Does your website have to be accessible? The BFSG explained

The BFSG implements an EU directive, the European Accessibility Act. The aim is that people with impairments – for example in seeing, hearing, mobility or understanding – can use products and services just like everyone else. That includes many older people too.

For websites, one area matters most: so-called services in electronic commerce. This means websites and apps through which consumers can conclude a contract – from an online shop to a paid online booking.

Whether your website falls under the law depends on two questions: What happens on the site, and how big is your business?

• Usually affected: online shops for consumers and websites with online booking or ordering where a contract with consumers is concluded
• Usually not affected: purely informational or business-card sites without any contract being concluded, and offers aimed only at businesses
• Exempt: micro-enterprises that provide services – businesses with fewer than ten employees and no more than two million euros in annual turnover or balance sheet total
• Important: The exemption applies to services. Anyone who manufactures or sells products that themselves fall under the law is obliged even as a micro-enterprise

The benchmark is the Web Content Accessibility Guidelines, WCAG for short, version 2.1 at level AA. The European standard EN 301 549 refers to them. That sounds technical, but it can be translated into understandable requirements:

• Text has enough contrast with the background and can be enlarged without anything being cut off
• The whole site can be operated without a mouse, and you can always see where you are
• Images with content have a text description that screen readers can announce
• Form fields are labelled, and error messages say clearly what to do
• Headings structure the page sensibly so that you can find your way without seeing it
• Nothing works only through colour, sound or mouse movement, and motion can be switched off
• Videos with important content have subtitles

In addition, those affected must publish information on accessibility – in the terms and conditions or in another clearly visible place. It describes the service, explains how the requirements are met and names the competent market surveillance authority. The statement should be reachable from every page and itself be accessible.

The competent body is the joint market surveillance authority of the German federal states for the accessibility of products and services (MLBF), based in Magdeburg. It has been actively checking since the beginning of 2026, sets priorities and follows up on reports from consumers. A graduated approach is planned: first a request to remedy deficiencies. Only after that are further measures considered, and for serious violations fines of up to 100,000 euros.

In addition, warning letters from competitors are circulating. Whether violations of the BFSG can be pursued this way at all has not yet been settled by the courts. So don't pay anything without checking – have such a letter reviewed legally.

Some providers promise to make a website accessible with a single embedded tool: an icon in the corner that lets you switch font size and contrast. That sounds convenient, but it does not remove the actual barriers. Missing labels, operation that only works with a mouse, or an illogical structure are built into the page itself – and have to be solved there.

On top of that, such tools often load scripts from third parties. That is a data protection issue of its own.

You don't have to solve everything at once. This order has proven itself:

• Clarify whether you are affected: Does the law apply to you? If in doubt, have it checked legally
• Take stock: free testing tools such as Lighthouse in Chrome or WAVE find many errors automatically; a test with the keyboard and your phone's screen reader shows the rest
• The ordering path first: product pages, basket, checkout and forms matter most
• Publish the statement: easy to find and updated every year
• Keep at it: check new content and features with every change

Accessibility doesn't only help people with disabilities. Good contrast is also easier to read on a phone in the sun, large controls are easier for older customers to hit, clear forms are submitted more often – and a clean structure is also understood better by Google.

That is why we build our websites from the start with sufficient contrast, keyboard operation, labelled forms and motion that can be switched off, and check this automatically before every handover. Whether a site meets all requirements, however, also depends on the content that is added later.

If you sell online to consumers or take bookings and are not a micro-enterprise, you should tackle the topic now. The requirements are extensive but manageable – especially if a website is built cleanly from the start. Retrofitted tools do not replace that. And even if you are not obliged, an accessible site wins you customers.