The EU Accessibility Act in Germany (BFSG) for Online Shops
Accessibility (EAA)The European Accessibility Act — Directive (EU) 2019/882 has applied since 28 June 2025, and it changes what consumer-facing e-commerce must offer across the EU. Because the EAA is a Directive, it does not apply directly: each Member State transposes it into national law and enforces it through national authorities. In Germany, that transposition is the Barrierefreiheitsstärkungsgesetz (BFSG) — the Accessibility Strengthening Act — supported by an implementing ordinance that sets out the technical detail.
This guide explains how the BFSG frames accessibility obligations for online shops selling to German consumers, what standard your store is measured against, and where German enforcement fits in. For the wider EU picture, see our accessibility law page, the complete accessibility guide, and our Germany country page.
What the BFSG covers
The BFSG carries the EAA’s logic into German law: certain products and services must be accessible to people with disabilities. For e-commerce, the relevant category is consumer-facing electronic commerce services — the online shop through which a consumer selects goods or services and completes a purchase. If you sell to consumers in Germany through your website, the BFSG is the framework you are expected to meet.
Germany already had an accessibility tradition for public bodies, but the BFSG is significant precisely because it extends binding accessibility duties into the private, consumer-facing marketplace. An online shop is no longer treated as a purely commercial choice about design; it is a service that must be usable by customers with a range of impairments.
The technical standard your shop must meet
The EAA points to the harmonised European standard EN 301 549, which in turn incorporates the Web Content Accessibility Guidelines (WCAG) 2.1 at level AA. In practice, this is the yardstick a German online shop is judged against. Meeting WCAG 2.1 AA is the clearest route to demonstrating that your checkout and storefront are accessible.
For a typical PrestaShop storefront, the recurring problem areas are consistent across the EU. Focus your effort where it matters most:
- Colour contrast — body text and interactive elements should meet a contrast ratio of at least 4.5:1 against their background, so low-vision customers can read prices and buttons.
- Keyboard navigation — every step, from filtering products to completing payment, must be operable without a mouse, with a visible focus indicator.
- Labelled checkout forms — each field needs a programmatic label, and errors must be announced clearly rather than shown by colour alone.
- Alt text for images — product photos and informative graphics need meaningful text alternatives.
- Accessible components — menus, sliders, modals and cart widgets must expose their role and state to assistive technology.
Who is exempt
The EAA — and therefore the BFSG — carves out an exemption for the smallest traders. Microenterprises that provide services and employ fewer than 10 people and have an annual turnover or balance-sheet total of no more than €2 million are exempt from the service obligations. Many small German webshops will fall inside this exemption.
The exemption should be treated with care rather than as an excuse. Business grows, and staff and turnover figures move. A shop that is exempt today may cross the threshold as it scales, at which point the obligations apply. Building accessibility in early is far cheaper than retrofitting it under pressure later.
The microenterprise exemption is a threshold, not a permanent shield — it disappears the moment your headcount or turnover grows past it.
Enforcement in Germany
Because the BFSG is national law, it is supervised and enforced by German market surveillance authorities rather than by an EU-level body. These authorities can require information, investigate complaints, and demand that non-compliant services be brought into line. Consumers and representative bodies can also raise concerns where a service falls short.
The practical takeaway is that “the EU said so” is not the operative reality for a German shop — the BFSG and the German authorities applying it are. Aligning to EN 301 549 and WCAG 2.1 AA is how you satisfy that domestic framework.
A practical starting point
Begin by running your live checkout with the keyboard alone, then check contrast and form labelling on the pages a customer must pass through to buy. These few steps surface the majority of real-world failures. If you would like a structured review mapped to WCAG 2.1 AA, our PrestaShop compliance audit examines your storefront and checkout against the standard.
This article is educational and does not constitute legal advice.