At a glance
- It covers services in electronic commerce for consumers, which includes online shops. Pure B2B stores are not covered.
- Microenterprises that provide services are exempt: fewer than ten employees and annual turnover or balance sheet total of no more than €2 million.
- In practice, the benchmark is the standard EN 301 549, which refers to WCAG 2.1 at level AA for web content.
- Accessibility information is also mandatory. For a service that does not meet the requirements, the law provides for fines of up to €100,000.
Who the law applies to
The BFSG applies to certain products and to services provided to consumers after 28 June 2025. These expressly include services in electronic commerce: websites and apps through which consumers enter into contracts, meaning online shops, booking flows and comparable offerings. Across the EU, the European Accessibility Act sets the same requirements; the BFSG is how Germany implements it.
Stores that sell exclusively to businesses are not covered. Anyone serving both groups falls under the law.
Microenterprises are exempt for services (Section 3(3) BFSG). Under Section 2 no. 17 BFSG, a microenterprise is a company with fewer than ten employees and annual turnover or balance sheet total of no more than €2 million.
Certain content is also exempt, including prerecorded video and audio content and office files published before 28 June 2025, third-party content that the company neither funds nor controls, and archives that are no longer updated.
What accessible means in practice
The exact requirements are set out in the ordinance to the BFSG (BFSGV). In practice, the European standard EN 301 549 serves as the benchmark; for websites, it refers to the Web Content Accessibility Guidelines (WCAG) 2.1 at level AA. Building to the newer version, WCAG 2.2, meets them as well.
- Operation
- Every function reachable by keyboard, with a visible focus
- Contrast
- At least 4.5 : 1 for body text
- Images
- Text alternatives for product images and icons
- Forms
- Labelled fields, understandable error messages
- Structure
- Headings, lists and regions readable by screen readers
- Zoom
- Enlargement to 200 per cent without loss of content
- Time
- No time limits without an option to extend them
- Payment
- Payment and sign-in processes accessible as well
- Media
- Captions for videos published after the deadline
Accessibility information
Under Section 14 BFSG and Annex 3, a store describes how it meets the requirements and makes this information itself accessible, for example in its terms and conditions or on a page of its own. This includes a general description of the service, explanations of how to use it, a description of how the requirements are met and the competent market surveillance authority.
An audit in four steps
- Automated test: tools like axe or Lighthouse find missing labels, weak contrast and structural errors, but only part of all problems.
- Keyboard test: the entire purchase process is completed without a mouse, from search to order confirmation.
- Screen reader test: with VoiceOver on iPhone and Mac and NVDA on Windows, it becomes clear whether products, variants and error messages are read out understandably.
- Documentation: results, fixes and open items are recorded; they form the basis for the accessibility information.
So-called overlays, bars with sliders for font size and contrast laid over the page, do not fix errors in the code. They are no substitute for an accessible implementation.
Enforcement and fines
The competent authority is the joint market surveillance body of the German federal states for the accessibility of products and services (MLBF), based in Magdeburg. If a service does not meet the requirements, it sets a deadline for remedying it and can, as a last resort, prohibit the service. Consumers and recognised associations can apply to it to open proceedings.
Anyone who intentionally or negligently provides a service that does not meet the requirements commits an administrative offence under Section 37(1) no. 8 BFSG. Fines of up to €100,000 are possible for this (Section 37(2) BFSG).
This article summarises the legal situation as of the date stated and is no substitute for legal advice in an individual case.
Frequently asked questions
Does the BFSG apply to existing stores too?
Yes. What matters is whether the service is provided to consumers after 28 June 2025. The transitional rules in Section 38 BFSG concern products already in use before the deadline and older contracts; how far they reach in an individual case needs legal review.
Is an accessibility plugin enough?
No. Extensions that show a bar for enlarging or recolouring change nothing about missing labels, keyboard operation or the structure of the page.
How a store is built accessible from the start is described in the Commerce module.