Accessibility: what the BFSG means for your website

What does the BFSG regulate for websites?

Germany’s Barrierefreiheitsstärkungsgesetz (BFSG) implements EU Directive 2019/882. It aims to make certain consumer products and services accessible. For websites, the law becomes relevant when digital services are offered to consumers after 28 June 2025.

The BFSG does not simply say that every company homepage must be perfect. It looks at specific services, including electronic commerce and certain banking, telecommunications, transport and media services. For many small companies the key question is: can consumers buy, book, conclude contracts or use a digital service through the website?

Which businesses are affected by accessibility duties?

Businesses can be affected when they offer products or services within the BFSG scope to consumers. Typical website cases include online shops, booking flows, customer portals, digital contract processes or other e-commerce functions. A simple brochure website is different from a shop with cart and checkout.

There is an important exception for micro-enterprises in services. This usually means fewer than 10 employees and no more than 2 million euros in annual turnover or annual balance sheet total. It is not a free pass for poor usability, but it can matter legally.

• Relevant date: 28 June 2025
• Check especially: shop, online booking, login, contract flow and consumer digital services
• Micro-enterprises may be exempt for services
• If unsure, seek legal or data protection advice

What does accessible mean technically?

Accessibility does not make a website complicated or ugly. It means people can perceive, operate and understand it — also with screen readers, keyboard navigation, zoom, colour vision limitations or motor impairments. Many checks use WCAG principles: clear structure, sufficient contrast, usable forms, visible focus, understandable errors and robust HTML.

For small businesses, the most important points are practical: the contact button must be reachable by keyboard, fields need visible labels, meaningful images need alt text, PDF menus should not be the only source of information and text must remain readable on mobile.

Which website functions should SMEs check first?

Start where customers spend money or contact you. An unusable checkout, blocking cookie banner or confusing booking form is more critical than a decorative image without alt text. Test the real customer path: open the Google result, understand the offer, find price or appointment, send an enquiry and receive confirmation.

Third-party tools are often critical. Booking systems, review widgets, maps, payment providers and embedded forms must also be usable and integrated cleanly. If an external component blocks keyboard use, the problem still appears on your website.

• Navigation and mobile menus
• Contact forms, booking and checkout
• Cookie banners and consent tools
• PDFs, price lists, menus and downloads
• External map, review, payment or booking widgets

What happens if an affected website is not accessible?

The BFSG provides for market surveillance by authorities. Service providers must meet accessibility requirements and provide information in accessible form. Violations can lead to corrective measures, restrictions and fines. Section 37 BFSG contains fine provisions; depending on the case, fines of up to 100,000 euros can be possible.

For most small companies, the practical damage is also important: complaints, poor user experience, lost enquiries and rushed fixes cost money. A calm check is better: am I affected, which core processes are critical, and what can be fixed with reasonable effort?

How can you approach a BFSG check pragmatically?

First list your functions: sell, book, pay, log in, download, contact. Mark which ones are aimed at consumers and which third-party tools are involved. Then run practical tests: contrast, Tab navigation, form submission, error messages, alt text and PDF alternatives.

For a new website, accessibility should be included in concept, design and build. Retrofitting is often more expensive, especially with old WordPress themes or restrictive builders. In a website subscription, accessible structure, mobile usability and clear forms should be part of the foundation.

When is a relaunch better than small fixes?

Individual issues can often be corrected quickly: improve colours, restore visible focus, add labels and make button text clearer. If the website is technically outdated, based on old layouts or uses components that cannot be made accessible, patchwork becomes expensive.

The decision should be based on effort and benefit, not fear. A more accessible website helps older customers, mobile users, search engines and your own team. If you plan new services, online booking or shop functions anyway, treat accessibility as a baseline requirement now.