Why this matters
Germany's Accessibility Improvement Act has applied in full since 28 June 2025 and covers services in electronic commerce, among other things. Many side businesses qualify for the micro-enterprise exemption for services. Applying that exemption too broadly to products, growing businesses, or every digital process can still produce the wrong result—and misses the commercial benefit of making a shop easier for real customers to use.
Turn knowledge into a start plan
This guide explains one topic. Whether it is really a priority for you right now depends on your answers in the start plan.
Create start planWhen an online shop falls within the BFSG
The BFSG covers specified products and consumer services. Its services include electronic-commerce services: digital services offered through websites or mobile applications at a consumer's individual request with a view to concluding a consumer contract.
For a B2C online shop, the path to the contract is therefore particularly important: product information, search, basket, identification, authentication, payment, and conclusion. A presentation-only website without a route to a consumer contract may require a different assessment.
Pure B2B offers do not fall within the same consumer-facing scope. A shop serving mixed customer groups should not rely only on a ‘B2B’ footer notice where consumers can in fact place orders.
The important micro-enterprise exemption
Micro-enterprises providing services are exempt from the corresponding BFSG service requirements under Section 3(3). A micro-enterprise generally employs fewer than ten people and has either annual turnover or an annual balance-sheet total not exceeding two million euros.
The two layers must remain separate: the exemption concerns services. Micro-enterprises that manufacture, import, or place products covered by the BFSG on the market do not receive a blanket exemption from the product duties.
Document employee headcount, turnover or balance-sheet total, and the business model at the review date. Reassess when you grow, offer a covered product, or spread the sales process across several businesses.
What accessible operation means in practice
An accessible service should be findable, accessible, and usable without particular difficulty and generally without outside help. The BFSGV requires information and functions to be perceivable, operable, understandable, and robust, among other things.
In a shop, that means meaningful headings and labels, sufficient contrast, useful alt text, keyboard operation, visible focus, correctly announced errors, zoomable content, and a checkout that does not rely only on a mouse, colour, or time pressure.
Identification, authentication, security, and payment functions also need accessible design. An otherwise strong shop still blocks customers if the cookie banner, CAPTCHA, payment window, or withdrawal function becomes an insurmountable barrier.
Provide information about accessibility
Service providers within scope must provide information explaining how the service meets the accessibility requirements. It belongs in the general terms or an equivalent accessible document and must itself be accessible.
Describe the service in general, explain the operation needed to understand it, and state how the relevant requirements are met. Keep the information for as long as the service is offered and establish a process for feedback and remediation.
A generic accessibility statement copied from a template does not establish conformity. It should accurately reflect the real shop, known limitations, contact route, and improvement process.
How to review your shop sensibly
Start with the most important user journeys rather than a single automated score: home, search, category, product detail, basket, checkout, payment, account, contact, withdrawal, and confirmation. Test on mobile, with a keyboard, and at strong zoom.
Automated tests can find missing labels, contrast issues, and technical role problems, but not every comprehension and usability barrier. Add manual testing and, where your service is in scope, a qualified assessment.
Prioritise blockers before cosmetic issues. Missing keyboard access, unlabelled inputs, unclear errors, lost focus, unreadable contrast, or an unusable payment window prevent real transactions.
Why an exemption is not a reason to stand still
Even a legally exempt micro-enterprise benefits from accessible processes. Accessibility often improves mobile use, clarity, technical quality, and reach while reducing support questions and abandoned purchases.
Build a small baseline regardless of the legal duty: semantic structure, keyboard access, visible focus, strong contrast, real labels, understandable language, and alt text for informative images.
If a theme, plugin, or payment module creates barriers, document the finding and ask the vendor for its roadmap and evidence. Choosing a third-party component does not automatically settle responsibility for the overall process you offer.
Quick checklist
- Check whether your website or app prepares or concludes consumer contracts.
- Distinguish B2C, B2B, and mixed sales routes honestly.
- Document the micro-enterprise criteria using headcount and turnover or balance-sheet total.
- Assess product duties separately from the service exemption.
- Test the full user journey from home page to payment and withdrawal.
- Operate all functions with a keyboard and check visible focus.
- Review labels, headings, contrast, alt text, and error messages.
- Include cookie, login, CAPTCHA, payment, and third-party components.
- Where applicable, provide accessible information on BFSG compliance.
- Organise feedback, remediation, and repeat testing.
Common mistakes
- Treating every business website as automatically subject to the BFSG.
- Applying the micro-enterprise service exemption to all covered products.
- Calling a consumer-facing shop B2B only through a footer notice.
- Relying on a single automated accessibility score.
- Leaving checkout, payment, cookie, and withdrawal functions out of testing.
- Publishing a template statement that does not match the real shop.
- Treating accessibility as a one-off project rather than part of updates.
Frequently asked questions
Is my small online shop exempt from the BFSG?
If your business meets the micro-enterprise criteria, the exemption for electronic-commerce services may apply. Product-related BFSG duties are separate, and growth or a changed business model requires a fresh assessment.
Do I have to comply with all of WCAG?
The BFSG, BFSGV, and the relevant technical standards and presumptions of conformity are legally decisive. WCAG criteria are an important practical testing tool but do not by themselves replace the legal assessment of the complete service.
Is an accessible shop theme enough?
No. The theme, your content, apps, payment provider, cookie banner, and ongoing changes combine to create the user journey. A good theme is a foundation, not proof that the finished shop is accessible.
What this guide can and cannot do
This guide helps with
- roughly sort your model by B2C, B2B, micro-enterprise status, and product relevance
- create a practical accessibility checklist for your most important user journeys
- prioritise barriers by their impact on real customers
This guide does not replace
- confirm your BFSG exemption or conformity as a binding decision
- replace a complete technical and legal accessibility audit
- guarantee the accessibility of third-party shop, payment, or plugin providers