European Accessibility Act (BFSG): What Online Shops Must Do in 2026
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2026
Law for Online Retailers
European Accessibility Act (BFSG)
What your online shop has had to implement since 2025

Since 28 June 2025, many online shops in Germany have been legally required to be accessible under the Barrierefreiheitsstaerkungsgesetz (BFSG), Germany's implementation of the European Accessibility Act. We explain in plain language what this means for your shop, who is really affected, and how to avoid fines and unnecessary trouble.

9 min read BFSG, accessibility, online shop in force since 28 Jun 2025

1. What is the BFSG and what is it about?

The Barrierefreiheitsstaerkungsgesetz, or BFSG for short, is Germany's national implementation of a European requirement, the European Accessibility Act, officially Directive (EU) 2019/882. The purpose of the law is to ensure that people with disabilities can use digital products and services just as easily as everyone else. That includes, for example, people with visual or hearing impairments, motor limitations, or cognitive impairments. Until now, many people associated accessibility mainly with public sector websites, which were already legally required to be accessible. The BFSG goes considerably further and, for the first time, also obliges private companies, explicitly including operators of online shops that sell goods or services to consumers.

In very practical terms, accessibility for your online shop means that the website must be built so that it can also be fully used with assistive technology such as screen readers, voice control, or keyboard only navigation. The internationally recognized benchmark is the WCAG 2.1 guideline at conformance level AA, which is referenced in Europe as the binding standard through the harmonized standard EN 301 549. This includes, among other things, alt text for images, sufficient color contrast, complete operability without a mouse, understandable form labels and error messages, and text that can be resized without losing content or functionality.

Beyond the pure website technology, the BFSG also requires that information about your products and services is presented in a perceivable way, and that the entire ordering process, meaning identification, payment, and authentication at checkout, works in an accessible manner. Your customer service, for instance contact forms or support chat, should also be designed to be accessible for people with disabilities.

2. Since when does the BFSG apply?

The BFSG is already in force: since 28 June 2025, the obligation to be accessible applies to all products and services covered by the law, including affected online shops. There is no general transition period left for websites. If you had not yet made your website accessible by that date, and your shop falls within the scope of the law, you are already outside the legal requirements right now.

There is an exception for existing hardware: self-service terminals that were acquired before the deadline may, under certain conditions, continue to be used for a longer period. These extended transition periods, however, concern physical devices such as checkout terminals, not the website or the online shop itself. For the digital sales channel, the obligation has applied from the deadline onward without exception.

3. Who is affected, does this apply to small shops too?

One of the most common worries among smaller shop owners is whether this even applies to them, or whether it is only relevant for large corporations. The clear answer: the BFSG fundamentally applies to all businesses that sell products or services online to consumers, meaning classic B2C e-commerce, regardless of company size. Other digital services such as online banking, e-books, or telecommunications are also covered by the law, but this article focuses on the online shop angle.

A genuine exemption exists only for so-called micro-enterprises: businesses with fewer than 10 employees and, at the same time, an annual turnover or balance sheet total under 2 million euros. Both criteria must be met together, not just one of them. If your business falls below this double threshold, it is exempt from most of the service-related obligations under the BFSG, which is a genuine relief for many small online retailers. Even so, it is worth taking a careful look: check thoroughly whether your business really meets both criteria, and whether any individual offerings you provide might still be covered despite your micro-enterprise status. Most small and medium sized online shops that employ more than 10 people or exceed the turnover threshold are affected by the BFSG.

4. Deadlines and thresholds at a glance

The following overview summarizes the most important deadlines, thresholds, and responsibilities around the BFSG, so you can see at a glance where your shop stands.

Criterion Rule What it means for your shop
In force since 28 June 2025 From this date, affected online shops must be accessible
Micro-enterprise exemption Fewer than 10 employees AND less than 2 million euros annual turnover or balance sheet total Both criteria must be met at the same time, otherwise the obligation applies
Existing self-service terminals Extended transition periods possible for devices acquired before the deadline Concerns physical hardware in store, not the website itself
Responsible authority Market surveillance authorities of the respective German federal states Can order inspections, demand corrections, and have non-compliant offers withdrawn from the market

One thing above all is important: the transition periods for hardware must not be confused with the situation for websites. For your online shop, the obligation has applied since the deadline, regardless of how long existing devices in a physical store may still be used on a transitional basis.

5. What you need to do concretely

Even though the topic may sound complex at first, in practice, accessibility for an online shop translates into a manageable number of concrete measures. Most of the requirements concern things that can be specifically implemented in the shop frontend, from the homepage through product pages to checkout.

The roadmap below shows the most important steps for making your shop accessible, step by step. Not every point applies equally to every shop, so an individual look at your website is always worthwhile before you start implementation.

Checklist: accessibility for your online shop in 7 steps

  • Add meaningful alt text to all images so screen readers can describe them correctly
  • Check color contrast between text and background and adjust it to WCAG compliant values
  • Make sure the entire shop can be operated using only the keyboard, without a mouse
  • Equip forms with clear labels, helper text, and understandable error messages
  • Make text resizable without losing content, navigation, or functionality
  • Design the checkout process, including identification, payment, and authentication, to be accessible
  • Offer contact and customer service channels that can also be used with assistive technology

6. Fines and risks of non-compliance

Compliance with the BFSG is not left to chance: the market surveillance authorities of the individual German federal states are responsible for enforcement. They can inspect online shops, demand corrections, and, in a serious case, even order that a non-accessible offer be withdrawn from the market until the deficiencies have been fixed.

For ongoing violations, significant fines may also be imposed, with the exact amount depending on the circumstances of the individual case. Besides the financial risk, you should not underestimate the reputational risk either: accessibility gaps are becoming increasingly visible in public, whether flagged by attentive customers, advocacy groups for people with disabilities, or even competitors who use a lack of accessibility as grounds for a complaint.

What can happen in a serious case

Market surveillance authorities can demand corrections, set deadlines, and, in repeated cases, impose fines that can be significant depending on the severity of the violation. On top of that comes the risk of negative public attention if accessibility gaps become known, which can damage trust in your shop more than the fine itself.

7. Common misconceptions

Misconception 1: This only applies to huge corporations. This assumption is false and dangerous for many shop owners, because in reality only genuine micro-enterprises below the double threshold of fewer than 10 employees and less than 2 million euros in turnover or balance sheet total are exempt. Most small and medium sized online shops already fall under the law.

Misconception 2: An accessibility statement or a corresponding badge on the website is enough. This is also not true: what is required is actual technical and content related accessibility, not merely a declaration of intent. A statement without genuine implementation does not protect against complaints.

Misconception 3: The BFSG only affects public sector websites. That was the situation before the BFSG, governed by the older BITV regulation or the EU directive for the public sector. The BFSG goes considerably further and explicitly includes private sector e-commerce as well.

Misconception 4: We will deal with it if someone complains. This wait and see approach is risky, because market surveillance authorities can also act on their own initiative without a specific complaint, and a complaint can trigger an official review at any time, often without prior warning.

8. What we can take care of for you

You do not have to deal with all these technical details on your own. We review your existing online shop as part of an accessibility audit and take a targeted look at your theme, your checkout, and your forms to identify concrete weak spots.

We then implement the necessary adjustments in the Hyva or Magento frontend, for example regarding color contrast, alt text, keyboard navigation, ARIA labelling for screen readers, and visible focus states. So that new content and pages do not silently reintroduce accessibility issues, we also offer ongoing monitoring of your shop.

Note: This article provides general information and does not replace individual legal advice.

9. Summary

The European Accessibility Act, implemented in Germany as the BFSG, has been in force since 28 June 2025 and also obliges operators of online shops to make their website accessible. Practically all shops that sell to consumers are affected, with genuine micro-enterprises below the double threshold of employee count and turnover or balance sheet total being the only exemption.

Concretely, this means for your shop: alt text for images, sufficient color contrast, full keyboard operability, understandable forms, resizable text, and an accessible checkout and customer service. Acting now not only helps you avoid possible fines and orders from market surveillance authorities, it also opens up an often overlooked target group for your shop: people who rely on accessible websites.

BFSG for online shops, the key facts at a glance

Since when

In force since 28 June 2025, no general transition period for websites

Who is affected

All online shops selling to consumers, except genuine micro-enterprises below the double threshold

What to do

Make the website technically accessible: contrast, alt text, keyboard, forms, checkout

Risk of inaction

Significant fines, restrictions by market surveillance, reputational damage

10. FAQ: European Accessibility Act (BFSG)

1What does BFSG mean?
BFSG stands for Barrierefreiheitsstaerkungsgesetz, Germany's implementation of the EU's European Accessibility Act.
2Since when does the BFSG apply to online shops?
Since 28 June 2025, with no general transition period for websites.
3Does the BFSG also apply to small online shops?
Yes, only genuine micro-enterprises below the double threshold are exempt from most obligations.
4What exactly is the micro-enterprise exemption?
Fewer than 10 employees and, at the same time, less than 2 million euros annual turnover or balance sheet total, both criteria together.
5What happens if my shop is not accessible?
Market surveillance authorities can demand corrections, withdraw offers from the market, and impose significant fines.
6Is an accessibility statement on my website enough?
No, real technical and content related accessibility is required, not just a statement.
7Does the BFSG only affect public sector websites?
No, the BFSG explicitly includes private online shops too, unlike the older BITV.
8What exactly needs to be accessible on my website?
Images, contrast, keyboard operability, forms, resizable text, plus checkout and customer service.
9How can I check whether my shop is accessible?
An audit against WCAG 2.1 level AA or EN 301 549 reveals concrete weak spots.
10Can Mironsoft make my shop accessible?
Yes, we take care of the audit, technical implementation in the Hyva frontend, and ongoing monitoring.