Does the accessibility law apply to your practice website? Check this before you pay for an audit.

The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025. In Germany it is implemented through the Barrierefreiheitsstärkungsgesetz (BFSG); in Czechia through Act No. 424/2023 Coll. on accessibility requirements for certain products and services. Both cover, among other things, services in electronic commerce — and that is where practice websites come in.

A purely informational website is not in scope

A website that only presents the practice — hours, services, team, directions — is not an e-commerce service. The question is what the website lets a patient do. The Bremen Medical Association’s information sheet on the BFSG names online appointment booking, the submission of contact forms or anamnesis questionnaires, and video consultations as functions that bring a practice website into scope. The German association of paediatricians (BVKJ), in its member information of July 2025, names binding appointment bookings via a website or app. The two readings are not identical — which is itself worth knowing before anyone tells you the answer is obvious.

The microenterprise exemption

Both the German and the Czech law exempt microenterprises from the requirements for services: businesses with fewer than ten employees and an annual turnover or balance-sheet total of no more than €2 million. Many single-doctor practices fall below that line. A larger group practice or a medical care centre (MVZ) often does not. Count carefully, and count the whole practice, not one doctor.

What is at stake

In Germany, violations of the BFSG can be fined up to €100,000, according to both the Bremen chamber and the BVKJ. For practices that are in scope, the question is not whether to act but how; the Bremen chamber points to the WCAG guidelines as the practical reference.

What to do either way

• Check the trigger first. List what the website lets patients do: book, send forms, start a video call. If the answer is ‘nothing’, the act is unlikely to apply.
• Then check the exemption. Headcount and turnover of the practice as a whole.
• If booking runs through a third-party tool, ask the provider how it meets the accessibility requirements — the booking widget is usually the most interactive part of the site.
• Build accessibly regardless. Sufficient contrast, readable font sizes, keyboard navigation, text alternatives for images, plain language. A practice serves older patients and patients in distress; for them accessibility is not compliance, it is whether the website works at all.

This article is a summary, not legal advice. If your website is clearly in scope, have the specific case assessed.

How FIB Consulting approaches it

We build practice websites to be fast, legible and usable on a phone and by older patients as standard — and we tell practices honestly when an accessibility audit is not what they need. See our medical IT work, the German page on websites for doctors, or get in touch.

Sources

Directive (EU) 2019/882 (European Accessibility Act) · Ärztekammer Bremen, Merkblatt BFSG, June 2025 · BVKJ, Mitgliederinformation Barrierefreiheitsstärkungsgesetz, 18 July 2025 · EY Czech Republic, tax alert on Act No. 424/2023 Coll., June 2025 · iubenda, European Accessibility Act guide.