Accessible online shops: what Germany’s BFSG requires

This guide explains the legal position based on the statutory text and guidance from the competent bodies, as of 28 September 2026. It is not a substitute for legal advice on your individual case.

1What it is about

The European Accessibility Act is an EU directive from 2019 that has applied in all member states from the same date. Its aim: people with disabilities should be able to use important products and services just like everyone else. That explicitly includes online retail.

The benchmark is set out in Section 3 BFSG: a service is accessible if people with disabilities can find, access and use it “in the generally customary way, without particular difficulty and, as a rule, without outside help” (our translation). For a shop, that means finding products, choosing them and paying – without a mouse, with a screen reader, with enlarged text or with impaired vision.

This affects more people than many assume. At the end of 2025, around 7.8 million people in Germany had a severe disability – 9.4 per cent of the population. Add to that older customers, people with temporary impairments and anyone looking at their phone in bright sunlight. Above all, then, accessibility means one thing: good usability for everyone.

2Does the law apply to your shop?

The BFSG applies to “services in electronic commerce”. This means websites and apps through which consumers conclude a contract at their own request (Section 2 no. 26 BFSG). A typical online shop falls within scope as soon as private customers can buy there.

According to the Federal Accessibility Agency (Bundesfachstelle Barrierefreiheit), purely B2B shops are not covered, because the law only regulates business with consumers; nor are purely presentational websites without a contract being concluded. Shops intended for business customers but also open to private individuals are a borderline case: going by the wording, they are not purely B2B shops.

The exemption for micro-enterprises

Micro-enterprises that provide services are exempt from the obligations (Section 3(3) BFSG). A micro-enterprise is one that employs fewer than ten people and has annual turnover of no more than 2 million euros or an annual balance sheet total of no more than 2 million euros (Section 2 no. 17 BFSG). Both conditions must be met: a shop with eight employees and turnover and balance sheet total of 3 million euros each is not exempt.

The exemption applies only to services. Anyone who manufactures or imports certain products themselves, such as computers, smartphones or e-book readers, has separate obligations for those products. For a shop selling fashion, furniture or bicycles, only the online shop as a service counts.

3What is actually required

The details are set out in the implementing ordinance (BFSGV). Under it, websites and apps must be “perceivable, operable, understandable and robust” (Section 12 BFSGV). These four terms are no accident: they are the core principles of the Web Content Accessibility Guidelines (WCAG), the internationally recognised standard for accessible websites.

Which standard applies

The technical reference is the European standard EN 301 549. The Federal Accessibility Agency currently names version V3.2.1 – for websites, that means WCAG 2.1 at levels A and AA. The new version V4.1.1, based on WCAG 2.2, was published in September 2026. However, it has not yet been published in the Official Journal of the EU and is therefore not yet the legal reference. Our advice: if you are building or rebuilding now, work to WCAG 2.2 straight away – the new version mainly adds to the old one rather than overturning it.

Specific obligations for shops

For online retail, Section 19 BFSGV additionally requires that sign-in, security checks and payment are accessible – precisely the steps where customers most often give up. If the manufacturer supplies accessibility information about its products, you must make it available in your shop.

Accessibility information

You must also state publicly how your shop meets the requirements – in your terms and conditions or “in another clearly perceptible manner” (Annex 3 BFSG). In practice, this is a dedicated, linked page. It contains a general description of your service, information on how to use it, a description of how the requirements are met, and the competent market surveillance authority. The page itself must be accessible.

And the obligation does not end at launch: the requirements must be met on an ongoing basis (Section 14 BFSG). Every new product image, every promotion and every extension therefore needs to be checked too.

4The checklist for your shop

The following 20 points cover the most common barriers in online shops. They are no substitute for a full audit, but they quickly show where your shop stands. The references in brackets point to the WCAG success criteria.

5How to find out where your shop stands

Automated testing tools are a good start, but they only find some of the problems. Whether an alt text makes sense or a purchase really works by keyboard is something only a person can judge. This sequence has proved its worth:

1. Run an automated scan

   Free tools such as Lighthouse in Chrome or the axe and WAVE browser extensions reveal missing alt texts, weak contrast and unlabelled fields within minutes.

2. Shop without a mouse

   Put the mouse aside and buy a product using Tab, Enter and the arrow keys. Wherever you get stuck or lose track of the focus, your customers get stuck too.

3. Listen with a screen reader

   NVDA for Windows is free, and VoiceOver is built into every Mac and iPhone. Listen to your home page, a product page and the checkout.

4. Zoom in and out

   Zoom to 200 per cent and open the shop on a small smartphone. Nothing may be cut off or overlap.

5. Get an expert audit

   Certainty comes from an audit against EN 301 549 by specialists, with a report that ranks the issues by urgency.

6A pragmatic approach in five steps

1. Establish whether you are affected

   Use the check above and keep an eye on the thresholds as your business grows.

2. Take stock

   Test as described and collect every issue in one list.

3. Purchase journey first

   Search, product page, basket, checkout: anything that prevents a purchase takes priority over everything else.

4. Check your theme and extensions

   Many barriers lie in the shop theme, in filters, sliders and cookie banners. Sometimes switching is cheaper than any repair.

5. Publish and keep at it

   Put your accessibility information online and make testing a fixed part of every change.

Steer clear of miracle widgets

So-called overlays promise to make a shop accessible with a single line of code. But they do not change the underlying code and can even interfere with assistive technologies such as screen readers. In the US, a well-known provider had to pay a million dollars in 2025 because, in the view of the Federal Trade Commission (FTC), it had misleadingly advertised that it made websites WCAG-compliant automatically.

7What happens if you don’t comply

Enforcement lies with the Länder market surveillance authority for accessibility (MLBF) in Magdeburg, a joint body of all 16 German states. It has been operating since 26 September 2025 and carries out checks both in response to reports and by random sampling (Section 28 BFSG). By June 2026, according to the state of Saxony-Anhalt, it had received almost 700 reports.

Fines are also possible: up to 100,000 euros for offering a service that is not accessible, and up to 10,000 euros for failures such as missing notifications or information (Section 37 BFSG). Consumers who cannot use the shop, and recognised associations, can ask the authority to open proceedings (Section 32 BFSG).

What about warning letters?

Since mid-2025, some law firms have been sending cease-and-desist letters over a lack of accessibility. Whether competitors can take action this way is disputed; we had found no published court decision on the question as of September 2026. No reason to panic – but a good reason not to put the issue off.

8Exemptions and transition

No general grace period

There is no transition period for the online shop itself. Section 38 BFSG concerns products already in use before the cut-off date and service contracts concluded beforehand – until 27 June 2030 at the latest.

Disproportionate burden

If accessibility would place a disproportionate burden on a business, the requirements do not apply to that extent (Section 17 BFSG). You must carry out the assessment under Annex 4 yourself, document it, keep it for five years, repeat it regularly and notify the authority. It is not an easy way out.

Fundamental alteration

The same applies if the requirements would fundamentally alter the essential characteristics of the service (Section 16 BFSG), again with documentation and notification.

Third-party content and archives

Not covered are, for example, third-party content that you neither fund, develop nor control, as well as archives and certain older media and files (Section 1(4) BFSG).

Selling to other EU countries

The European Accessibility Act applies throughout the EU, and each country has transposed it into its own law. If you sell to consumers in other member states, you must also inform the authorities there of any non-compliance (Section 14(4) BFSG).

9Our verdict

Accessibility is not red tape; it is good craftsmanship. An accessible shop is easier for everyone to use, loses fewer customers at the checkout and is better understood by search engines.

If you are planning a new shop or a rebuild anyway, build accessibility in from the start – retrofitting almost always costs more. And even if you are exempt as a micro-enterprise, you still win: all the people who gave up at someone else’s checkout.

Have your shop checked