technical substance repeats itself: the BFSG transposes Directive (EU) 2019/882 and points to EN 301 549 and the WCAG, the same ground already familiar to anyone who has worked on accessibility for ticket sales in the United States. What changes from country to country is who inspects, within what deadline, and for how much in fines.

Sources

• §1 BFSG: scope of application, products and services covered from 28 June 2025 (Gesetze im Internet)
• §2 BFSG: definitions, including micro-enterprise and e-commerce services (Gesetze im Internet)
• §3 BFSG: concept of accessibility and the exemption for micro-enterprises providing services (Gesetze im Internet)
• §17 BFSG: disproportionate burden, five years of documentation and notification to the authority (Gesetze im Internet)
• §28 BFSG: service surveillance, sampling without a specific cause and information for consumers (Gesetze im Internet)
• §37 BFSG: fines of up to €100,000 and €10,000 (Gesetze im Internet)
• Full text of the BFSG: §14 provider obligations, §32 rights of consumers and associations, §38 transition until 27 June 2030 (Gesetze im Internet)
• §3 BFSGV: state of the art and publication of standards by the Bundesfachstelle (Gesetze im Internet)
• §12 BFSGV: general requirements for services, sensory channels, text formats and support services (Gesetze im Internet)
• §19 BFSGV: additional requirements for e-commerce services (Gesetze im Internet)
• §1 DDG: definition of digital service by reference to Directive (EU) 2015/1535 (Gesetze im Internet)
• §19 AGG: prohibition of disability discrimination in mass-market transactions (Gesetze im Internet)
• §21 AGG: injunction, compensation and the two-month deadline (Gesetze im Internet)
• §10 Bayerische Versammlungsstättenverordnung: 1 per cent of spaces for wheelchairs, minimum two (Gesetze Bayern)
• Bundesfachstelle für Barrierefreiheit: BFSG standards, EN 301 549 V3.2.1 and EN 17161:2019
• Bundesfachstelle für Barrierefreiheit: e-commerce, online shops and why an overlay doesn't satisfy the BFSG
• Marktüberwachungsstelle der Länder für die Barrierefreiheit (MLBF): operations began on 26 September 2025 (Land of Schleswig-Holstein)
• Statistisches Bundesamt: 7.8 million people with severe disabilities in Germany at the end of 2025, press release 246 of 13 July 2026
• Directive (EU) 2019/882 on accessibility requirements for products and services (EUR-Lex)