The Barrierefreiheitsstärkungsgesetz (BFSG) transposes EU Directive 2019/882 (European Accessibility Act) into German law and obliges manufacturers, retailers and service providers to make certain products and services – including e-commerce – accessible. It has applied since 28 June 2025.
The BFSG is a law designed to ensure that people with disabilities can also use online shops and digital services – comparable to a ramp at a shop entrance, only digital. For shop operators this means the website must meet specific technical and design requirements, for example regarding contrast, forms and keyboard operation.
Why does the BFSG affect me?
The BFSG has applied since 28 June 2025 and covers, among other things, services in electronic commerce – in practice almost every online shop aimed at consumers. Computers, smartphones, e-book readers, self-service terminals and banking services also fall within its scope. The law turns accessibility from a voluntary extra into a legal obligation.
For services, only micro-enterprises with fewer than ten employees and an annual turnover or balance sheet total of no more than two million euros are exempt. For everyone else: anyone offering contracts to consumers in Germany online must meet the requirements – regardless of where the shop is technically operated.
Practical relevance for shop and website operators
For technical implementation, practice generally refers to the European standard EN 301 549, which for web content essentially builds on WCAG 2.1 at conformance level AA. This affects core areas of a shop: navigation and search, product pages, forms, the entire checkout, plus colour contrast, font sizes and keyboard operability. In addition, the BFSG requires information on how the service meets the accessibility requirements – in practice often implemented via an accessibility statement.
In our experience, accessible design does not only benefit people with disabilities: clear structures, sufficient contrast and understandable forms typically make a site easier to use for everyone – including on mobile devices or in poor lighting conditions. Many measures, such as semantic HTML and alternative texts, also overlap with established SEO fundamentals.
Typical mistakes
- Treating accessibility as a one-off project instead of an ongoing process – every update can introduce new barriers
- Optimising only the homepage while checkout, forms and PDF documents remain untouched
- Using overlay widgets as a supposed all-in-one fix without addressing the underlying issues in the code
- Overlooking the information obligations on accessibility, even though they are an explicit part of the law
- Underestimating the effort and reacting only after a complaint or an enquiry from the authorities
What to look out for
A structured approach usually works best: first an audit of the current state, then prioritising barriers by severity and reach, followed by step-by-step implementation in the ongoing development process. Market surveillance authorities can order measures up to and including suspension of the service; the BFSG also provides for fines of up to 100,000 euros. The law contains limited transition rules for existing contracts and products already in use – new offerings, however, must meet the requirements from the start. Our service page accessibility optimisation shows what a BFSG-compliant implementation can look like.
The BFSG itself does not contain technical test criteria. These derive from the accompanying ordinance (BFSGV) and the standard EN 301 549, which for web content essentially refers to WCAG 2.1 at level AA.