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Germany

The BFSG: accessibility for online shops in Germany

Since 28 June 2025, the Barrierefreiheitsstärkungsgesetz (BFSG), Germany's transposition of the European Accessibility Act, requires many consumer-facing online services to be accessible. Here is who it covers, what it asks of a website or online shop, and how we get you there.

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The BFSG in a few lines

The Barrierefreiheitsstärkungsgesetz, literally the Accessibility Strengthening Act, transposes Directive (EU) 2019/882, the European Accessibility Act, into German law. It applies to certain products placed on the market and certain services provided to consumers after 28 June 2025.

Its core rule is short (section 3): products and services must be accessible, meaning that people with disabilities can find, access and use them in the usual way, without particular difficulty and, in principle, without outside help. The detailed requirements are set by a federal regulation adopted under section 3(2), in line with Annex I of the directive. Services that meet the harmonised European standards published in the Official Journal of the EU are presumed to meet those requirements (section 4); for websites, the relevant standard is EN 301 549, which builds on the Web Content Accessibility Guidelines (WCAG).

Who is covered

Among the services listed in section 1(3), the one that concerns most businesses is e-commerce: services offered through websites and mobile apps, provided electronically at the individual request of a consumer with a view to concluding a consumer contract (section 2). In plain terms, an online shop selling to consumers, a booking or ordering service for private customers, or an app used to buy from you.

The other services covered are telecommunications, certain elements of passenger transport, consumer banking and e-books.

Three limits matter in practice:

  • Business-to-business only: a shop or portal that sells exclusively to businesses is not an e-commerce service for consumers within the meaning of the BFSG.

  • Micro-enterprises providing services are exempt (section 3(3)). A micro-enterprise employs fewer than ten people and has either an annual turnover or an annual balance sheet total of no more than 2 million euros (section 2).

  • Certain content is excluded (section 1(4)): pre-recorded video and audio and office documents published before 28 June 2025, some online maps, third-party content the business neither funds, develops nor controls, and archives that are no longer updated.

A brochure website that presents a business without selling to consumers is generally outside the scope. Accessibility remains good practice, and the exemption for micro-enterprises disappears as soon as the business grows past the thresholds.

What an online shop must do

  • Make the whole purchase journey accessible: navigation, search, product pages, cart, checkout, payment, customer account and order confirmation.

  • Provide information on accessibility, in the terms and conditions or in another clearly perceptible way: a general description of the service in an accessible format, the explanations needed to use it, how it meets the accessibility requirements, and the competent market surveillance authority (Annex 3). In practice, this takes the form of an accessibility statement.

  • If a requirement would impose a disproportionate burden, assess and document it, and keep the assessment for five years (section 17). This is an exception to be justified, not a general way out.

Transitional rules exist (section 38): services may continue to use products they were already lawfully using before 28 June 2025 until 27 June 2030 at the latest, and service contracts concluded before that date may run unchanged until they expire, but no later than 27 June 2030. They do not exempt a new shop or a redesign.

Enforcement

The federal states have set up a joint market surveillance authority for the whole of Germany: the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF), based in Magdeburg.

When it finds that a service is not accessible, it first asks the provider to correct it within a set period. If nothing is done, it repeats the request under threat of prohibition, and can ultimately order the service to be stopped (section 29). Offering or providing a service that does not meet the requirements is an administrative offence punishable by a fine of up to 100,000 euros (section 37).

How we audit and fix your shop

Our accessibility compliance service starts with an audit of a representative sample of pages and the full purchase journey. We combine automated tests (axe DevTools, WAVE, Lighthouse) with manual checks of the criteria that tools cannot detect. You receive a report with a compliance grid by criterion, screenshots, a prioritised action plan and a draft accessibility statement to adapt with your details.

If you want us to fix the issues, we quote the remediation separately and apply the technical fixes to the theme and templates, so that they apply across the shop: contrast, keyboard navigation, structure, forms, text alternatives. On Shopify or WooCommerce, we also check the apps and plugins that insert their own interface, and suggest alternatives when they cannot be made accessible. PDF documents and testing with people with disabilities are not included unless the quote provides for them.

The starting price is shown at the top of this page and on our pricing page. For a new shop, we build accessibility in from the start: see online shop creation and online shop redesign.

What we do not promise

We do not certify BFSG compliance and we do not give legal advice. Whether your business is a micro-enterprise, whether a service falls within the scope, and whether a burden is disproportionate are legal assessments that remain yours or your adviser's. What we deliver is an audit against the technical requirements, fixes and a record of what has been tested and corrected.

Frequently asked questions

We have eight employees. Are we exempt?

If your annual turnover or your balance sheet total is no more than 2 million euros, you are a micro-enterprise and the BFSG exempts you for services. Check both criteria with your adviser; accessibility still widens your audience.

We sell only to businesses. Does the BFSG apply?

The e-commerce services covered are those provided to consumers with a view to a consumer contract. A shop reserved for business customers is generally outside the scope; a mixed shop open to consumers is not.

Is an accessibility overlay widget enough?

No. A widget added on top of the page does not fix the underlying code, the structure or the checkout. We fix the theme and templates themselves.

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