The BFSG in practice: how to make your online shop accessible
The German Accessibility Act has applied since June 2025. Who is affected, which exemptions apply, and how to implement WCAG 2.1 AA in concrete terms.
What the BFSG requires — and since when
The German Accessibility Reinforcement Act (BFSG) transposes the European Accessibility Act into German law and has applied since 28 June 2025. It requires providers of certain products and services to make their offerings perceivable, operable, and understandable for people with disabilities. Unlike earlier rules, it applies not only to the public sector but explicitly to the private sector.
Who is affected?
Covered areas include e-commerce (online shops, booking and payment platforms), consumer banking services, e-books, telecommunications and certain passenger transport services, as well as a range of hardware products such as self-service terminals. For most mid-sized retailers, the online shop is the decisive point of contact.
Putting the micro-enterprise exemption in context
Services provided by micro-enterprises — fewer than 10 employees and no more than €2 million in annual turnover or balance sheet total — are exempt from the BFSG obligations. However, this exemption applies only to services, not to products: anyone who manufactures, imports, or distributes physical products covered by the BFSG remains obligated.
WCAG 2.1 AA — the concrete requirements
- Perceivable: text alternatives for images, sufficient color contrast, scalable text
- Operable: full keyboard operation, enough time, no mouse-only interactions
- Understandable: clear language, consistent navigation, helpful error messages in forms
- Robust: clean, semantic HTML that works with screen readers and assistive technologies
Accessibility statement and evidence
Service providers must publicly set out how their offering meets the requirements. This accessibility statement belongs in an easy-to-find place on the website and must be kept up to date. Also document your testing — automated checks cover only part of the picture; manual tests with keyboard and screen reader are essential.
What violations can cost
The market surveillance authorities of the federal states can object to deficiencies, order their removal, and, as a last resort, prohibit an offering from continuing to be provided. Violations can be penalized under § 37 BFSG with fines of up to €100,000. On top of that comes the commercial risk of excluding a relevant part of the customer base.
Frequently asked questions
Does the BFSG also apply to purely informational websites?
Purely corporate websites without any contract conclusion generally do not fall directly under the BFSG, because it attaches to specific services such as e-commerce. However, as soon as an ordering, booking, or payment function for consumers is added, the requirements apply. For reach and legal certainty, accessibility is advisable in any case.
Is an automated accessibility test sufficient?
No. Automated tools find only part of the issues, such as missing alt text or insufficient contrast. Central criteria such as a meaningful focus order, understandable error messages, or operability with a screen reader can only be reliably assessed through manual testing.
What is the harmonized standard EN 301 549?
EN 301 549 is the European standard for the accessibility of ICT products and services. For web content it refers to WCAG 2.1 at level AA. Those who comply with this standard can rely on the presumption that they meet the corresponding legal requirements.