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.

How big the gap still is shows in a test by the German charity Aktion Mensch: of 65 online shops run by large German websites, only 20 could be operated with the keyboard alone in June 2025 (Aktion Mensch: Online-Shops im Test, in German). You can run a similar keyboard test yourself in half an hour; the instructions are further down.

This article covers which shops the law applies to, which exemptions and transition periods exist, how to test your shop yourself, what WooCommerce, Shopify and Shopware provide, and what happens if you don't comply.

This article explains the legal situation from a web developer's point of view and is not legal advice. Last reviewed: 28 October 2026.

Which online shops the BFSG applies to

The short version:

Your shop	Does the BFSG apply?
Consumers can order and pay online	Yes, since 28 June 2025 (Section 1(3) no. 5 BFSG).
You sell only to businesses	Generally not, because the law refers to consumers. As soon as private customers can order, you are covered.
Fewer than ten employees and no more than €2 million turnover or balance sheet total	No, micro-enterprises are exempt for services (Section 3(3) and Section 2 no. 17 BFSG).
The website only informs, orders come by phone or email	Generally not, because no contract is concluded online. An order or booking form can change that.

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.

Exemptions for fundamental alteration or disproportionate burden

Two further exemptions apply to all businesses, but they are narrow. Under Section 16 BFSG you do not have to meet a requirement if doing so would fundamentally alter the basic nature of your service. Under Section 17 BFSG the same applies if the requirement would impose a disproportionate burden on you. The criteria are set out in Annex 4, above all the ratio of the cost of accessibility to your overall costs.

You cannot simply invoke them. You have to assess and document why the exemption applies, keep that assessment for five years after you last provided the service, and inform the market surveillance authority without delay. Under Section 17 you repeat the assessment at least every five years and whenever the service changes. Anyone who receives funding to improve accessibility cannot rely on Section 17. For most shops neither exemption is a realistic option: an online shop does not change its basic nature when buttons get labels and forms work with a keyboard.

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 article BFSG accessibility statement: requirements and template.

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.

The MLBF is a joint authority of Germany's 16 federal states and, by its own account, has been working nationwide since September 2025. At the beginning of June 2026 it had received almost 700 reports, including on possible breaches (MLBF announcement of 1 June 2026, in German). Customers can report barriers there through an online form or file an application under Section 32 BFSG, which opens administrative proceedings.

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.

Test your shop yourself in 30 minutes

Automated checkers find only some of the errors. If you play through a purchase yourself, half an hour shows you the places where customers really get stuck. Put the mouse aside and use only Tab, Shift+Tab, Enter, the space bar and the arrow keys.

1. Delete your cookies or open a private window and close the cookie banner using only the keyboard. If you cannot reach "Reject" or the focus gets stuck behind the banner, the purchase ends right there.
2. Go from the home page to a category, set a filter and change the sort order. With every Tab step, check whether you can see where the focus is.
3. Choose a product with a variant, such as size or colour, and add it to the cart. Can you tell without a mouse that it arrived there?
4. Change the quantity in the cart and go to checkout.
5. Leave a required field empty in the checkout and submit. The error message has to say which field is missing, and you should be able to get there directly with the keyboard.
6. Go as far as choosing the payment method. Card fields and payment buttons usually come from the payment provider and are embedded in the shop. Check that you can reach them with the keyboard and leave them again.
7. Zoom the page to 200 percent in the browser. Price, add-to-cart button and the checkout fields must stay visible and usable.
8. Listen to the journey once with a screen reader, with NVDA on Windows or VoiceOver on Mac and iPhone. Buttons should be announced with their purpose, not just as "button".

After that, an automated check with WAVE or Lighthouse (step 1 further down) is worth it for contrast, alternative text and form labels. This run-through does not replace an audit against all WCAG 2.1 AA criteria. It does show you quickly whether your shop has barriers that stop a purchase, and which of them to fix first.

WooCommerce, Shopify, Shopware: what the shop system provides and what it doesn't

All three major systems have worked on accessibility in recent years. None of them takes the obligation off your hands, because the law is aimed at you as the provider, not at the software vendor. Barriers usually appear where you add something yourself: theme, extensions, cookie banner, payment widgets, chat and your content.

WooCommerce. The team states that the front end of the WooCommerce plugin is substantially conformant with WCAG 2.2 level AA and that known issues are still being fixed (WooCommerce Accessibility). According to the WooCommerce documentation, the blocks for product listings, cart and checkout are built for keyboard and screen reader use. The same page warns that themes and plugins that modify the checkout can break accessibility. So check the checkout especially carefully if it contains plugins for payment methods, extra fields or vouchers. How I rebuild and look after WooCommerce shops is described on my page as a WooCommerce freelancer.

Shopify. Themes in the Shopify Theme Store must reach an average Lighthouse accessibility score of at least 90 and be fully keyboard accessible (Shopify theme requirements). For its checkout, Shopify has published a WCAG 2.2 conformance report that lists several criteria as only partially supported, such as visible focus and contrast. The same report says merchants are responsible for making sure their store complies with applicable laws, expressly including the European Accessibility Act (Shopify Checkout Accessibility Conformance Report). Apps and changes to the theme code are therefore yours to check.

Shopware. Shopware aims to meet WCAG 2.1 AA and the German BITV 2.0 in its storefront, but itself mentions open issues. Since version 6.7.0 the improvements are active by default; before that they were behind a feature flag (Shopware Developer Documentation). According to Shopware, developers are responsible for their own themes and extensions. If you still run 6.6 or older, plan the update to 6.7.

Is an accessibility plugin or overlay enough?

No. Germany's federal and state monitoring bodies for the accessibility of public websites state that an overlay tool does not necessarily make a website accessible and often makes it harder to use with assistive technology (BFIT-Bund: assessment of overlay tools, in German). The assessment is about public bodies, but the technical problem is the same for shops. Which plugins really help with testing, and why overlays such as accessiBe or UserWay do not make a shop BFSG-compliant, is covered in my guide making WordPress accessible.

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

Start with the keyboard test above. After that, automated tools find some of the remaining 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, 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

Frequently asked questions

Does the BFSG apply to my B2B shop?

Generally not, because the law covers online shops through which consumers conclude contracts. As soon as private customers can order from you, you are covered. Micro-enterprises with fewer than ten employees and no more than €2 million turnover or balance sheet total are exempt.

What happens if my shop is not accessible?

The German market surveillance authority MLBF can require you to fix it, and consumers or recognised associations can request proceedings against your shop (Section 32 BFSG). For a shop that does not meet the requirements, Section 37 BFSG provides for fines of up to €100,000. On top of that come customers who abandon the purchase because they cannot get any further.

Is an accessibility plugin enough?

No. Plugins help with testing and compensate for individual weaknesses, but a shop becomes accessible through its theme, content, forms and checkout. Germany's federal and state monitoring bodies state that overlay tools do not necessarily make a website accessible and often make it harder to use with assistive technology.

Do I have to do anything myself with Shopify, WooCommerce or Shopware?

Yes. WooCommerce, Shopify and Shopware provide a core that is meant to be largely accessible, but the BFSG obligation lies with you as the provider. Shopify says so explicitly in its checkout conformance report. You check your theme, apps or plugins, cookie banner, payment widgets and your product texts and images yourself.

What is the quickest way to check my shop?

Play through a purchase using only the keyboard, from the cookie banner through filters and the cart to the payment method, and leave one required field empty in the checkout. Then let WAVE or Lighthouse check contrast, alternative text and labels. Together this takes about half an hour and does not replace a full WCAG 2.1 AA audit.

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.