What does the German Accessibility Act (BFSG) require from my online shop?

The Barrierefreiheitsstärkungsgesetz (BFSG) transposes the European Accessibility Act (EAA) into German law and came into force on 28 June 2025. It obliges providers of certain digital services – explicitly including online shops selling to consumers – to design their offerings so that people with disabilities can use them without assistance. Importantly, this covers not just the homepage but the entire purchase process: product search, product detail pages, cart, registration, checkout and payment. You can find a detailed overview on our accessibility optimization page.

The details are governed by the accompanying ordinance (BFSGV). The decisive criterion is electronic commerce: as soon as consumers can conclude contracts via your website, the requirements apply – regardless of whether you sell physical products, digital goods or services. Besides online shops, booking portals, banking services, e-books and apps are also covered. Since the EAA is an EU directive, comparable obligations exist in all member states – businesses selling across Europe therefore benefit twice from an accessible implementation.

Who is affected by the BFSG

The law applies to companies providing digital services to consumers – which covers the vast majority of German online shops with B2C business. Micro-enterprises with fewer than 10 employees and an annual turnover or balance sheet total of no more than 2 million euros are exempt for services (BFSG, sections 2 and 3); whether the exemption applies should be assessed legally on a case-by-case basis. Pure B2B shops are generally not covered – however, hybrid shops that also sell to consumers are typically subject to the obligations. Enforcement lies with the market surveillance authorities; in addition, violations can be pursued under unfair competition law.

The specific requirements

The established technical benchmark is the Web Content Accessibility Guidelines (WCAG) 2.1 at conformance level AA, referenced by the European standard EN 301 549. For shops, this results in requirements such as:

• Perceivability – alternative text for images, sufficient color contrast (at least 4.5:1 for regular text), scalable font sizes
• Operability – full keyboard navigation, a visible focus indicator, no keyboard traps in menus or modals
• Understandability – clear language, unambiguously labeled form fields and comprehensible error messages in the checkout
• Robustness – clean, valid code that works with screen readers and other assistive technologies
• Accessibility information – details on how the service meets the requirements (e.g. in an accessibility statement (knowledge entry))

In practice, a staged approach has proven effective: an audit first makes the current state visible, after which findings are prioritized by risk and effort – contrast issues, alternative texts and form labels can often be fixed with manageable effort, while keyboard operation and focus management in complex menus or checkout flows require more development work. Importantly, accessibility is not a one-off measure but must be considered with every release. In our experience, an accessible implementation also improves usability and mobile use – which benefits all customers.

Violations can result in fines of up to 100,000 euros; in addition, competitors and associations can issue formal warning letters. The first warning letters circulated shortly after the law came into force (KBM Legal). Transitional rules apply only in narrowly defined exceptional cases and do not protect against warnings under unfair competition law.