Since 28 June 2025, Germany's Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) has applied. It requires companies to make digital offers for consumers accessible, above all online shops, booking and appointment systems, banking and ticketing. In 2026 it is getting serious: the federal states' market surveillance authority adopted its inspection strategy in January, and a second wave of warning letters has been reported since February. A pure business-card website without ordering or booking functions generally does not fall under the act.
Which websites are affected?
The BFSG applies to certain products and services aimed at consumers. For websites, this mainly means services in electronic commerce:
- online shops
- booking and appointment systems
- banking and ticketing
Generally not affected are:
- pure information or business-card websites without contracts being concluded
- offers aimed exclusively at businesses
- micro-enterprises with fewer than ten employees and annual turnover of no more than two million euros, if they provide services
Experts disagree on whether a micro-enterprise's online shop falls under the exemption. It does not apply to products, such as selling hardware.
What is required?
The website must be perceivable, operable, understandable and robust. In practice, implementation follows the WCAG 2.1 standard at level AA. Typical points:
- sufficient contrast between text and background
- full keyboard operation, with a visible focus
- alternative text for images that carry content
- understandable forms with labels and error messages
- a clean structure with headings so that screen readers can read the page aloud
- an accessibility statement describing how accessible the offer is
Who checks, and what are the consequences?
The responsible body is the federal states' joint market surveillance authority for accessibility (MLBF) in Magdeburg, since 26 September 2025. It sets priorities and does not check every website. Breaches can lead to fines of up to 100,000 euros, lower amounts for missing information such as the accessibility statement, and an offer can be prohibited.
On top of that come warning letters. Whether competitors may pursue BFSG breaches under competition law has not yet been settled by the courts. You should therefore always have a warning letter checked by a specialist lawyer before paying or signing anything.
Is an accessibility plugin enough?
So-called overlay tools place a toolbar with font size, contrast and read-aloud functions over the website. They do not replace a real implementation, because they do not fix the actual problems in the code, such as missing labels or a page that cannot be operated by keyboard.
How to proceed
- Clarify whether your offer falls under the BFSG.
- Have the website reviewed, automatically and manually, including with a keyboard and screen reader.
- Fix the problems in the code and the content.
- Publish an accessibility statement.
- Check new content and features as you add them.
This article is not legal advice. For your specific case, contact your legal advisor.
Sources
- axes4: BFSG in practice: what has happened since the deadline (German)
- KMU-Digitalcheck: BFSG 2026 for SMEs (German)
- Plakart: Accessibility statement and BFSG: what matters in 2026 (German)
- D!E mit Ausrufezeichen: Two waves of warning letters under way (German)
