German Accessibility Act: what the BFSG asks of a foreign online shop

The German Accessibility Act, in German the Barrierefreiheitsstärkungsgesetz or BFSG, has required since 28 June 2025 that online shops and other e-commerce services sold to consumers in Germany can be used by people with disabilities. It applies to any business that sells to German consumers, wherever it is based, unless it is a micro-enterprise providing a service: fewer than ten employees and no more than 2 million euros in annual turnover or balance sheet total.

The BFSG is Germany's version of the EU's European Accessibility Act, Directive (EU) 2019/882. It was adopted on 22 July 2021, with a regulation, the BFSGV, that sets out the detailed requirements. The rules are the same directive as in Belgium or France; the way Germany enforces them is not. This guide is for a shop or booking site outside Germany with German customers: what is covered, what compliance means in practice, who checks it, what it costs to get wrong, and what to do first.

Who the BFSG covers

The law covers certain products, such as computers, smartphones, e-readers and self-service terminals, and certain services provided to consumers. For most websites, the service that matters is e-commerce: any service provided at a distance, by electronic means, at the request of a consumer, with a view to concluding a consumer contract.

Two points catch foreign sellers. First, the micro-enterprise exemption is not the same in every EU country: Germany exempts service micro-enterprises, Belgium decided to cover them with a later start date. Check each country you sell into. Second, being outside the EU does not help: a UK or US shop that sells to consumers in Germany is in scope for those sales; see UK website accessibility law and ADA website compliance for the rules at home.

What compliance means for a shop

The BFSG and the BFSGV require that services be perceivable, operable, understandable and robust, the four principles of the Web Content Accessibility Guidelines. The harmonised European standard EN 301 549 translates them into testable criteria for websites, and for websites those criteria are WCAG 2.1 level AA. In practice, an e-commerce service meets the BFSG when:

• every step of the purchase, from search to payment and the order confirmation, works with a keyboard and a screen reader;
• images that carry information have text alternatives, and text has enough contrast and stays usable when enlarged;
• forms have labels and clear error messages, and nothing depends on colour, a time limit or an image CAPTCHA alone;
• identification, authentication and payment methods are accessible too, which includes the payment provider's pages you send customers to;
• information about the service and how it meets the requirements is available, in an accessible format.

That last point is the BFSG's version of an accessibility statement: you publish, in your terms and conditions or in another clearly findable place, a description of the service and how it meets the accessibility requirements. Our accessibility statement template has an EU version that covers it, to adapt into German for German customers.

Who checks it, and what it costs to get wrong

Market surveillance is a matter for the German states, which set up one joint authority for it: the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF), based in Magdeburg. It can check services on its own initiative or after a complaint, ask a business to bring a service into conformity within a deadline, and as a last resort order a service to stop being offered.

Fines are set in section 37 of the BFSG: up to 100,000 euros for the most serious breaches, such as offering a service that does not meet the requirements, and up to 10,000 euros for others. For many businesses the larger risk is not the fine but an order to stop offering the service in Germany until it complies.

Then there is the German specialty: the Abmahnung, a formal warning letter with costs attached. Competitors and qualified associations can treat a breach of consumer protection rules as unfair competition and send one, demanding that you stop and sign a declaration with a penalty clause. The same culture produced the wave of letters over Google Fonts; see are Google Fonts GDPR compliant. Whether accessibility breaches will become a regular target for such letters is still being tested in the courts; a shop that sells in Germany should not wait to find out.

Transition periods

A plan for a shop that already sells in Germany

1. Check whether you are in scope. Consumers in Germany, an e-commerce service, and not a service micro-enterprise: then you are.
2. Test the path to the order. Search, product, basket, checkout and payment, with a keyboard only and with a screen reader, in German. Note every point where you get stuck.
3. Fix templates before content. One fix in a product card template reaches every product; then add alt text and accessible product information.
4. Talk to your payment provider and your banner vendor. Their screens are part of your service under the law.
5. Publish the accessibility information. In your terms or on a page linked from every page, in German.
6. Keep it up. Every theme update, plugin and campaign page can break it again; test before each release.

The BFSG is one of several German rules a foreign shop meets. The others, from the legal notice to the withdrawal button and packaging registration, are in selling online in Germany, and the legal notice itself in Impressum requirements.