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Since 28 June 2025, Germany's Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) has been in force. It requires many businesses to make online shops, booking flows and other consumer-facing digital services accessible. This article explains who is affected, which exemptions apply and what the requirements mean in practice for websites and shops.
Please note: this article provides a general overview and is not legal advice. Whether and to what extent the BFSG applies to your business should be assessed individually by a legal professional.
What is the BFSG?
The BFSG transposes the European Accessibility Act (EAA), an EU directive from 2019, into German law. Accessibility here means that people with disabilities must be able to find, access and use products and services in the usual way, without particular difficulty and generally without help from others.
The law applies to products placed on the market and to services provided to consumers from 28 June 2025 onwards (as of November 2026). The details are set out in an accompanying ordinance, the BFSGV.
Which products and services are covered?
The BFSG contains a closed list. Products include consumer computers, smartphones and operating systems, certain self-service terminals such as ATMs or ticket machines, and e-book readers.
Covered services include, among others:
- electronic communications services
- certain elements of passenger transport services, such as websites, apps and e-tickets
- consumer banking services
- e-books and dedicated software
- e-commerce services
The last item matters most for typical businesses. It covers services provided electronically via websites or mobile apps, at the individual request of a consumer, with a view to concluding a consumer contract. Typical examples are online shops, online appointment booking that concludes a contract, and order forms for paid services.
Who is not affected?
Purely B2B offerings
The BFSG is tied to consumer contracts. According to the prevailing view of chambers of commerce and specialist bodies, a shop that sells exclusively to businesses does not fall under the e-commerce obligations. A shop that also sells to private customers is not exempt just because it serves business customers as well.
Purely informational websites
A corporate website that only provides information and does not allow consumers to conclude contracts is generally not an e-commerce service. The boundary is not always clear, for example with contact forms that effectively lead to a contract. A case-by-case review is worthwhile.
Microenterprises providing services
Under the BFSG, a microenterprise has fewer than ten employees and either an annual turnover or a balance sheet total of no more than EUR 2 million. The accessibility requirements do not apply to microenterprises that offer or provide services.
Important: this exemption applies to services only. A microenterprise that manufactures or sells products from the list remains subject to the product obligations. If you are close to the thresholds, keep an eye on them, as growth can remove the exemption.
What requirements apply to websites and shops?
The BFSGV follows four core principles that also underpin the widely used Web Content Accessibility Guidelines (WCAG). Content must be perceivable, operable, understandable and robust. Robust means that assistive technologies such as screen readers (software that reads screen content aloud) can reliably interpret the page.
In practice, the harmonised European standard EN 301 549, which refers to WCAG for web content, serves as the benchmark. For an online shop this means, for example:
- All functions are keyboard accessible, including cart, variant selection and checkout.
- Informative images have meaningful alternative text.
- Text and controls have sufficient colour contrast.
- Form fields are properly labelled; error messages are clear and not indicated by colour alone.
- The page remains usable at 200 percent zoom.
- Headings, lists and navigation are correctly marked up in the code.
- Videos have captions where needed.
- Time limits, for example during payment, can be extended.
Third-party components are often overlooked: cookie banners, payment widgets, chat windows or review plugins. They are part of the service and must be operable too.
Accessibility information
Providers must also publish information on how their service meets the requirements. This information must itself be accessible and can be provided, for example, in the terms and conditions or in another clearly perceivable way. Many businesses create a dedicated accessibility page for this.
Transition periods and enforcement
Transitional rules apply in certain cases. Service providers may continue to use products they lawfully used before 28 June 2025 until 27 June 2030. Service contracts concluded before the cut-off date may continue unchanged until that date at the latest. For an online shop that continuously concludes new contracts, this rarely helps.
Enforcement lies with the joint market surveillance authority of the German federal states for accessibility (MLBF), based in Magdeburg, which has been fully responsible since 26 September 2025. Consumers can report accessibility barriers there. The BFSG provides for fines of up to EUR 100,000; if deficiencies are not fixed despite deadlines, the authority can, as a last resort, prohibit the service.
Checklist: how to proceed
- Clarify whether you are affected: Do consumers conclude contracts via your website or app? Are you above the microenterprise thresholds? If in doubt, get legal advice.
- Take stock: Review the key user journeys: home page, product search, product page, cart, checkout and customer account.
- Use automated tests: Browser extensions for accessibility testing find many technical errors, but not all.
- Test manually: Complete the checkout using only the keyboard and spot-check with a screen reader.
- Assess theme and plugins: With WordPress and WooCommerce, the theme largely determines accessibility. Check whether your extensions are accessible.
- Prioritise: Fix barriers that prevent a purchase first.
- Publish the information: Prepare the accessibility information for your service.
- Make it stick: Check new content, updates and campaign pages before publishing.
Be cautious with so-called overlay tools that add an accessibility toolbar via script. They do not replace fixing issues in code and content.
Support from Simplify Data
Simplify Data builds websites and shops with React, Next.js, WordPress and WooCommerce for businesses in Kiel, Schleswig-Holstein, Hamburg and remotely across Germany. We review existing sites for technical barriers and implement fixes in the code and theme. The legal assessment of whether you are affected should come from lawyers or chambers of commerce. Request accessible web development