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No—the BFSG does not automatically apply to every website. It applies to specified products and services, including qualifying consumer e-commerce services. For many website owners, the key question is whether the site or app lets an individual consumer complete a transaction to conclude a consumer contract. The law took effect on 28 June 2025, so covered services are already subject to it.
Does the BFSG apply to my website?
The Barrierefreiheitsstärkungsgesetz (BFSG) is Germany’s implementation of the European Accessibility Act, Directive (EU) 2019/882. Its service rules cover listed categories, including consumer e-commerce, telecommunications, certain passenger-transport services, consumer banking, and e-books and their dedicated software. A website may be part of a covered service even if that service is not an online shop.
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. A corporate or informational website that does not provide such a service is not automatically covered merely because it belongs to a business. Conversely, assess the actual service and transaction path, not just the site’s label or homepage.
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The BFSG defines service providers by reference to offering consumer services on the Union market; it is not limited in its wording to businesses headquartered in Germany. How the law applies to a particular cross-border arrangement depends on its facts and should not be inferred from location alone. The statute entered into force on 28 June 2025; its scope includes enumerated consumer services provided after that date.
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What does the BFSG require from online shops?
The law’s broad outcome is that 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. BFSGV §12 requires relevant digital information, websites, associated online applications, and mobile services to be designed consistently and appropriately so they are perceptible, operable, understandable, and robust.
- Perceptible: Information and interface elements must be available to users through the senses they can use.
- Operable: Users must be able to navigate and operate the service, including its controls and forms.
- Understandable: Information, instructions, and interactions must be comprehensible.
- Robust: Content and controls must work reliably with the technologies people use to access them.
These are statutory characteristics, not a declaration that any particular checklist, plugin, or automated scan proves compliance. The cited legal material does not establish one conclusive WCAG version as the BFSG standard. The Federal Accessibility Agency publishes standards and conformity information, so check its current official material when selecting technical criteria.
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Review the full shopping and service journey
BFSGV §19 adds e-commerce-specific duties. Where the operator has accessibility information about products and services offered for sale, that information must be accessible. Service functions for identification, authentication, security, and payment must also meet the four accessibility characteristics. The same applies to identification and authentication methods, electronic signatures, and payment services where the service provides them.
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In practice, review more than the home page: product or service discovery, account creation and sign-in, forms, security checks, payment selection, confirmation, and any associated mobile experience. Where a service includes help desks, call centers, technical support, relay services, or training, BFSGV §12 also requires available support services to communicate accessibility and compatibility information through accessible means.
What information must a covered service publish?
Under BFSG §14, a covered service may be offered only if it meets the accessibility requirements and its provider has prepared the required information and made it publicly accessible. The provider must retain that information for as long as the service is offered and ensure continuing compliance.
Annex 3 says the information belongs in the provider’s terms and conditions or in another clearly perceptible place. It should explain the applicable accessibility requirements and, where relevant to assessing the service, its design and delivery. The listed content includes:
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- 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.
This information duty is separate from the duty to make the service accessible. A statement that describes accessibility does not, by itself, establish that the service meets the requirements; it should accurately describe the service and its compliance.
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Service-providing microenterprises are exempt from the general accessibility requirements in BFSG §3(1). The statutory definition is an enterprise with fewer than 10 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 a specific exemption for microenterprises offering or providing services, not a blanket exemption for every small company or every obligation relating to products. Businesses with mixed product and service activities, or uncertainty about whether they meet the definition, should assess those obligations separately and seek qualified legal advice where needed. The BFSG also provides for advisory support to microenterprises through the Federal Accessibility Agency.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Which content is excluded?
The BFSG contains exclusions for certain kinds of content, subject to conditions. They do not remove all duties from an otherwise covered service or exempt an entire website simply because it contains one excluded item.
- Recorded time-based media published before 28 June 2025.
- Office-application file formats published before 28 June 2025.
- 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.
- Archive content that has not been updated or revised after 28 June 2025.
Apply each condition to the specific content. For example, the third-party exclusion turns on the operator’s relationship to that content, while the archive exclusion concerns whether archived material has been updated or revised after the specified date.
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How should a website owner assess next steps?
- Identify the service. Determine what consumers can do through the website or app and whether it is a listed service, especially an electronic service offered at an individual request to conclude a consumer contract.
- Check exceptions carefully. Assess whether the service is provided by a qualifying microenterprise and whether particular content meets a specific exclusion. Do not treat a content exclusion as a site-wide exemption.
- Find the current technical criteria. Consult the Federal Accessibility Agency’s current standards and conformity information; the technical mapping should not be assumed from a WCAG version alone.
- Review the service end to end. Include the website, associated online applications, mobile services, support channels, and—where relevant—account, security, and checkout functions.
- Publish accurate accessibility information. Put the required information in terms and conditions or another clearly perceptible location, and retain it while offering the service.
- Maintain and reassess. Compliance is ongoing while the service is offered. Revisit accessibility when the service, its transaction flow, or relevant content changes.
The BFSG and BFSGV have been amended, and the BFSGV text reports an amendment dated 10 July 2026. Because the applicable technical standards and their mapping can change, verify the current official requirements before relying on a past assessment. These general points do not determine how the law applies to any particular business model.
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