BFSG checklist: make your online shop accessible in 7 steps
Since June 2025, the BFSG has required accessible online shops, apps, and other consumer services. Instead of getting lost in individual criteria, a structured approach helps: from checking whether you are affected, to technical implementation to WCAG 2.1 AA, to a published accessibility statement.
This checklist takes you through implementation in seven steps. It is tailored to retailers and mid-sized providers working without a specialized department. Start with the affected/exemption check — it determines the entire scope.
Your checklist
- 1Check scope and exemptions: clarify whether your service is covered and whether the micro-enterprise exemption (fewer than 10 employees, no more than €2 million) applies — it does not apply to products.
- 2Assess the current state: test your website, shop, and apps against WCAG 2.1 AA using automated tools and manual tests (keyboard, screen reader).
- 3Prioritize barriers: rank deficiencies by severity and frequency of use — fix critical blockers in checkout and forms first.
- 4Implement technically: provide text alternatives, contrast, keyboard operation, focus order, and understandable error messages in line with EN 301 549.
- 5Create the accessibility statement: set out publicly and easy to find how your offering meets the requirements, and keep the statement up to date.
- 6Embed processes: firmly plan accessibility into content maintenance, relaunches, and the procurement of new components so that no new barriers arise.
- 7Re-test regularly: repeat tests, evaluate user feedback, and keep the evidence documented in case of market surveillance.
Matching tool
Make your digital offerings BFSG-compliant.
Accessibility Act Checker → Check now for freeFrequently asked questions
How long does it take to make an online shop accessible?
This depends heavily on the starting point and the shop technology used. Modern systems with clean, semantic HTML are significantly faster to adapt. For the initial implementation, plan for a few weeks to a couple of months depending on scope; accessibility is then an ongoing task.
Do I need external providers or can I do it in-house?
Basic improvements — contrast, alt text, keyboard operation — can often be done in-house. For a robust audit and complex components, external expertise can be worthwhile. Manual testing is decisive; purely automated checks are not sufficient.
What must the accessibility statement contain?
It describes the service, the relevant requirements, and the technical implementation, and explains how the offering ensures accessibility. It must be published in an easy-to-find place and updated whenever the offering changes.