BFSG website requirements: what Germany's accessibility law asks of online shops

The Barrierefreiheitsstärkungsgesetz (BFSG, roughly "Accessibility Strengthening Act") is Germany's national law for the European Accessibility Act. This page explains what it asks of an online shop, section by section, with links to the official text on gesetze-im-internet.de, the federal justice ministry's legal information service. For the EU picture, see EU accessibility law for websites; to compare Germany with other member states, see the European Accessibility Act by country.

The BFSG at a glance

Does the BFSG apply to your online shop?

Section 1(3) applies the law to these services when they are provided to consumers after June 28, 2025: telecommunications services; websites, apps, e-tickets, travel information and self-service terminals for air, bus, rail and water passenger transport (for urban, suburban and regional transport, only interactive self-service terminals); consumer banking services; e-books and the software for them; and "Dienstleistungen im elektronischen Geschäftsverkehr", which is e-commerce.

Section 2, point 26 defines e-commerce services as digital services offered through websites and mobile apps that are provided electronically, at a consumer's individual request, with a view to concluding a consumer contract. A consumer (point 16) is a natural person buying for purposes that are mainly outside their trade or profession. In plain terms, if consumers can buy from your website or app, the shop is the kind of service the law describes, whatever platform it runs on and whatever it sells: the federal accessibility office's e-commerce FAQ says a shop is covered even when the products it sells are not themselves covered by the BFSG. Point 4 defines a service provider as anyone who provides or offers a service to consumers on the EU market; the definition does not mention where the provider is based. If you run on Shopify or WordPress, our pages for Shopify stores and WordPress sites cover what the platform does and does not handle.

The core rule is section 3(1): services an economic operator offers or provides must be accessible. The law calls them accessible when people with disabilities can find, access and use them in the usual way, without particular difficulty and, as a rule, without help from others.

Content the law leaves out

Section 1(4) excludes these kinds of website and app content:

• pre-recorded time-based media, such as video, published before June 28, 2025;
• office file formats published before June 28, 2025;
• online maps and mapping services, as long as essential information for navigation maps is provided in an accessible digital form;
• third-party content that the business neither funds, develops nor controls;
• content that counts as an archive because it is not updated or edited after June 28, 2025.

These are the only kinds of content the law lists as excluded. The federal accessibility office's e-commerce FAQ reads the requirements as suggesting that the whole website or app must meet them, not only the pages that lead to a purchase, and the labor ministry's guidelines on applying the BFSG give an example shop whose entire website, including checkout, must be accessible. The office-file exclusion covers only files published before June 28, 2025, so newer downloadable documents need attention too; our accessible PDF guide and PDF checker help with PDFs.

The microenterprise exemption

Section 3(3) says the accessibility duty in section 3(1) does not apply to microenterprises (Kleinstunternehmen) that offer or provide services. Section 2, point 17 defines a microenterprise as a business that employs fewer than ten people and has either an annual turnover of at most €2 million or an annual balance sheet total of at most €2 million.

Both parts of the definition matter. A shop with 12 employees is not a microenterprise, however small its turnover. A shop with 6 employees, €3 million turnover and a €1.5 million balance sheet total meets the definition, because only one of the two financial limits needs to be met. The exemption covers services only: a business that manufactures, imports or distributes a covered product has product duties at any size. "Covered product" means the list in section 1(2), such as consumer computers, smartphones, e-readers and payment terminals, so selling other physical goods online does not end the exemption. Section 3(3) also has the federal labor ministry publish guidelines to help microenterprises apply the law, and the ministry's guidelines on applying the BFSG give the example of a hair salon with four employees and €1 million in turnover that sells hair care products on its website: it does not have to meet the requirements. Under section 15, the federal accessibility office, the Bundesfachstelle für Barrierefreiheit, also advises microenterprises on applying the law.

What an online shop must do

Section 14 sets the duties of a service provider. In summary:

• Two conditions before offering the service (14(1)): the service meets the requirements in the BFSGV, and the provider has prepared the information described in Annex 3 and made it available to the public in an accessible form.
• Keep the information (14(2)) for as long as the service is offered.
• Stay accessible (14(3)) whenever the service is offered, taking into account changes to the service, to the requirements and to the standards relied on.
• Correct and report (14(4)): if the service does not conform, take corrective action and inform the market surveillance authority, and those of other EU states where the service is offered, without delay.
• Cooperate (14(5)): give the authority the information it needs, on a reasoned request.

The technical requirements in the BFSGV

The concrete requirements sit in the ordinance. Section 12 of the BFSGV applies to all covered services and requires, among other things, that websites, online applications and mobile apps are designed to be "wahrnehmbar, bedienbar, verständlich und robust": perceivable, operable, understandable and robust, the four principles WCAG is built on. Section 12 also asks that information about the service is offered through more than one sensory channel, uses an adequate font size with sufficient contrast and spacing between letters, lines and paragraphs, and comes with an alternative presentation for non-text content.

Section 19 of the BFSGV adds three requirements for e-commerce:

• provide information about the accessibility of the products and services for sale, where the responsible economic operator supplies that information;
• make identification, authentication, security and payment functions perceivable, operable, understandable and robust when they are delivered as part of the service;
• make identification methods, electronic signatures and payment services perceivable, operable, understandable and robust when they are provided.

Neither the BFSG nor the BFSGV names a WCAG version. Section 3 of the BFSGV requires the state of the art to be taken into account and has the Bundesfachstelle publish a list of the most important standards. Section 4 of the BFSG presumes that a service meets the requirements where it follows harmonized standards whose references are published in the EU's Official Journal. The 2021 Official Journal citation of EN 301 549 v3.2.1, which uses WCAG 2.1 Level AA, was made under the Web Accessibility Directive for public sector sites; AccessibleEU describes v3.2.1 as the current reference for the EAA too, and v4.1.1, which moves to WCAG 2.2, gives a presumption of conformity only once it is cited (see our EN 301 549 page).

The Bundesfachstelle's standards page for the BFSG calls EN 301 549 the central technical reference for digital accessibility and says that, until the harmonized standards requested by the European Commission are published and announced in the Official Journal, the current EN 301 549 and WCAG are the main guide for putting the BFSG into practice. The conformity tables that section 3(2) of the BFSGV also asks it to publish were not available when we checked. Building to WCAG 2.2 AA meets the WCAG baseline of both versions (v3.2.1 still lists WCAG 4.1.1 Parsing, which WCAG 2.2 removed), and our WCAG 2.2 checklist lists what that means.

Common failures to check first

The WebAIM Million 2026 report found low-contrast text on 83.9% of home pages and missing alternative text on 53.1%. Both relate to what the BFSGV asks for on contrast and on alternatives for non-text content. A shop-focused version of the checks:

The information duty (Annex 3)

Annex 3, point 1 says the provider states, in its general terms and conditions or in another clearly perceptible way, how the service meets the accessibility requirements. The information must describe the applicable requirements and, where relevant, cover how the service is designed and carried out. Besides the consumer information German civil law already requires, it includes at least, where applicable:

1. a general description of the service in an accessible format;
2. the descriptions and explanations needed to understand how the service is carried out;
3. a description of how the service meets the relevant requirements of the BFSGV;
4. the name of the competent market surveillance authority.

Under section 14(1) this information must itself be accessible, and under 14(2) the provider keeps it for as long as the service is offered. Our accessibility statement generator produces a structured draft you can adapt to Annex 3, and our accessibility statement guide explains each part. The authority to name for a shop in Germany is the MLBF, described next.

Who enforces the BFSG: the MLBF

The law leaves the market surveillance authority to state law (section 2, point 22). According to the Bavarian trade inspectorate, the states decided to found a joint body, the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF), a public-law institution based in Saxony-Anhalt that has been fully responsible for enforcement since September 26, 2025. In its own news release of June 1, 2026, the MLBF calls itself the joint authority of the 16 German states, says it began its nationwide work in September 2025, and says it was working through almost 700 reports it had received. The MLBF's own site gives its address in Magdeburg and offers two online forms: one to report a barrier and one to apply for action under section 32(1) of the BFSG. Its market surveillance strategies, adopted by its board on January 29, 2026, set priorities based on risk assessment, technological trends and consumer applications.

How a case can unfold under the law:

• Checks (section 28): the authority examines a service when it has reason to believe it does not meet the requirements, and it also checks services by random sampling without a specific reason, following the rules in Annex 1 for websites and apps.
• Applications (section 32): a consumer who cannot use a service, or can use it only in a limited way, can apply for proceedings, and so can a recognized disability association or a qualified consumer body. The authority decides by formal notice.
• Measures (section 29): the authority first sets a reasonable deadline for corrective action. If nothing happens, it repeats the demand with the threat of a ban, and it can then order the service to stop until conformity is shown.

Fines under section 37

Section 37 lists the administrative offenses, committed intentionally or negligently, and sets the maximum fine for each group. The ones most relevant to an online shop:

Section 37(2) also sets €100,000 as the maximum for the product offenses in points 1, 7, 9 and 10, such as placing a non-conforming product on the market. As of mid-2026 we have found no confirmed fine issued under any national EAA law, the BFSG included. The amounts above are maximums set in law, not typical outcomes.

Transition rules (section 38)

Section 38 contains three transitional allowances:

• Service providers may keep providing their services until June 27, 2030 using products they already lawfully used for those or similar services before June 28, 2025.
• Service contracts concluded before June 28, 2025 may continue unchanged until they expire, but no later than June 27, 2030.
• Self-service terminals in lawful use before June 28, 2025 may stay in use until the end of their economic life, but no longer than 15 years after they were first put into use. The directive allows up to 20.

None of these covers a website as such. A shop that was online before June 28, 2025 has no extra time because of its age.

Disproportionate burden (section 17)

Under section 17, the requirements apply only as far as they do not impose a disproportionate burden, judged against the criteria in Annex 4. A provider that relies on this must carry out and document the assessment, keep it for five years after last providing the service, repeat it at least every five years and whenever the service changes, and inform the authority without delay. A provider that receives outside public or private funding to improve accessibility cannot rely on it. The notification duty does not apply to microenterprises.

Public sector websites: BITV 2.0

The BFSG covers services for consumers. The electronic information and services of public bodies fall under a separate ordinance, the Barrierefreie-Informationstechnik-Verordnung (BITV 2.0), which requires them to be accessible and usable for people with disabilities (section 1(2)).

A practical BFSG plan for an online shop

1. Confirm you are in scope

   Check whether consumers buy from your site and whether you meet the microenterprise definition. Our which accessibility laws apply tool walks through it.

2. Find what is broken

   Our free scan runs 16 rule-based WCAG checks on the page you enter, such as a product page, and up to two more pages linked from it. The deep audit opens up to six images per page and checks whether each alt text describes what the image shows. Automated checks cover only part of WCAG, as our page on what automated testing can check explains.

3. Fix the source, then test manually

   Fix templates and components first, since one fix there reaches every product page. Then run a keyboard test through checkout and consider a full accessibility audit. An overlay widget does not change the underlying code; see what to use instead of an overlay.

4. Publish the Annex 3 information and keep records

   Publish the information in your terms or on a clearly linked page, name the MLBF, and keep a record of what you tested and fixed. If you rely on section 17, document the assessment.