Accessible websites and online shops — what the BFSG requires

The German Accessibility Improvement Act (Barrierefreiheitsstärkungsgesetz, BFSG) has applied since 28 June 2025 to companies that serve consumers in electronic commerce — that is, B2C online shops, booking and appointment journeys, retail banking, passenger transport, telecommunications and e-books. Purely B2B offerings are in principle not covered. For services there is an additional exemption for micro-enterprises with fewer than 10 employees and no more than 2 million euros in annual turnover or annual balance sheet total. The binding assessment of an individual case belongs with a lawyer; we implement the technical requirements.

If a covered offering does not meet the requirements of the German Accessibility Improvement Act (BFSG), market surveillance authorities can object to the defects and demand that they be put right; if that does not happen, fines follow and, in the extreme case, a ban on the offering. Alongside this, competition-law warning letters are circulating under § 3a of the German Unfair Competition Act (UWG); whether they hold has not yet been settled in court. Under § 32 BFSG, consumers and authorised associations can ask the market surveillance authority to step in. In practice it usually starts more harmlessly: with a complaint through the feedback channel or an enquiry from the authority. Anyone who knows the state of their website and can produce a plan of action is then in a far better position than someone who only starts checking at that point.

Purely B2B shops are in principle not covered by the German Accessibility Improvement Act (BFSG), because the act relates to services for consumers. In practice the line is rarely as clean as it looks on the org chart: as soon as a shop also sells to private individuals, as soon as traders can order without being checked, or as soon as there is a publicly accessible booking journey, it becomes a question of the individual case. That assessment belongs with a lawyer. Either way, B2B users also benefit from keyboard operation and readable contrasts.

No, an accessibility overlay does not meet the requirements — it covers barriers instead of removing them. The script is laid over an existing website and changes nothing in the source code, which is where the problems sit: missing labels, wrong heading hierarchies and elements that cannot be operated by keyboard all remain. Accessibility happens in the markup, not in an embedded script. So we rebuild the templates themselves — in TYPO3, WordPress and Shopware 6.

The effort depends on the state of the system, which is why there is always an audit at the start and never a flat rate. A well-maintained website with a clean theme often needs no more than corrections to contrasts, focus styles and forms. A shop that has grown over the years, with page-builder pages, third-party plugins and custom widgets, is a rebuilding project. After the audit you receive a prioritised plan of action with the effort for each item — and you decide what gets done first.