Online shops & e-commerce
From the product catalogue through search to checkout — the entire buying process must be accessible.
In force since 28 June 2025
BFSG: what the law really requires of you.
Since 28 June 2025, many websites and online shops must be accessible. Here you’ll learn honestly whether you’re affected, what to do — and why an accessibility widget alone isn’t enough to be compliant.
Scope
Are you affected? In most cases: yes.
The BFSG requires private companies to make their consumer-facing digital products and services accessible. Online shops and booking websites count as “services in electronic commerce” — and clearly fall under the law.
Booking & appointment portals
Binding online appointment bookings and reservations also count as a covered service.
Banking & financial services
Consumer banking services are explicitly part of the law’s scope.
E-books & e-readers
Electronic books and reading devices that come to market after the deadline must be accessible.
Telecommunications
Telecommunications services and interactive consumer devices are covered as well.
Passenger transport & ticketing
Electronic tickets and self-service terminals in passenger transport fall under the requirements.
The microenterprise exemption — and its limits
For services, microenterprises are exempt from the BFSG: businesses with fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million. Both conditions must be met at the same time.
But beware: this exemption does not apply to products covered by the law, and not once one of the limits is exceeded. Purely business (B2B) offerings are exempt — but only if it’s clearly recognisable that you don’t sell to consumers.
Note: This page gives an understandable overview and is not legal advice. Whether the BFSG applies to your specific offering should, if in doubt, be checked with qualified legal advice.
Deadline & benchmark
28.06.2025
In force — since this date, covered offerings must meet the requirements.
WCAG 2.1 / 2.2
Technical standard (via EN 301 549) — conformance Level AA is the benchmark.
+ Statement
Duty to publish an accessibility statement — including a feedback mechanism for reporting barriers.
The BFSG is Germany’s implementation of EU Directive 2019/882 (European Accessibility Act); the technical benchmark behind it is EN 301 549 — and therefore the WCAG.
Consequences
The law has teeth.
Since September 2025, the market surveillance authority of the German states (MLBF) in Magdeburg monitors compliance. This isn’t about warning-letter panic — it’s about taking a clean, documented path.
Fines up to €100,000
For non-accessible provision or missing mandatory information, § 37 BFSG provides for fines of up to €100,000.
Official measures
Market surveillance can order the removal of defects and, in extreme cases, prohibit provision of the service.
Warning-letter risk
Violations can be subject to competition-law warnings — from competitors or recognised associations.
The honest part
Is an overlay widget enough? On its own: no.
An accessibility widget is a useful building block — but it doesn’t automatically make your website legally compliant. Here’s the honest difference.
What it doesn’t do
- It fixes no errors in the code: missing alt text, weak contrast, broken keyboard operation remain.
- It doesn’t replace real WCAG conformance — and on its own doesn’t protect against fines or warnings.
- It can even disrupt screen-reader users when it overrides the page instead of solving the causes.
What an overlay does
- Lowers barriers for many visitors — font size, contrast, read-aloud, operation aids.
- Gives your users control over the presentation — instantly and without programming.
- Helps make your efforts visible and document them.
It only becomes legally sound once the underlying issues are fixed. That’s exactly what a scanner is for — not for hiding things.
In 5 steps
How to become BFSG-compliant — verifiably.
Accessibility is not a one-off project but a process. Welcoma supports every one of these steps.
Check whether you’re affected
Clarify whether your offering falls under the BFSG — and which parts of your website are affected.
Scan your real status (coming soon)
The Welcoma scanner finds issues against WCAG 2.1/2.2, prioritises them by severity and points to the affected place in the code — so you see the real problem, not just a symptom.
Fix the issues
Work through the prioritised list — alt text, contrast, keyboard operation, structure. The on-screen menu additionally lowers barriers for your visitors.
Create your accessibility statement
The statement generator produces your statement to BFSG specifications — including a feedback mechanism for your users.
Monitor continuously (coming soon)
Keep an eye on your status and see, via usage analytics, which aids your visitors actually use.
FAQ
BFSG — briefly explained
Am I affected as a small online shop?
Probably yes. Online shops count as a service in electronic commerce. Only microenterprises with fewer than 10 employees and no more than €2 million in annual turnover or balance sheet are exempt — both conditions must be met at the same time, and the exemption applies only to services, not to covered products.
Is it enough to install an accessibility widget?
No. A widget lowers barriers and helps you document your efforts — but it fixes no underlying issues in the code. Your site only becomes legally sound once the actual WCAG violations are fixed. That’s what the scanner is for.
What does it cost if I do nothing?
For violations, the BFSG provides for fines of up to €100,000 (§ 37 BFSG). Market surveillance can also order measures and, in extreme cases, prohibit provision. On top of that comes the risk of competition-law warnings.
Do I need programming skills?
Not for setting up the widget and the statement — that runs via a dashboard. To fix the code issues found by the scanner you’ll need technical implementation depending on the findings; but the scanner shows you exactly where to start.
What goes into the accessibility statement?
It describes the state of accessibility of your offering, any remaining limitations and a feedback mechanism through which users can report barriers. The statement generator creates it for you to BFSG specifications.
From when does the law apply?
The BFSG has been in force since 28 June 2025. Covered products and services provided after this date must meet the requirements. There are transition periods for individual areas.
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