German Accessibility Act (BFSG) for Online Shops: What Has Applied Since June 2025

The German Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) has applied since 28 June 2025. Anyone running an online shop for consumers in Germany has to make it usable for people with disabilities without outside help. On top of that come the mandatory accessibility information pages, which many shops still have not published.

This article covers which shops the law applies to, which exemptions and transition periods exist, what happens if you don't comply, and how to adapt your shop step by step.

This article explains the legal situation from a web developer's point of view and is not legal advice. Last reviewed: 7 October 2026.

Which online shops the BFSG applies to

The BFSG transposes the European Accessibility Act (Directive (EU) 2019/882) into German law. For shops, Section 1(3) no. 5 BFSG is the key provision: the law applies to "e-commerce services" provided to consumers after 28 June 2025. Section 2 no. 26 BFSG defines these as services offered via websites and apps at the individual request of a consumer with a view to concluding a consumer contract.

In practice this means:

• B2C shops where consumers order and pay are covered. So are booking flows and order forms through which a contract is concluded.
• Pure B2B shops are generally not covered, because the law consistently refers to consumers. If you serve both trade customers and consumers in the same shop, you are covered.
• Micro-enterprises that provide services are exempt from the accessibility requirements under Section 3(3) BFSG. Under Section 2 no. 17 BFSG, a micro-enterprise has fewer than ten employees and either an annual turnover of no more than €2 million or a balance sheet total of no more than €2 million. Both conditions must be met: a shop with eight employees and €3 million turnover (and a balance sheet total above €2 million) is not a micro-enterprise. The German Federal Ministry of Labour confirms the exemption for services.

Transition periods: what may continue until 2030

There is no general grace period for online shops. The transitional rules in Section 38 BFSG are narrow:

• Service providers may continue to provide their service until 27 June 2030 using products they lawfully used for it before 28 June 2025. "Products" in the legal sense means things like hardware or terminals, not the website itself.
• Service contracts concluded before 28 June 2025 may continue unchanged, but no longer than 27 June 2030.
• Self-service terminals already in use before the cut-off date may stay in use until the end of their economic life, for no more than 15 years after they were put into use.

There is no transition period for the shop website itself. Under Section 1(4) BFSG, only certain content is excluded: pre-recorded audio and video and office files (such as PDFs) published before 28 June 2025, third-party content you neither fund nor control, and archived content that has not been edited since the cut-off date.

What the law requires of your shop

Section 14 BFSG sets out two obligations. The shop must meet the accessibility requirements of the BFSG ordinance (BFSGV). And you must prepare the information required by Annex 3 BFSG and publish it in an accessible form.

The technical requirements. The law does not refer to WCAG directly. In practice, shops are tested against the harmonised European standard EN 301 549, which adopts the WCAG 2.1 success criteria at levels A and AA for web content. WCAG 2.1 AA is therefore the usual benchmark.

The accessibility information. Under Annex 3 BFSG you describe your service, explain how it is carried out, explain how the shop meets the requirements, and name the competent market surveillance authority. This is often called an accessibility statement, but it is not the same as the accessibility statement public bodies publish. For example, the BFSG does not require businesses to offer a feedback mechanism; that obligation applies to public bodies. What exactly belongs in the information, including a template for online shops, is covered in my German-language article Barrierefreiheitserklärung nach BFSG: Angaben und Muster.

What happens if you don't comply

• Fines: Offering a service that does not meet the requirements is an administrative offence under Section 37 BFSG. Fines of up to €100,000 are possible, and up to €10,000 for other breaches such as failing to provide information to the authority.
• Market surveillance proceedings: The competent authority for all of Germany is the Market Surveillance Authority of the Federal States for the Accessibility of Products and Services (MLBF) in Magdeburg. Under Section 32 BFSG, consumers can request proceedings against your shop, and so can recognised associations, without being affected themselves.
• Warning letters: Whether competitors can additionally send cease-and-desist letters for BFSG breaches under competition law is a question for your legal adviser.

Accessibility also matters beyond the law: anyone who cannot complete the checkout with a keyboard or cannot understand an error message will buy elsewhere. That affects not only people with disabilities but also older customers and anyone ordering one-handed on their phone.

The most common barriers in online shops

The same issues come up again and again in shop audits:

1. Weak contrast on text, prices and buttons
2. Elements that only work with a mouse, such as dropdown menus, filters or quantity selectors
3. Missing alternative text on product images
4. Unclear checkout error messages that don't say which field is wrong
5. Unlabelled buttons and icons that a screen reader only announces as "button"

Much of this can be fixed with reasonable effort.

Step by step to an accessible shop

Step 1: Check the current state

Automated tools find some of the errors, such as missing alternative text, contrast problems and missing form labels. Free options:

• WAVE Web Accessibility Evaluation Tool
• Google Lighthouse

Keyboard traps, an illogical focus order or a checkout that fails with a screen reader are not detected by these tools. That takes a manual test.

Step 2: The quick wins

• Add alternative text: Describe every product image briefly and specifically, e.g. "Women's leather shoe, red, 5 cm heel".
• Fix colour contrast: Under WCAG 2.1 AA, normal text needs a contrast ratio of at least 4.5:1. You can check this with the WebAIM Contrast Checker.
• Label your forms: Every input field needs a visible, linked label. Placeholder text inside the field is not enough.

Step 3: The bigger tasks

• Test keyboard operation: Can you get from the product page to the order confirmation using only Tab, Enter and the arrow keys?
• Check mobile usability: Are buttons large enough, and can the page be zoomed without content disappearing?
• Make dynamic elements work with screen readers: Filters, live search and cart notifications need suitable ARIA attributes so that changes are announced.

Step 4: Publish the information and train your team

• Publish the accessibility information under Annex 3 BFSG (German article), usually as a separate page linked in the footer. This has been mandatory since 28 June 2025.
• Train everyone who maintains content. An accessible theme won't help much if new products go live without alternative text.

Checklist for your shop

• All product images have meaningful alternative text.
• Text-to-background contrast is at least 4.5:1.
• Form fields are linked to labels; placeholders do not replace labels.
• The entire ordering process works with a keyboard (test with the Tab key).
• Videos have captions or transcripts.
• Headings are properly structured (h1, h2, h3).
• Checkout error messages say exactly what is wrong, e.g. "Please enter a valid email address".
• The accessibility information under Annex 3 BFSG is published.

You can find all criteria in detail in the W3C WCAG quick reference.

Tools and sources

• Contrast checker: WebAIM Contrast Checker
• Screen reader testing: NVDA (free for Windows)
• PDF checking: PAC
• Legal text: Barrierefreiheitsstärkungsgesetz (BFSG)
• Authority: MLBF questions and answers on the BFSG

Your next step

If your shop hasn't been tested yet, start with the checkout. That is where people either can or cannot buy, and it is where several of the typical barriers listed above sit: forms, error messages and keyboard operation.

Would you rather not do this yourself? I make WordPress and WooCommerce shops accessible: an audit against WCAG 2.1 AA, fixing the findings and the matching Annex 3 information. Get in touch and I'll take a look at your shop.

For plugins that help with an accessible WordPress website, see my post on the most important plugins for an accessible WordPress website.