German Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG): Measures, exceptions, deadlines and sanctions

Why do online shops have to be designed to be barrier-free in the future?

From 28 June 2025, online shops have to be barrier-free – this is required by the new Barrier-Free Strengthening Act (ger. Barrierefreiheitsstärkungsgesetz, BFSG). Find out what this means for operators, what the requirements are, whether there are exceptions and what sanctions may be imposed.

What measures are required?

The Accessibility Strengthening Act requires providers of B2C services – in particular, operators of online shops, apps and websites – to design their digital offerings in such a way that they can be accessed and used by people with disabilities without the need for assistance and without any particular difficulty.

Not only the products or services themselves must be designed to be barrier-free, but also digital access to information, such as product descriptions, contract details or payment processes.

Online shop operators must ensure that their internet offering is designed to be barrier-free. This could include, for example:

• sufficient contrasts: content must be visually clearly distinguishable (e.g. black text on a white background),
• subtitles and alternative texts: multimedia content such as videos require subtitles or transcriptions, images should be provided with descriptive alternative texts,
• keyboard operability: forms, buttons and navigation elements must be fully operable without a mouse – i.e. using the keyboard.

For orientation, the following can be used:

• EN 301 549 (European standard for the accessibility of ICT products and services),
• WCAG 2.1 (Web Content Accessibility Guidelines).

For operators of online services, this means that they have to check their entire internet offering and adapt it to the new legal requirements.

Are there exceptions for micro-enterprises?

The only exceptions are micro-enterprises with fewer than ten employees and fewer than 2 million euros in annual sales or whose annual balance sheet total does not exceed 2 million euros. However, their products must be accessible.

Further exceptions are defined in §§ 16 and 17 BFSG and include:

• costs disproportionate to accessibility
• fundamental changes to the product or service as a result of accessibility

Attention: Exceptions are to be interpreted restrictively, must be documented if necessary and require notification to the responsible market surveillance authority.

By when do online shops have to be adapted?

The law comes into force on 28 June 2025. By this date, all online operators must implement the requirements of the Accessibility Strengthening Act.

What are the sanctions for non-compliance?

The market surveillance authorities will monitor compliance with the provisions of the Accessibility Strengthening Act. In the event of violations, the authorities can restrict or prohibit the provision of the product on the German market or ensure that the product is withdrawn or recalled. Fines of up to €100,000 may also be imposed.