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Outbyte Driver Updater FREEScan for outdated or missing drivers - takes under a minuteDriver Scan →Outbyte PC Repair FREERepair Windows errors before they cause bigger problemsFix Now →The BFSG does not automatically apply to every website. It applies to listed products and services, including qualifying consumer e-commerce services, unless an exemption or a specific content exclusion applies. Germany’s Barrierefreiheitsstärkungsgesetz (BFSG), which implements the European Accessibility Act (EAA), took effect on 28 June 2025. For many website owners, the key question is whether their site or app helps a consumer conclude a contract online.
Does the BFSG apply to my website?
Start with the service the site provides, not simply the fact that it is a website or that its operator is based in Germany. The BFSG covers specified product and service categories. Its service list includes consumer e-commerce, as well as telecommunications, certain passenger-transport services, consumer banking, e-books and dedicated software, among others.
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For e-commerce, the statutory definition focuses on a digital service offered through a website or mobile application, provided electronically at an individual consumer’s request, with a view to concluding a consumer contract. An online shop that lets consumers select goods and place orders is a clear example of the kind of service to assess. A company site that only provides general information is not automatically covered as e-commerce just because it belongs to a business; consider whether it offers a qualifying service or is part of another service category in the law.
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A free scan shows the junk files, broken settings and background clutter dragging Windows down - then fixes them in one click.Free scan · Windows 10 & 11The law concerns services offered on the Union market, so a business should not assume that being headquartered outside Germany alone settles whether the BFSG applies. The result for cross-border operations depends on the particular facts. The BFSG also covers specified products placed on the market after 28 June 2025, but this article focuses on website and service obligations.
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A practical scope check
- Identify what consumers can do. Map the website and mobile app functions, including product discovery, account creation, booking, ordering, and payment.
- Ask whether a consumer can conclude a contract. Determine whether the digital service is provided electronically at an individual consumer’s request for that purpose.
- Check for another listed service. A site may form part of a covered service even if it is not an online shop.
- Check applicable exceptions. Assess the service-provider microenterprise exemption and any content-specific exclusion separately; neither should be treated as a blanket exemption without checking its conditions.
The statute took effect on 28 June 2025, and its service requirements apply to covered services provided after that date. The official BFSG was amended by a regulation dated 10 July 2026, so operators should check the current statutory text and official standards information when assessing their obligations.
What does the BFSG require from online shops?
The BFSG sets the accessibility outcome: people with disabilities should be able to find, access, and use covered services in the generally customary manner, without particular difficulty and generally without outside help. The implementing regulation, the BFSGV, requires covered digital information necessary to provide the service, websites, associated online applications, and mobile services to be designed consistently and appropriately so they are perceptible, operable, understandable, and robust.
- Perceptible: users can perceive the information and interface through the means available to them.
- Operable: users can navigate and operate the service.
- Understandable: information and operation can be understood.
- Robust: the service works reliably with relevant user agents and assistive technologies.
For e-commerce, BFSGV §19 makes the transaction path especially important. Where the service provides them, identification, authentication, security, and payment functions must meet the same four characteristics. The requirements also extend to identification methods, authentication methods, electronic signatures, and payment services where provided. Accessibility review should therefore include account and checkout flows, not just the home page.
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Repair Windows errors before they cause bigger problemsFix Now →Scan for outdated or missing drivers - takes under a minuteDriver Scan →Where the responsible operator has accessibility information about products or services offered for sale, the e-commerce service must make that information accessible. The regulation also addresses support services, such as help desks, call centers, technical support, relay services, and training: available support must communicate information about accessibility and compatibility through accessible means.
The legal material described here does not establish one specific WCAG version as conclusively mandated for every BFSG service. The regulation points to standards information and conformity tables published by the Federal Accessibility Agency. Check that agency’s current official material when selecting technical criteria; do not assume a particular version based on the BFSG alone.
What is the BFSG accessibility information duty?
A covered provider must prepare information about how its service meets the applicable accessibility requirements and make that information publicly accessible. The provider must retain it for as long as the service is offered and maintain compliance while offering the service. This is a separate obligation from making the service itself accessible: a published statement does not cure an inaccessible site or checkout.
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The information should appear in the provider’s terms and conditions or in another clearly perceptible place. The statutory information elements include:
- a general description of the service in an accessible format;
- explanations needed to understand how the service operates;
- an explanation of how relevant accessibility requirements are met; and
- the competent market-surveillance authority.
The description should address applicable requirements and, where relevant to assessing compliance, the service’s design and delivery. Keep it accurate as the service changes; generic claims unsupported by the actual user experience can mislead rather than inform.
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Are small businesses exempt from the BFSG?
The BFSG provides a specific exemption for microenterprises that offer or provide services: the general accessibility requirements in §3(1) do not apply to them. A microenterprise has fewer than ten employees and either annual turnover of no more than €2 million or an annual balance-sheet total of no more than €2 million.
This is not a universal small-business exemption. It is framed for microenterprises providing services and does not by itself remove obligations relating to products or establish that every business below a general notion of “small” qualifies. Businesses with mixed product and service activity, or uncertainty about employee counts and financial thresholds, should obtain advice on their specific classification. The law also provides for advisory support to microenterprises through the Federal Accessibility Agency.
Which content is excluded, and under what conditions?
The BFSG contains exclusions for particular content, but these are conditional and do not automatically exempt an otherwise covered website or service. The listed categories include:
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- recorded time-based media published before 28 June 2025;
- office-application file formats published before that date;
- online maps and map services, provided essential navigation information is available in accessible digital form;
- third-party content that the relevant operator neither finances nor develops nor controls; and
- archive content that has not been updated or revised after 28 June 2025.
Apply each condition to the particular content. For example, the third-party content exclusion turns on the operator’s relationship to that content; it is not a general shield for all externally supplied material on a site.
Quick Recap
How should a website owner act now?
- Document the service and transaction path. Identify the consumer-facing service, the contractual steps, and the web, mobile, account, support, and payment functions involved.
- Determine scope and exceptions. Assess the statutory service definition, relevant microenterprise status, and any content exclusion on its own conditions. Get qualified legal advice where the business model or cross-border facts make the answer uncertain.
- Check current official technical material. Consult the Federal Accessibility Agency’s current standards and conformity information rather than assuming a particular technical standard version.
- Review actual use, including checkout. Examine whether users can perceive and operate the service and understand its content, and whether it works robustly. Automated scans or interface add-ons may support assessment, but do not by themselves establish compliance.
- Publish accurate accessibility information. Put it in terms and conditions or another clearly perceptible location, cover the relevant statutory information, and retain it while the service is offered.
- Reassess when the service changes. New account, payment, product, or support functions can affect both accessibility and the accuracy of published information; the provider’s duties continue for the period the service is offered.
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