BFSG Accessi­bility: Obligations for Websites, Stores and Apps

Since June 28, 2025, online stores, booking flows, apps and other digital services for consumers in Germany must be accessible – as required by the German Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG). For services, only microenterprises are exempt; purely B2B offerings and informational sites without contract conclusion are generally not covered. Anyone affected must design their offering according to the requirements of the accompanying ordinance, publish accessibility information and expect checks by market surveillance.

The BFSG transposes the European Accessibility Act – EU Directive 2019/882 – into German law; the details are set out in the ordinance implementing the BFSG (BFSGV). This article covers the legal side: scope, exemptions, obligations, deadlines and consequences. To learn how to implement and test the technical requirements in practice, read our article on WCAG 2.2 and BITV 2.0 in practice.

Which products and services the BFSG covers

The law distinguishes between products and services. Products are consumer hardware; services are digital offerings – and that is where most obligations for SMEs lie.

Area	Examples	Typically affected
Products	Computers, laptops, tablets and smartphones including operating systems, e-readers, routers, smart TVs, self-service terminals such as ATMs, ticket machines and check-in kiosks	Manufacturers, importers, distributors
E-commerce services	Online stores, booking and reservation flows, ticket sales, paid subscriptions via website or app	Retailers, service providers, platforms
Banking services	Online banking, payment services, consumer credit, investment services for consumers	Banks, financial service providers
Telecommunications and media	Phone and internet services, access to audiovisual media services, e-books including reading software	Network operators, streaming services, publishers
Passenger transport	Websites, apps, e-tickets and travel information in air, bus, rail and waterborne transport – to a varying extent depending on the mode	Transport operators

For most SMEs, e-commerce services are the decisive category. This means services provided electronically via websites or apps at the individual request of a consumer with a view to concluding a consumer contract. That covers the classic online store as well as binding online appointment booking, ticket sales or taking out a subscription.

Who is exempt – and where the boundaries lie

Microen­ter­prises

Microenterprises that provide services are exempt from the requirements. A microenterprise employs fewer than ten people and has an annual turnover or an annual balance sheet total of no more than €2 million. Important: the exemption applies to services only. Anyone who manufactures, imports or distributes products must meet the requirements even as a microenterprise.

B2B offerings and informa­tional sites

Purely B2B offerings are not aimed at consumers and are therefore generally not covered. What matters, however, is how the offering is actually set up: a store for business customers in which private individuals can order without any check may still fall under the law. A company website that only provides information is usually not affected – a contact form alone does not lead to a contract. Add a binding online booking or an ordering process, though, and the picture changes.

Dispro­por­tionate burden and fundamental alteration

The law allows exemptions if accessibility would require a fundamental alteration of the service or impose a disproportionate burden. This exemption is narrow: you must assess it yourself, document it and inform the market surveillance authority. It is not a blanket way out of an inconvenient project.

What the BFSG specifically requires

The requirements are set out in the ordinance implementing the BFSG. They follow the familiar principles: an offering must be perceivable, operable, understandable and robust. For websites and apps, this means, among other things:

• full operability via keyboard and with screen readers such as NVDA, VoiceOver or TalkBack
• sufficient contrast, scalable text and information that is not conveyed by color alone
• text alternatives for images and controls, plus captions for videos
• understandable forms with labels and error messages in plain language
• accessible identification, security and payment functions where they are part of the service
• information on the accessibility of the products offered, where the manufacturer provides it

In practice, the technical benchmark is the European standard EN 301 549, which refers to the WCAG criteria of levels A and AA for web content. The widely used version V3.2.1 of the standard references WCAG 2.1; if you implement WCAG 2.2 AA, you cover these criteria and are prepared for new versions of the standard. Looking at the entire journey is crucial: not just the home page must be accessible, but the path from product search through cart, login and payment to the order confirmation – including embedded third-party components such as the cookie banner, chat widget or payment provider.

Information duty: the accessi­bility statement under the BFSG

Service providers must provide information on how their offering meets the requirements – in their general terms and conditions or in another clearly perceivable way. In practice, the term accessibility statement, familiar from the public sector, is often used for this. The information must itself be accessible and remain available for as long as the service is offered. It includes:

1. a general description of the service in plain language
2. explanations needed to understand and use the service
3. a description of how the service meets the accessibility requirements
4. ideally, known limitations, a schedule for fixing them and a contact option for feedback

The last point goes beyond the mandatory minimum, but it builds trust and gives users a direct way to report problems. It is also common to name the competent market surveillance authority.

Deadlines and transitional rules

The requirements have applied since June 28, 2025. For existing offerings, the law contains transitional rules:

• Service providers may continue to use products they lawfully used for their service before June 28, 2025 until June 27, 2030.
• Service contracts concluded before June 28, 2025 may continue unchanged until they expire, but no later than June 27, 2030.
• Self-service terminals put into operation before that date may remain in use until the end of their economic life, for a maximum of 15 years.

Opinions differ on whether an existing online store counts as such a product and would therefore have until 2030. No reliable grace period for websites can be derived from this. At the latest with every relaunch, change of store platform or major rebuild, you should make accessibility a binding requirement.

Enforcement and consequences of violations

Compliance is monitored by Germany’s federal states, which pool this task in a joint market surveillance authority based in Magdeburg. The authority can review offerings, demand corrections within a deadline and – if deficiencies persist – restrict or prohibit the provision of a service. Administrative offenses can be punished with fines of up to €100,000.

Consumers can ask market surveillance to take action against an inaccessible offering; recognized associations also have the right to file requests and bring legal action. Whether competitors can additionally send cease-and-desist letters under German competition law is debated among experts. Either way, a documented audit and action plan is worth far more in an emergency than an overlay tool that only changes the surface.

In practice: assess applica­bility and avoid mistakes

A typical scenario: a garden equipment dealer with 35 employees runs an online store for private and business customers and offers inspection appointments that can be booked online. Here is a structured approach:

1. Inventory your offerings: store, booking, customer account, app, subscriptions – every feature through which consumers conclude contracts goes on the list.
2. Check exemptions: with 35 employees, the microenterprise exemption does not apply; the store and appointment booking are covered.
3. Assess the current state: audit against WCAG 2.2 AA with automated tests, keyboard and screen reader – along the real purchase and booking journey.
4. Plan measures: checkout blockers first, then forms, contrast and content; review third-party components and replace them if necessary.
5. Document: file the audit report and action plan, publish the accessibility information and update it with every release.

Common imple­menta­tion mistakes

• testing only the home page instead of the complete purchase or booking journey
• relying on an overlay tool instead of fixing errors in the code
• ignoring third parties such as the payment provider, cookie banner or booking widget
• writing the accessibility information once and never updating it
• leaving accessibility out of the requirements specification and acceptance criteria, so it gets lost in the next relaunch

How Nano Concepts can help

We audit your website, online store or app along real user journeys, prioritize the findings and implement the changes in design and code – together with our partner agency LOMA DESIGN. For new projects, we build accessibility into the design system and implementation from the start, for example with an accessible website. The legal assessment of your individual case remains a matter for your legal counsel; we provide the technical basis and documentation for it. In a free initial consultation, we clarify where you stand and what effort is realistic.

This article does not replace legal advice.