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The European Accessibility Act for German online shops: what the BFSG requires

Updated October 28, 2026. By All the Possibles.

Germany wrote the European Accessibility Act into its own statute, with numbered sections and numbered fines. That makes the German picture clearer than most, so this page quotes the sections and ends with a free check of your shop.

The law in Germany

Directive (EU) 2019/882 became the Barrierefreiheitsstärkungsgesetz (BFSG), with technical detail in the Verordnung zum Barrierefreiheitsstärkungsgesetz (BFSGV). The duties apply from 28 June 2025. § 1 sets the scope, which includes services in electronic commerce provided to consumers, so a shop that sells to private customers in Germany is in. There is no general grace period for the shop itself. The transition in the law covers service contracts concluded before 28 June 2025, which may run unchanged until 27 June 2030 at the latest, and products a provider was already lawfully using.

Who is exempt, in the words of § 3

§ 3(1) says products and services that an economic operator places on the market or provides must be accessible. § 3(3) says that § 3(1) "gilt nicht für Kleinstunternehmen, die Dienstleistungen anbieten oder erbringen": the duty does not apply to microenterprises that offer or provide services. A microenterprise has fewer than 10 employees and no more than EUR 2 million in annual turnover or balance sheet total. Two things follow. First, the exemption is about services, so a microenterprise that places covered products on the market, such as e-readers, routers or payment terminals, still has product duties. Second, the exemption is something you may need to show. Keep the headcount and the turnover figure on file with a date.

The disproportionate burden route from Article 14 of the Directive exists in the German law too, with a documented assessment. Money received to improve accessibility closes it.

Who checks

Market surveillance for the BFSG sits with the Länder, which set up a joint body, the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen, hosted in Saxony-Anhalt. Trade sources report that it began checks in autumn 2025, including automated tests of websites. I have not confirmed the start date against an official notice, so treat it as reported. The authority can require corrective measures and can prohibit a service until conformity is shown.

The fines in § 37

§ 37(1) BFSG lists the administrative offences. Offering or providing a service that does not meet the requirements of § 14(1) can be fined up to EUR 100,000, as can placing or making available a non-compliant product. Missing, incorrect, incomplete or late information, which includes the accessibility information a service provider must give under § 14(4), carries up to EUR 10,000. The amounts are ceilings, and the first instrument in practice is an order to fix the problem, but the ceiling on the service offence is the number to remember.

What a German shop has to publish

§ 14 obliges a service provider to make the required information available in its general terms and conditions or in another clearly accessible way, explaining how the service meets the accessibility requirements. In practice that is a page in German, linked from the footer and the AGB, that says what the shop does for accessibility, which standard it follows, what is not yet accessible and why, and how to report a barrier. The technical benchmark everyone uses is EN 301 549, which draws on WCAG; the BFSGV points to harmonised standards rather than naming a WCAG version, so confirm the current citation before you claim a specific version.

What to fix first

  1. Checkout and account sign-in by keyboard only, from product page to order confirmation. This is the failure that turns into a complaint.
  2. Accessible names on icon buttons and image links: cart, search, menu toggle, product thumbnails, the payment method radios.
  3. Labels and error messages on the address, shipping and payment forms, and a focus move to the first error.
  4. Page language set to de, document titles per page, a skip link, a single h1.
  5. Contrast on prices, sale badges, buttons and placeholder text, and target size on mobile.
  6. Alt text on product images that names the product, and empty alt on decoration.
  7. The accessibility information under § 14, in German, dated, with a contact route that someone answers.

Run the free check below on your busiest product page, then on checkout. The Designers page audit runs the same check inside an agent session, and the Accessibility Readiness Report covers up to ten pages for $149 once, with a fix list in order and a draft of the § 14 information for your terms.

Free check of one page, about a minute

We read the page the way a crawler does, name each problem with its WCAG clause, and email you a link to the result. An automated draft, not legal advice.

One page, one check per site every 7 days, link live for 30 days. The full report covers up to ten pages and costs $149 once.

Sources

This is a reading of public texts by a tool builder, not legal advice.

Questions people ask

Does the BFSG apply to my online shop?

If you sell products or covered services to consumers in Germany through a website or app, the Barrierefreiheitsstärkungsgesetz has applied to that shop since 28 June 2025. E-commerce services to consumers are in scope. Shops that sell only to businesses are outside the consumer rules, but check that reading with a lawyer before relying on it.

Is a small shop exempt from the BFSG?

§ 3(3) BFSG says the accessibility duty in § 3(1) does not apply to microenterprises that offer or provide services. A microenterprise has fewer than 10 employees and annual turnover or balance sheet total of no more than EUR 2 million. The exemption is for services. If the shop places covered products on the market, those products are still covered. Document how you qualify, because the surveillance authority can ask.

What are the fines under the BFSG?

§ 37 BFSG sets fines of up to EUR 100,000 for, among other things, offering or providing a service that does not meet the requirements, and up to EUR 10,000 for missing, incorrect or late information. The authority can also order corrective measures.