The Barrierefreiheitsstärkungsgesetz (BFSG – Accessibility Strengthening Act) has required all companies offering products or services in electronic commerce to comply with digital accessibility according to WCAG 2.1 AA since June 28, 2025. Only micro-enterprises with fewer than 10 employees and less than 2 million euros in revenue in the services sector are exempt. Violations can result in fines of up to 100,000 euros and the prohibition of the online offering. Anyone operating an online shop, a booking system, or a digital service portal must act now.
Who Is Affected by the BFSG?
The BFSG applies to all companies offering products or services in electronic commerce, regardless of company size. Online shops, booking platforms, banking apps, e-book services, and interactive service portals clearly fall under the law. Only micro-enterprises with fewer than 10 employees and annual revenue under 2 million euros are exempt – but only in the services sector, not for products.
For SMEs in practice, this means: if you operate an online shop, offer online bookings, or provide digital services, you need to act. Pure corporate websites without transaction functionality are not directly affected at this time – however, the requirements are expected to be expanded in the medium term. Additionally, accessibility improves the user experience for all visitors, not just for people with disabilities.
What Technical Requirements Apply?
The technical standard behind the BFSG is WCAG 2.1 at conformance level AA (Web Content Accessibility Guidelines). These guidelines define four core principles: perceivability, operability, understandability, and robustness. For practical implementation on websites, this results in specific requirements.
- All content must be keyboard-operable (no mouse-only functions)
- Color contrasts must be at least 4.5:1 for normal text and 3:1 for large text
- Images need descriptive alt texts; decorative images require an empty alt attribute
- Forms must be properly labeled (label elements, error messages, required field indicators)
- Videos need subtitles; audio content needs a text version
- The page must remain fully usable at 200% zoom
- Time limits must be extendable or disableable
Semantic HTML and ARIA: The Technical Foundation
The foundation for accessible websites is semantic HTML. Screen readers and other assistive technologies can only correctly interpret content when the HTML structure reflects the meaning of elements. This means: headings as h1 through h6, navigation as nav, main content as main, lists as ul/ol – and buttons as button, not as styled div elements.
Where native HTML is insufficient, ARIA attributes come into play. ARIA attributes (Accessible Rich Internet Applications) supplement HTML elements with additional information for assistive technologies. A hamburger menu needs aria-expanded, a modal dialog needs role='dialog' and aria-modal='true', and dynamic status messages need aria-live='polite'. But be careful: incorrect ARIA is worse than no ARIA. The first rule of ARIA is: if you can use a native HTML element, do so.
What Penalties Apply for Non-Compliance?
The market surveillance authorities of the federal states are responsible for enforcing the BFSG. Violations can result in fines of up to 100,000 euros. Additionally, authorities can prohibit the provision of non-compliant products and services – in the worst case, an online shop or booking platform must go offline until the deficiencies are resolved.
Beyond the legal consequences, there is growing awareness among consumers and business partners. Companies that ignore accessibility exclude not only the estimated 7.9 million severely disabled people in Germany, but also older users with declining vision or motor skills – a demographic with significant purchasing power.
Practical Steps Toward an Accessible Website
Accessibility cannot be bolted on after the fact – it must be anchored in the architecture and development process. Start with an assessment: test your website with the NVDA screen reader (free), navigate through all functions using only the keyboard, and check your site with automated tools like axe DevTools or the WAVE Evaluator.
- Assessment: Automated tests (axe, WAVE) and manual testing (keyboard, screen reader)
- Ensure semantic HTML structure (no div soup)
- Check and adjust color contrasts (contrast checker tools)
- Test focus order: Tab navigation must be logical and visible
- Equip forms with labels, error messages, and required field indicators
- Use ARIA only where native HTML is insufficient
- Publish an accessibility statement (legally required)
Important: Automated tests only catch approximately 30 to 40 percent of barriers. A WAVE score of zero errors does not mean your website is accessible. Manual testing with real assistive technologies is indispensable.
Conclusion: Accessibility as a Quality Standard
The BFSG is not a bureaucratic obstacle, but a quality standard. Accessible websites are better structured, more performant, and more pleasant to use for all visitors. They tend to rank better on Google because semantic HTML and good page structure are also SEO signals. And they reach a larger audience.
Those who act now not only avoid fines but invest in a future-proof website. The fundamentals – semantic HTML, keyboard navigation, sufficient contrasts, and correct ARIA usage – are not rocket science. They require diligence in development and an awareness that a website must work for all people.
