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BFSG: what online shops must do now – a six-step plan

· 5 min read

Germany's Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) has applied to online shops since 28 June 2025. If you sell to consumers and are not a micro-enterprise, you should do six things now: check whether the law applies to you, test your shop, fix the most important barriers in the checkout and forms, test manually, publish an accessibility statement and re-check the shop regularly. This article shows what that looks like in practice – without scaremongering and without legal advice.

Where things stand in autumn 2026

The deadline is more than a year behind us. The federal states' market surveillance authority (MLBF) in Magdeburg has been operating since September 2025. As of October 2026 we are not aware of any confirmed fines against online shops. At the same time, other countries show that inspections do take place: the Czech Trade Inspection Authority, for example, inspected 47 online shops in the second quarter of 2026 and found violations at 10 of them. In Germany there is also the risk of cease-and-desist letters under competition law (Abmahnungen).

The realistic assessment: no reason to panic, but no reason to keep postponing the topic either. Every relaunch, every new theme and every new campaign page is an opportunity to avoid creating barriers in the first place.

Step 1: Check whether the BFSG applies to you

Three questions are enough for a first assessment:

  1. Do you sell to consumers? Pure B2B shops are assessed differently.
  2. Is your offer part of e-commerce or another covered area? For online shops the answer is almost always yes.
  3. Are you not a micro-enterprise? Businesses with fewer than 10 employees whose annual turnover or annual balance sheet total is no more than €2 million are exempt.

The third question is tricky. A shop with four employees, €3 million turnover and a balance sheet total of €400,000 is still a micro-enterprise – because with fewer than 10 employees, both turnover and balance sheet total would have to exceed €2 million. More examples are in the guide Who is affected?.

If you are not affected, the BFSG imposes no obligation on you. An accessible shop is still a better shop.

Step 2: Test the shop

Start with an automated check against WCAG 2.2 AA. It quickly finds the errors that can be detected technically: missing alternative text, insufficient contrast, form fields without labels, icon buttons without names, a missing language declaration.

Don't just pick the home page – choose the pages where customers get things done:

  • a typical category page with filters,
  • a product page with variants,
  • the shopping cart,
  • the checkout up to the choice of payment method,
  • registration, login and customer account,
  • the contact form.

You can test one page with our free check. Important: an automated check is not a full audit. It finds only some of the possible barriers. What it does not find is described in our article on automated vs manual testing.

Step 3: Set priorities

Not every error is equally serious. We recommend this order:

  1. Anything that prevents a purchase. A required field without a label in the checkout, a payment button without an accessible name, a cookie banner that cannot be closed with the keyboard.
  2. Navigation and search. A menu that only opens with a mouse locks keyboard users out of the entire range.
  3. Product information. Alternative text for product images, readable prices and variants, understandable size charts.
  4. Everything else, such as the blog, magazine or about page.

Many errors often sit in a few templates. A corrected product template fixes the error on thousands of product pages at once. That is why it pays to sort errors by template rather than by page.

Step 4: Test manually

Plan a manual test of the most important flows – for example once a quarter and after every major update:

  • Using only the keyboard, search for a product, add it to the cart and go through to the choice of payment method. Is the focus always visible? Do you get stuck anywhere?
  • At 200% zoom, repeat the same steps.
  • On a smartphone, check that buttons are large enough and nothing is covered.
  • With a screen reader – such as NVDA on Windows or VoiceOver on Mac and iPhone – go through the checkout.

If nobody on the team has experience with this, a manual test by specialists is worthwhile. The WCAG 2.2 criteria to watch are summarised in our WCAG 2.2 checklist.

Step 5: Publish the accessibility statement

§ 14 BFSG requires information on how your service meets the accessibility requirements – in your terms and conditions (AGB) or in another clearly perceivable way, and itself accessible. Annex 3 (Anlage 3) describes the content. In practice, most shops publish a separate "Barrierefreiheitserklärung" (accessibility statement) page linked in the footer.

Three tips:

  • Describe your shop, not just any shop. Copied templates help little.
  • Be honest about what has already been done and what has not. A section on known limitations with a plan is better than claiming everything is done.
  • Name a contact for feedback and the competent authority.

Structure and typical mistakes are explained in the accessibility statement guide. Agree the text with your legal adviser.

Step 6: Keep at it

Accessibility is not a project with an end date. A new theme, a plugin update, a new landing page or a changed cookie banner can introduce new barriers. So:

  • check automatically on a regular basis, for example weekly,
  • react to new errors immediately, while the change is still fresh,
  • update the statement when something significant changes,
  • take feedback seriously: anyone who reports a barrier is helping you.

What you should not do

  • Use an overlay as the solution. A widget does not change the code. Our article why overlays don't work explains why.
  • Claim to be "fully accessible" without having tested it.
  • Delegate the topic to a single person who also does everything else on the side. Accessibility concerns design, development, content and customer service.

How we help

We check your shop automatically against WCAG 2.2 AA, explain every problem in plain language with instructions for Shopify, WooCommerce, PrestaShop and Shoptet, monitor the shop weekly and, based on a questionnaire, create a draft accessibility statement for your legal adviser. This is an automated check, not a full audit, and not legal advice – but a solid plan for the next steps.

The legal framework is summarised in our BFSG guide.

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