BFSG 2026: Does Your Business Website Have to Be Accessible?
The German Accessibility Strengthening Act (BFSG) has been in force since June 28, 2025. Ever since, two rumors have been going around: “This applies to every website” and “This doesn't apply to me anyway.” Both are wrong. Here is who is actually affected, which exemption applies, and what the requirements mean in practice.
What the BFSG is actually about
The BFSG transposes European Directive 2019/882, the European Accessibility Act, into German law. The basic idea: certain products and services should be usable by people with disabilities without help from others. That covers ATMs and e-book readers just as much as online shops.
The key point for businesses: the BFSG does not regulate “all websites” across the board. It lists specific products and services. One of them is electronic commerce, meaning services provided through a website or app that are aimed at concluding a contract with consumers.
Am I affected? Three questions
1. Can consumers complete a transaction with you online?
Ordering, booking, subscribing, entering into a contract. An online shop counts. So does an appointment booking that ends in a paid appointment. A plain contact form for sending a non-binding inquiry, as a rule, does not.
2. Are they consumers, or only business customers?
The BFSG protects consumers. Pure B2B, where only businesses can sign a contract, is not covered. In practice, the line is rarely that clean: if you don't explicitly and effectively limit your offer to business customers, you are in fact also selling to consumers.
3. Does the micro-enterprise exemption apply?
Service providers with fewer than 10 employees and no more than €2 million in annual turnover or annual balance sheet total are exempt from the requirements for services. Note: the exemption applies to services. There is no such exemption for products as defined by the law.
Yes to questions 1 and 2, no to question 3? Then you should look into this. And even if the exemption applies, it's worth a second thought (more on that below).
What is required technically
The benchmark is the European standard EN 301 549. For web content, it refers to the Web Content Accessibility Guidelines (WCAG) 2.1, conformance level AA. If you meet WCAG 2.1 AA, you generally meet the requirements for web content.
That sounds abstract. In practice, it's about things you can measure:
| Requirement | What it means in practice |
|---|---|
| Contrast | At least 4.5:1 for normal text, 3:1 for large text and controls. Light gray on white almost always fails. |
| Keyboard operation | Every function reachable without a mouse, in a logical order, with a visible focus. No trap you can't get back out of. |
| Alt text | Describe images that carry content. Explicitly mark purely decorative graphics as decorative so screen readers skip them. |
| Structure | Headings in the correct hierarchy, landmarks, form fields with real labels instead of placeholder text. |
| Zoom | Can be enlarged up to 200% without content getting lost or the page scrolling horizontally. |
| Error messages | Clearly worded, tied to the field, perceivable by screen readers. |
| Motion | Animations that start automatically respect the system setting for reduced motion. |
On top of that, there is a formal obligation that often gets overlooked: an accessibility statement that is easy to find and offers a way to report barriers. It also has to name what is not accessible yet. Honesty here isn't a weakness; it's part of the requirement.
What happens if you don't comply
Enforcement lies with the market surveillance authorities of the German states. They can order measures, demand corrections and, as a last resort, prohibit the service from being offered. The law provides for fines. Consumers and recognized associations can report violations.
Realistically, nobody is sending inspectors out across the board. The more likely path starts with a complaint from someone who couldn't get any further on your site. And complaints come up where people wanted to get something done and failed.
The underestimated part: it's not just about blindness
Accessibility is often equated with screen readers. In reality, far more people benefit: the 60-year-old who forgot their reading glasses. Someone looking at a phone in bright sunlight. Someone with one hand on a tool, using only the keyboard. Someone who temporarily can't click after an injury. Sufficient contrast and clean keyboard operation help a very large share of your visitors, not a fringe group.
What you can check yourself in an hour
Before anyone writes up a quote, it's worth taking stock. Four checks that require no expertise:
- Keyboard test. Put the mouse away. Use Tab to move through your homepage, your contact form, your checkout. Can you reach everything? Can you always see where you are? Do you get stuck anywhere?
- Zoom test. Set your browser to 200%. Does text disappear? Do elements overlap? Do you have to scroll sideways?
- Contrast test. Use a free contrast checker and measure your gray body text color against the background. Anything below 4.5:1 is a finding.
- Form test. Click on the label of an input field. Does the cursor jump into the field? If not, the connection between label and field is missing. That's a common flaw and easy to fix.
As a complement, automated testing tools like Lighthouse or axe find roughly a third of the typical problems. The rest only turns up when someone actually uses the site.
And if the exemption applies?
Many businesses along the Bergstraße and in the Rhine-Neckar region have fewer than ten employees and are therefore exempt as service providers. Still, here are three reasons to do it anyway:
- The threshold shifts. If you grow, you lose the exemption, and then the requirement lands on a website that has grown over the years instead of on a new build. Retrofitting costs more.
- Public tenders. If you supply public-sector clients, you'll run into accessibility anyway: the BITV applies there.
- It pays off for SEO. A clean heading hierarchy, meaningful alt text, clear structure: what helps screen readers also helps search engines. The effort is rarely wasted.
About our own site
We checked our own site against the same criteria and found more than we would have liked, including insufficient contrast on small labels and a control that could be reached by keyboard even though it was supposed to be invisible. What is still open, and by when we plan to fix it, is listed in our accessibility statement. We think that's a more honest approach than claiming perfection.
Frequently asked questions
Is an accessibility widget enough?
No. Overlay widgets sit on top of a page but don't change its structure. If a button has no label, it still has none with a widget. Tools like these can be useful as a supplement, but they don't work as proof of conformance.
Does this also apply to my online shop on a website builder platform?
Yes. Responsibility lies with whoever offers the service, not whoever built the software. Some builders provide a usable foundation, but the theme, content and customizations are up to you, and that's exactly where most barriers come from.
Do I have to rebuild my entire website?
Usually not. The focus is on the paths consumers use to complete a transaction: product page, cart, form, confirmation. A blog archive from 2018 has a different priority than the checkout.
What does it cost?
That depends on the current state of the site. A solidly built site often only needs fixes to contrast, focus styles and forms. A site that relies on page builder effects and uses images instead of text can take more work. You can only give a serious answer after an audit. Flat-rate prices quoted before anyone has looked at the code are a warning sign.
Where is this in the law?
The full text of the BFSG is available at gesetze-im-internet.de/bfsg. The technical requirements come from EN 301 549 and the WCAG. The Federal Accessibility Agency (Bundesfachstelle für Barrierefreiheit) offers advice and practical guidance.
The short version
- The BFSG has applied since June 28, 2025 and covers, among other things, electronic commerce with consumers.
- A purely informational website with no way to complete a transaction is generally not affected.
- Service providers with fewer than 10 employees and no more than €2 million are exempt for services, but not for products.
- The technical benchmark is EN 301 549, which for the web means WCAG 2.1 Level AA.
- An accessibility statement with a way to report barriers is part of the requirements.
- Overlay widgets don't replace an accessible website.
Not sure whether the BFSG applies to you?
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