Accessible websites under the German BFSG: what SMEs need to know in 2026
Since 28 June 2025, digital services for consumers in Germany have to be accessible. Who the BFSG binds, where the micro-enterprise exemption ends and what WCAG 2.1 Level AA actually requires.
The duty to run an accessible website is the requirement under Germany's Barrierefreiheitsstärkungsgesetz (BFSG, the Accessibility Strengthening Act) to offer digital consumer services that people with disabilities can use without outside help. It has applied since 28 June 2025 – but not to every company. It covers online shops, booking flows, customer portals and banking. A brochure website with no contract conclusion, and an offering aimed only at business customers, fall outside it. What matters is not whether you have a website, but what consumers can do on it.
The key points at a glance
- The duty covers consumer services, not every company website: shop, booking and customer accounts yes, pure information and B2B no.
- The micro-enterprise exemption – under ten employees and at most €2 million in turnover or balance sheet total – covers services only, not products.
- The technical benchmark is the European standard EN 301 549, which refers to WCAG 2.1 Level AA for web content.
- The transition period to 27 June 2030 extends no website deadline: it covers products already in use and legacy contracts.
- Section 37 BFSG sets two penalty ranges: up to €10,000 as a rule, up to €100,000 for listed breaches.
- As of 2026 the federal states' market surveillance body is operational, acting on complaints and random checks.
Who has had to run an accessible website since June 2025?
The duty binds economic operators offering services to consumers electronically, whatever the industry. Section 3 BFSG deliberately keeps the benchmark broad: products and services are accessible when people with disabilities can find, reach and use them in the customary way, without particular difficulty and in principle unaided. The technical requirements sit in the BFSG implementing regulation, in force since 28 June 2025.
In practice one question gets you most of the way: can a private individual initiate or conclude a contract on your website? If so, your offering is a service within the meaning of the act. The table sorts the common cases; borderline situations need legal advice. Mixed offerings are judged by the part concerned: run a shop for private customers alongside a trade area, and the consumer side has to be accessible while a closed dealer portal does not.
| Your online offering | Covered by the BFSG | Reason |
|---|---|---|
| Online shop for private customers | Yes | Service in electronic commerce |
| Appointment or booking flow for private customers | Yes | Contract is initiated online |
| Customer portal with login | Yes | Service is delivered online |
| Information page with phone number and directions | No | No contract concluded through the page |
| Offering aimed exclusively at business customers | No | No consumer relationship |
When does the BFSG exempt micro-enterprises from the duty?
The exemption applies to services only, because the act releases micro-enterprises from the requirements in that area alone (Section 3(3) BFSG). A micro-enterprise is an establishment with fewer than ten employees that also reaches no more than €2 million in annual turnover or balance sheet total. Anyone manufacturing, importing or distributing a product covered by the act stays bound – company size changes nothing there. That distinction gets lost in many guides.
Two points are routinely overlooked. First, the classification is a snapshot, not a permanent state: grow past the threshold and the duty applies with no grace period, so record your assessment in writing and with a date. Second, the exemption releases you from the law, not from the market. Public sector clients and larger business customers require accessibility by contract, and search engines read the same signals a screen reader needs: clean heading hierarchy, meaningful link text, text alternatives. Fixing those properly also means working on the fundamentals of search engine optimisation.
Does the transition period until 2030 also apply to your website?
The transition period extends no deadline for your website. Section 38 BFSG permits two narrow things: service providers may keep using products lawfully deployed before 28 June 2025 until 27 June 2030, and contracts concluded before 28 June 2025 may run on unchanged until they expire, at the latest until 27 June 2030. Self-service terminals have their own limit of 15 years from commissioning.
For a front end this means an online shop that cannot be operated today is not compliant today – not from 2030. The period helps where hardware or running contracts are involved. Relying on it defers no obligation, only the invoice, and a relaunch under time pressure costs more than a planned retrofit.
What does WCAG 2.1 Level AA actually require of a company website?
WCAG 2.1 Level AA is the technical benchmark EN 301 549 refers to for web content, published by the W3C as the Web Content Accessibility Guidelines 2.1. The guidelines have three conformance levels, of which A and AA are binding. For an SME project they break down into a manageable list of tasks.
- Keyboard operation: every function – navigation, filters, forms, cookie dialogue – is reachable without a mouse, with a visible focus ring and no trap.
- Contrast: text against background at least 4.5:1, large type and interface controls at least 3:1.
- Text alternatives: every image that carries information gets a meaningful alt attribute, decorative images stay empty.
- Structure: one H1 per page, then heading levels with no gaps, lists and tables as real markup rather than layout.
- Forms: every field has an associated label, errors are named in text and not only marked by colour.
- Motion and media: animations that start on their own can be paused, videos get captions.
- Magnification: the page stays usable at double zoom and at narrow mobile widths, with no horizontal scrolling.
This list is not a box-ticking exercise. It describes decisions taken in component code, where they are cheap to take while a site is being built. Automated tools find only part of it: every tool reports contrast and missing attributes, while keyboard traps and illogical focus order surface only in a manual pass. Plan a hands-on check for every revenue-critical flow.
What does an accessible website cost for an SME?
There are no reliable flat rates: search for the cost of an accessible website and you will find offers from a few hundred to several tens of thousands of euros. The reason is not arbitrariness but the starting point: what drives the figure is the number of page templates, the amount of interactive components and whether the markup is clean. A component-based site with few templates reaches Level AA in a manageable time frame; a shop grown over years with third-party plug-ins is its own project.
A figure becomes dependable only after an audit. The usual approach has three parts: an automated test across all templates, a manual review of keyboard, focus and forms, then a defect list prioritised by impact with the effort per item. Only then can a fixed price be calculated. How we break down website budgets in general is set out in our overview of what a website costs in Germany; the package structure is listed under pricing.
What happens if your website is not accessible?
Fines follow Section 37 BFSG, in two ranges: up to €10,000 as a rule and up to €100,000 for breaches listed individually in the act. The widely quoted €100,000 is therefore an upper limit for specific offences, not a standard figure. Supervision lies with the market surveillance body of the federal states; the supervisory authorities explain the procedure, for example the Bavarian trade inspectorate.
More relevant in practice than the penalty range is the path to it. Consumers can complain to the market surveillance body, which reviews the case and demands remediation; it gets expensive only when a company fails to respond. Alongside that sits the commercial risk: a booking flow that fails without a mouse loses enquiries every day, whether or not an authority ever asks. Accessibility also excludes nobody who does not need it: large tap targets, clear error messages and legible contrast help users on a small display or in poor light too.
How do you get started over the next four weeks?
Start with the classification, not the code. Four steps give you a dependable basis. First, establish whether your offering falls under the BFSG and whether the exemption applies – in writing, with a date. Second, identify the two or three pages through which consumers actually complete a purchase. Third, walk those flows with a keyboard and a screen reader and note every point where you get stuck. Fourth, sort the defects by impact: first what prevents completion, then what makes it harder, then cosmetics. That order keeps the budget together, because those few pages carry most of the risk.
For the technical part, the same rule holds as for any front-end project: accessibility belongs in the components, not in an overlay script that masks them. We build it directly into the markup in accessible web design and in custom web applications.
Does a pure brochure website have to be accessible?
An information-only page with no ordering, booking or account function is, on the current reading, outside the duties of the BFSG, because no service is delivered electronically through it. Once a form leads to a contract, the classification changes. Borderline cases need legal review.
Is an accessibility overlay enough?
Overlays do not meet the requirements. They place a second interface over the page and leave the underlying structure untouched: keyboard traps, missing labels and skipped heading levels remain. The criteria of WCAG 2.1 Level AA apply to the content itself, not to an add-on tool.
Do we need an accessibility statement?
Service providers bound by the act must inform users about the accessibility of their service, easy to find on the website – in practice as its own page next to the imprint and the privacy policy. Which details are required is set out in the BFSG implementing regulation.
We are a micro-enterprise but sell a product. What applies?
Then the product side of the act still applies. The exemption in Section 3(3) BFSG releases micro-enterprises only from the requirements for services; manufacturers, importers and distributors of covered products are bound regardless of their size.
Building accessible websites mit ZeuZ IT
We check whether your offering falls under the duty, review the decisive flows by hand and fix them in the markup – at a fixed price. If a retrofit does not justify the effort because a relaunch is due anyway, we say so openly in the initial consultation and propose the cheaper route. Tell us the one page your customers complete their purchase on – we will reply with an assessment and a fixed price.