Does Your Website Have to Be Accessible? Germany's BFSG, Checked

A note up front: this article is not legal advice. It puts the legal situation into plain terms for business owners; for binding answers on your individual case, speak to a lawyer or your chamber of commerce (IHK).

Perhaps you know the email: from 2027, "every website without exception" must be accessible, or five-figure fines loom. Quote attached.

We went looking for that deadline at the body that would have to know it: Germany's Federal Agency for Accessibility (Bundesfachstelle Barrierefreiheit). It isn't there.

What actually applies is more nuanced – and for many small businesses considerably more relaxed. Understanding it means deciding better than under pressure.

What is the BFSG – in two paragraphs?

The Barrierefreiheitsstärkungsgesetz implements an EU directive – the European Accessibility Act – into German law. It obliges companies to design certain products and services so that people with disabilities can use them without assistance. It has been in force since 28 June 2025 (Federal Agency for Accessibility).

For websites, the relevant category is "services in electronic commerce": if consumers can conclude contracts through your website – an online shop, a booking system, paid reservations – that part of your site falls under the act in principle. Violations carry fines of up to €100,000 (IHK Schwerin).

Is my website covered? The 2-question check

Question 1: Can consumers conclude transactions electronically on your site? This means more than "there's a contact form." It covers websites through which purchase or service contracts are concluded: online shops, binding online booking, paid reservation systems. A plain business-card website with a phone number and directions is, on the prevailing reading, not covered. For borderline cases – say, a booking calendar without payment – interpretations differ; it's worth asking your chamber of commerce.

Question 2: Is your business larger than a micro-enterprise? This is where the act's most important exemption comes in – more on that in a moment.

For typical owner-run businesses, that means:

• Driving school with online registration and online payment: covered, depending on size.
• Physiotherapy practice with online appointment booking: borderline – depends on the setup and the size of the business.
• Garage whose website only shows services, team, and a phone number: on the prevailing reading, not covered.
• Kitchen studio with an online shop: covered for the shop, unless an exemption applies.

The micro-enterprise exemption – and the deadline that doesn't exist

The act explicitly exempts micro-enterprises that provide services: businesses with fewer than ten employees and no more than €2 million annual turnover are not covered by the BFSG for their services (Federal Agency for Accessibility). The exemption does not apply to products – whoever places physical products on the market falls under the act regardless of size.

Two things worth knowing:

First: the widespread claim that this exemption "runs out at the end of 2026," making every website mandatory from 2027, does not appear in the Federal Agency's publications. If a provider pressures you with that deadline, ask them for the precise legal basis – and have the answer checked by your chamber of commerce if in doubt. Serious advice cites sections of the law, not a countdown date.

Second: "exempt" does not mean "done." The exemption frees you from the act – not from the reasons the act exists. And those reasons are commercially relevant too.

Why accessibility pays off even without the obligation

We build every website to the WCAG 2.2 AA standard – including for businesses the BFSG doesn't cover at all. Not out of idealism, but for three sober reasons:

1. Reach. Millions of people live with visual, hearing, or motor impairments – add an ageing customer base that benefits just as much from good contrast, clear type, and simple navigation. A business whose website locks these people out is voluntarily giving up customers.

2. Visibility. Accessibility and machine readability are technically close cousins: clean heading structure, described images, clear forms, plain language. Exactly these properties make a website easier for Google and for AI search systems to parse. An accessible website is almost automatically one that search engines understand better.

3. Future-proofing. The scope of accessibility rules has grown steadily in recent years, never shrunk. Building cleanly today means no expensive retrofit later – bolting accessibility onto a finished website is regularly more expensive than building it in from the start.

What does "accessible" actually require? The key criteria

In practice, the benchmark is the international WCAG standard (Web Content Accessibility Guidelines) at level AA. Behind the unwieldy name sit very concrete requirements – a selection:

• Contrast: text must stand out sufficiently from its background (light grey on white fails).
• Keyboard operability: every function must be reachable without a mouse.
• Alt text: images need descriptions a screen reader can announce.
• Understandable forms: fields are labelled; error messages explain what to fix.
• Structure: headings are real headings, not just bold text.
• Motion: animations can be reduced or switched off.

For a first impression of where you stand, try a simple self-test: operate your website using only the keyboard (Tab key), and set your browser's zoom to 200%. If content becomes unreachable or the layout falls apart, you have your answer.

Frequently asked questions

Does the BFSG apply to my existing website? The act applies to services provided since 28 June 2025 – so an existing website with covered functions falls under it unless an exemption applies. The act provides transition rules for certain legacy cases; whether one applies to you is best clarified with your chamber of commerce.

I only have a contact form – am I covered? A plain contact form without contract conclusion does not, on the prevailing reading, make your site "electronic commerce." As soon as binding booking, ordering, or paying happens online, the picture changes.

I'm a sole trader – so I can ignore all this? Legally, as a micro-enterprise you're exempt for services. Commercially, accessibility remains worthwhile: better usability for every customer, better readability for search engines and AI systems.

What does an accessible website cost? Built in from the start, accessibility adds barely any cost – it's a question of craft standards, not budget. It gets expensive when a finished site has to be rebuilt. That is why we build to WCAG 2.2 AA from the start. If your website has to meet the BFSG, we set that out in your offer.

Who actually enforces this? The market surveillance authorities of the German federal states. They can audit, demand corrections, and impose fines of up to €100,000 for violations.

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Sources

• Federal Agency for Accessibility: The BFSG (German)
• IHK Schwerin: Accessibility mandatory for businesses from June 2025 (German)
• IHK Munich: BFSG overview for companies (German)
• W3C: Web Content Accessibility Guidelines (WCAG)

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About the author: Nils Ehrenfried is the founder of The Presence. He started out on the agency side – with projects for clients including TSG Hoffenheim and Springer Verlag – then switched perspectives and built a company of around 250 employees, which he led up to its exit. Now back on the services side, he knows both roles: the craft of an agency, and the daily reality of a real business that hires one.

Not sure which side of the 2-question check you're on? Tell us one thing in a free consultation: what consumers can do on your website – book, order, or just read. Then we'll tell you what's needed. Even if the answer is "nothing." Book a free consultation