BFSG Compliance (Barrierefreiheitsstärkungsgesetz 2025)

BFSG Requirements for Vending Operators

Self-service terminals are subject to the harmonized standard EN 301 549 V3.2.1, which mandatorily defines technical minimum requirements. Three requirements directly impact the vending market: control elements must be positioned no higher than 1,220 mm from the ground (wheelchair access per EN 301 549, Section 8), display text must have a contrast ratio of at least 4.5:1 (WCAG 2.1 Level AA), and purely visual outputs require an audio or tactile alternative. Time-limited input windows must be extendable by the user.

Timelines: Existing Devices Until 2030, New Devices Immediately

Installed units that were already in service before 28 June 2025 have a statutory transition period until 28 June 2030. New installations from the effective date must comply immediately. Operators with mixed device fleets can integrate replacement of non-compliant terminals into regular replacement cycles to spread costs evenly.

Cashless Terminals in Focus

Cashless terminals on vending machines are treated as standalone products and fall under BFSG product obligations. Pricing for accessible retrofit terminals with audio functionality and tactile keypads is not uniformly published and must be requested from the supplier. Whether an MDB-compatible cashless replacement is more cost-effective than full device replacement must be calculated on a case-by-case basis. Non-compliant payment terminals may no longer be first placed on the market from the effective date.

Market Surveillance and Authority

Market surveillance and enforcement are the responsibility of competent state authorities. A central contact point has been established at the Bundesministerium für Arbeit und Soziales (BMAS). Violations may be pursued as administrative offences.