Accessible video under the BFSG (EAA): who must do what

Does the BFSG apply to our videos?

Only if consumers can buy or book something on your website or app, and you are not a micro-enterprise.

The BFSG covers a closed list of products and services (§ 1 BFSG (opens in a new tab)). Besides banking, telecoms, e-books and passenger transport, the entry that matters for most companies is "e-commerce services": websites and apps through which a consumer concludes a contract (§ 2 no. 26 BFSG (opens in a new tab)). The Federal Ministry of Labour's guidelines give online shops and online appointment booking as examples, and say the whole website, checkout included, has to be accessible (BMAS guidelines, example 3 (opens in a new tab)). So a product film on a shop's homepage counts.

Three details trip people up. "Exclusively B2B" has to be true in practice: if a private person can complete a purchase on your site, get advice. The exclusion for third-party content does not cover a film you commissioned, because it only applies to content you neither funded, developed nor control (§ 1(4) no. 4 (opens in a new tab)). And the date exclusion protects the old file, not the footage: a re-cut you publish now is safest treated as new.

The German states run a joint market surveillance authority, the MLBF in Magdeburg, which started work in September 2025 (Bundesfachstelle FAQ, Q24 (opens in a new tab)). Offering a service that does not meet the requirements can be fined up to €100,000 (§ 37 BFSG (opens in a new tab)).

We only sell B2B. Should we still care?

Legally, probably not. Commercially, often yes.

Many B2B companies are simply not obliged, and nobody should sell you compliance you don't need. Three things still pull accessibility into B2B video:

• Your clients may be obliged. If your film ends up on a client's online shop, it has to meet their requirements, not yours.
• Public-sector buyers. Federal bodies must make their websites accessible (BITV 2.0 (opens in a new tab)) and even explain their homepage in German Sign Language and Easy Language (§ 4 (opens in a new tab)). In EU-wide tenders, public buyers must write accessibility criteria into the specification for anything people will use, unless there is a good reason not to (§ 121(2) GWB (opens in a new tab)).
• It is better video. Captions reach people watching on a train without headphones, in a second language or in a loud trade-fair hall. A transcript gives search engines text to read. And the Bundesfachstelle points out that the law's scope may widen in future (FAQ, Q15 (opens in a new tab)).

What does "accessible video" mean in practice?

Captions, audio description where the picture carries information, a text alternative and a player everyone can operate.

The BFSG itself never says "captions". Its regulation requires websites to be perceivable, operable, understandable and robust, with at least one way to use a service without hearing and one without sight (§§ 12 and 21 BFSGV (opens in a new tab)). The practical yardstick, according to the Bundesfachstelle, is the European standard EN 301 549 together with the Web Content Accessibility Guidelines, WCAG (Normen und Standards zum BFSG (opens in a new tab)). The current reference version builds on WCAG 2.1. Version 4.1.1, published in September 2026, moves to WCAG 2.2 but is not yet cited in the EU's Official Journal (AccessibleEU (opens in a new tab)). The criteria for captions and audio description are identical in both: WCAG 2.2 added no new ones for audio and video (opens in a new tab).

Captions are not subtitles. Subtitles usually carry dialogue only, often translated. Captions also carry sound: [phone rings], [slow piano], who is speaking. The new EN 301 549 uses the word "subtitles", but says they must include "sound effects, music, laughter, speaker identification and location" (clause 9.1.2.2 (opens in a new tab)).

Audio description is sometimes built in. Where the main soundtrack already conveys everything important, no separate description is needed (WCAG definition, note 3 (opens in a new tab)). A transcript alone only meets Level A (opens in a new tab), not the AA level (opens in a new tab) that EN 301 549 includes.

Sign language is rarely a legal must. According to the Bundesfachstelle, neither the EAA nor the BFSG has explicit rules on it (FAQ, Q20 (opens in a new tab)). It makes sense when your audience includes Deaf people whose first language is DGS, or when a public body needs it.

How do we plan accessibility into production?

Decide it in the brief, not after picture lock.

Retrofitting audio description into a film cut wall-to-wall with dialogue and music is hard: there are no gaps for a describer to speak in. Planned early and written into the brief, most of the work disappears into decisions you make anyway.

• Script: let the voice-over say what matters on screen. "Here's the dashboard" becomes "The dashboard flags three open alerts." Where a separate description is still needed, leave pauses for it.
• On-screen text: read key text aloud, and hold titles long enough to read.
• Graphics: strong contrast, and keep the lower part of the frame clear. That is where captions sit.
• Flashing: fast social edits and strobe light can cross the limit of three flashes per second (WCAG 2.3.1 (opens in a new tab)). Check before export.
• Sound and music: note the cues that carry meaning while you edit, so the caption file can name them.
• Two languages: make German and English captions from the locked cut, not the draft script. A script only counts as a transcript once it matches the final edit (WCAG definition (opens in a new tab)).
• Delivery: caption files (SRT or WebVTT (opens in a new tab)) that viewers can switch on and off, plus burned-in versions for social feeds where needed.

Take our ADAM Audio "In The Studio" series (opens in a new tab): portraits of producers, engineers and artists, shot in London, Berlin and Vienna. In films like these, sound is the subject. A caption that just says [music] tells a viewer who can't hear it almost nothing; one that says what is playing, and when it changes, does. The same goes for a trailer like the one we made for World Warfare & Economics (opens in a new tab), with an original score and a cast voice actor: the voice lines belong in the captions, and so do the music cues that carry the story.

What should we ask a production company?

Ask what they deliver, in which format and languages, and who checks it.

For budgeting: one Berlin production studio we reviewed in September 2026 publishes guide prices of about €150 per video minute for subtitles, €300 for audio description, €80 for a timed transcript and €400 for sign language.

How we approach this

We plan language versions into the brief, before any camera rolls.

Our website is built to WCAG 2.2 Level AA, and our accessibility statement says so, including where we fall short: not every film in our portfolio has accurate captions yet. That statement covers our website, not the films we make for clients.

For client films, we deliver subtitles in nearly any language, AI voice-overs in nearly any language if you want one, on-screen text in other languages when you supply the translation, and transcripts. The moment to decide them is step two of our process.

Captions with sound cues and audio description aren't part of our standard offer, but they're possible on request if you need them. Put them in the brief, so the script and edit leave room for them. Subtitles and a translated voice-over help many viewers, but they are neither captions nor audio description.

This is general information, not legal advice.

Planning a film that has to work for everyone, or not sure what you need? Let's talk.