---
title: BFSG 2025: What the Accessibility Reinforcement Act means for websites &amp; online stores - isla Studio
url: https://isla-stud.io/en/allgemein/bfsg-2025-was-das-barrierefreiheitsstaerkungsgesetz-fuer-websites-onlineshops-bedeutet/
date: 2025-12-11
---

# BFSG 2025: What the Accessibility Improvement Act means for websites &amp; online stores

Accessibility is no longer just a „nice to have“. It determines whether people can use your content at all - and increasingly it also determines how search engines rate your website.



With the Accessibility Improvement Act (BFSG), the legislator has now put the topic where it belongs: in the standard checklist for digital products, websites and online stores. Since June 28, 2025 at the latest, certain products and services must be made accessible. This also includes e-commerce services - in other words, the very online offers that consumers use to conclude contracts, buy products or book services. (Laws on the Internet)



This is what this article is about,




what the BFSG 2025 actually regulates,



whether your website or online store is affected by the BFSG,



how you implement the requirements in practice,



and why accessibility is not only a legal benefit, but also a benefit for your ranking and conversion.





Table of contents
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1. what is behind the Barrier-Free Strengthening Act (BFSG)?



The BFSG transposes the European Directive (EU) 2019/882, the so-called European Accessibility Act, into German law. The aim is to harmonize the accessibility requirements for certain products and services across Europe and to enable people with disabilities to participate on an equal footing. (Laws on the Internet)



Section 1 of the BFSG states, very briefly:




The purpose of the Act is to ensure the accessibility of certain products and services in the interests of consumers and users. (Laws on the Internet)




Important for your planning:




The law was passed in 2021 and



came fully into force on June 28, 2025. (Social Association VdK Germany e.V.)




The specific technical requirements for accessibility are regulated in the Ordinance to the BFSG (BFSGV). Among other things, it is based on the European standard EN 301 549 and thus on the Web Content Accessibility Guidelines (WCAG 2.1, Level AA). (Laws on the Internet)







2 Who does the BFSG 2025 apply to - am I affected as a website operator?



The central question that many people are asking is this:




„Is my website affected by the BFSG?“




The answer does not depend on whether you „have a website“, but on what you do there. The law lists a range of products and services - from banking services to e-books and e-commerce services. (Federal Accessibility Agency)



2.1 BFSG and „e-commerce services“



The term „e-commerce services“ is defined in the BFSG (Section 2 No. 26 BFSG) and is clearly explained by the Federal Accessibility Agency: It refers to services where consumers conclude a contract online - for example by purchasing, booking or ordering. (Federal Accessibility Agency)



Typical examples:




Online stores where customers place products in their shopping cart, order and pay,



Websites with online appointment booking, if the booking leads directly to a paid contract (e.g. medical practice, hairdresser, coaching, course booking),



portals through which tickets, subscriptions or digital services are booked,



platforms on which consumers conclude contracts with third parties.




If you find yourself in these examples, you are in the core area „BFSG online store / BFSG website in electronic commerce“.







2.2 Purely informative websites vs. BFSG obligation



Not every website is automatically an „FSIA website“ within the meaning of the law:




Pure information offerings on which you explain services, show references and enable contact, but do not offer direct online contract conclusion, are often classified differently by specialist bodies than classic e-commerce or booking platforms. (Federal Accessibility Agency)



Nevertheless, digital accessibility makes sense here too - from the point of view of user experience, SEO and brand presence.




In short:




Yes, the BFSG 2025 affects many online stores and booking routes.



No, not every simple company website is automatically subject to the BFSG obligations.








2.3 BFSG &amp; microenterprises: the exceptions



Are you wondering whether you fall under the so-called „BFSG microenterprise exemption“? Rightly so, because many smaller businesses fall into this category.



Micro-enterprises are companies with (Bundesregierung.de)




less than 10 employees and



no more than EUR 2 million in annual turnover or annual balance sheet total.




The following applies to these companies:




If they provide services, accessibility is generally voluntary according to the BFSG - they are therefore not subject to the obligation to provide accessible services. (Federal Government.de)



However, if they manufacture products or place products on the market that fall under the scope of the BFSG (e.g. certain end devices or e-books), the requirements apply despite their micro-enterprise status. (Federal Government.de)




It is also important to note that B2B offers aimed exclusively at companies are not covered by the BFSG, according to various specialist sources. It is crucial that it is clear that these are not offers for consumers. (BFSG)







3. when do the requirements apply - and what are the penalties for non-compliance?



The BFSG came into effect - with a few exceptions - on June 28, 2025. From this date, the products and services covered must meet the statutory accessibility requirements. There are transitional regulations for certain constellations, such as for products that have already been placed on the market. (Social Association VdK Germany e.V.)



3.1 BFSG Fines of up to 100,000 euros



If accessibility requirements are not met when offering products or services, the responsible market surveillance authorities can take measures - from requesting improvements to banning the offer. In serious cases, fines of up to 100,000 euros can be imposed, as various legal articles explain. (Weiß &amp; Partner Esslingen)



In addition to official proceedings, you should not underestimate the reputational effects: If you demonstrably exclude people, you lose trust - both with users and with partners, the media and potential employees.







4 What does „barrier-free“ actually mean for websites and online stores?



The BFSGV specifies what accessibility means for the products and services concerned. For e-commerce services in particular: (laws on the Internet)




the general requirements for services (§ 12 BFSGV),



additional requirements for certain services (§ 13 BFSGV) and



the special requirements for services in electronic commerce (Section 19 BFSGV).




In practice, this means for a BFSG website / BFSG online store, among other things:




Information must

understandable,



perceptible via different senses (e.g. text instead of pure picture writing),



and robustly provided. (Laws on the Internet)





The user interface must be designed in such a way that it can be used by people with different limitations - keyword keyboard operability, focus guidance, helpful error messages. (Laws on the Internet)



Assistive technologies (e.g. screen readers) must be able to handle the content in a meaningful way - this requires clean HTML structures and semantic markup.




Many of these requirements coincide with what you already know from technical search engine optimization: structured content, clear semantic levels, stable layouts and good performance. A detailed overview of these intersections can be found in the article „Technical SEO 2024: Comprehensive guide to website optimization“ on my website:https://isla-stud.io/ratgeber/technische-seo-leitfaden-2024/ (saskialund.de)







5. practical requirements: BFSG website &amp; BFSG online store



To make things concrete, here are some key points that can be derived from the BFSG, BFSGV and the WCAG basic principles:



5.1 Structure &amp; navigation




Headings follow a logical hierarchy (H1-H2-H3).



Navigation areas are organized as <nav> excellent, the main content as <main>.



The focus (i.e. the controlled element) is visible/highlighted when you operate your website using only the keyboard.




5.2 Forms &amp; checkout



The checkout in particular determines whether your online store is accessible:




Each form field has a correctly linked label.



Error messages are understandable and are made accessible both visually and via screen reader.



Mandatory fields are clearly marked.



Captchas do not block people with disabilities; there are alternatives or accessible variants. (Laws on the Internet)




5.3 Content &amp; media




Images have meaningful alternative texts, especially if they trigger functions (buttons, icons) or convey relevant content.



Videos offer subtitles, ideally also transcripts.



PDFs that are important for products or contract content (e.g. general terms and conditions, product information) are available in accessible form or there are equivalent HTML alternatives. (Laws on the Internet)




5.4 Performance &amp; stability



Accessibility without performance problems is much easier to implement:




A stable, high-performance structure (Core Web Vitals) helps to ensure that control elements do not „slip away“ while people try to focus on them or click on them.



This is where we come full circle to technical SEO and articles such as „Most important SEO trends in 2024: How to prepare optimally“:https://isla-stud.io/ratgeber/wichtigste-seo-trends-in-2024-so-bereiten-sie-sich-optimal-vor/ (saskialund.de)








6th BFSG Website Checklist: Starting point for your implementation



The following FSIO checklist for websites is not a substitute for legal advice, but it will help you to get started:




Clarify the scope of application

Do you offer products or services to consumers?



Can consumer contracts be concluded online on your website (purchase, booking, subscription)? (Federal Accessibility Agency)





Check company size

Are you a microenterprise (fewer than 10 employees and no more than EUR 2 million in annual turnover/total assets)?



Do you „only“ provide services or do you also market products within the meaning of the BFSG? (Federal Government.de)





Analyze structure &amp; content

Is your website fully keyboard accessible?



Are the most important functions accessible without a mouse?



Is the heading structure consistent?





Test forms &amp; checkout

Are all mandatory fields clearly marked?



Are errors explained clearly?



Does the entire process (e.g. checkout, appointment booking) work with a keyboard and screen reader?





Check media &amp; documents

Do all relevant images have alt texts?



Are videos subtitled?



Are PDFs containing contract information accessible or are there HTML alternatives? (Laws on the Internet)





Strengthening the technical basis

Are you already using a clean SEO setup, e.g. with a plugin like Yoast SEO?



My guide to Yoast SEO for WordPress: „Setting up the Yoast SEO plugin optimally: here's how!“:https://isla-stud.io/yoast-seo/yoast-seo-plugin-optimal-einstellen-so-gehts/ (saskialund.de)





Observe documentation and information obligations

Can users easily find out to what extent your service is accessible?



Is there a page or section with „information on accessibility“, as required by Annex 3 to the BFSG and Section 19 BFSGV? (Laws on the Internet)










7. tools, quick wins &amp; userway as a supplement



Accessibility is not a one-off tick in the checklist, but an ongoing process. However, this does not mean that you have to work without technical support.



7.1 Automated checks to get started



There are numerous tools that recognize typical problems:




Browser extensions that check WCAG rules,



integrated checks in developer tools,



specialized scanners for large websites.




They do not replace a manual check, but quickly show you where you should start.



7.2 Accessibility widget as a supporting module (Userway certified according to ISO27001)



An accessibility widget can help users to better adapt content to their needs - for example by




contrast switchers,



font size slider,



simplified views for certain restrictions.




It is important to have the right expectations: a widget does not automatically make a page BFSG-compliant, but can offer additional options and cushion gaps in the short term.



If you want to use such a tool, Userway is an established solution. You can view the offer via the following link:







Test Userway Accessibility Widget



Used sensibly, Userway can help to improve user-friendliness and perceived accessibility - ideally in combination with structural improvements to layout, HTML and content.







So what we need to take away from the BFSG:



The Barrierefreiheitsstärkungsgesetz 2025 makes it clear: digital accessibility is no longer an optional extra, but is becoming a mandatory quality standard - especially where people conclude contracts, buy products or book services online.



For you as the operator of a website or a BFSG online store, this means that




Check whether your offers fall within the scope of the BFSG,



make your website technically and content-wise accessible,



keep an eye on documentation and information obligations,



and see accessibility not just as an obligation, but as an opportunity for better user experience, better rankings and more conversion.




With a solid technical basis, a clearly structured BFSG website checklist and the support of tools - from SEO plugins such as Yoast to accessibility widgets such as Userway - an unwieldy law becomes a practical project that strengthens your digital presence in the long term.







Sources




Laws on the Internet - Barrierefreiheitsstärkungsgesetz (BFSG), Federal Ministry of Justice / juris GmbH, incl. § 1 (Purpose and scope of application), § 2 (Definitions), § 14 (Obligations of the service provider), § 37 (Provisions on fines). (Laws on the Internet)



Laws on the Internet - Ordinance on the Accessibility Reinforcement Act (BFSGV), Ordinance on the accessibility requirements for products and services under the BFSG, in particular §§ 1, 2, 12, 13 and 19 (Laws on the Internet).



Bundesfachstelle Barrierefreiheit - FAQ on the BFSG and FAQ on services in electronic commerce, explanation of the products and services concerned, definition of „services in electronic commerce“ and practical examples of online stores and booking sites. (Federal Accessibility Agency)



Federal Ministry of Labor and Social Affairs (BMAS) - Regulation on the Accessibility Reinforcement Act, background information on the BFSGV and the relationship between BFSG, BFSGV and European standards (e.g. EN 301 549). (BMAS)



Federal Government - „Digital accessibility becomes mandatory: Questions and answers on the Accessibility Reinforcement Act“, compact presentation of the scope of application, deadline June 28, 2025, exceptions for micro-enterprises and application examples. (Federal Government.de)



Portal Barrierefreiheit (Bund) - Information on the BFSG, overview of the scope of application, market surveillance and role of the BFSGV as a concretization of the technical requirements. (BMAS)



IHK Darmstadt - „Barrierefreiheitsstärkungsgesetz: Pflicht für Webseitenbetreiber und Online-Shops“, classification of BFSG obligations in e-commerce, information on micro-enterprises, B2B offers and online appointment bookings. (Chamber of Industry and Commerce)



HÄRTING Rechtsanwälte - „Das Barrierefreiheitsstärkungsgesetz (BFSG) im E-Commerce“, legal analysis of scope, deadlines, affected online services and obligations for digital offers. (HÄRTING Attorneys at Law)



Legal guide - „Barrierefreiheitsstärkungsgesetz (BFSG) - Das müssen Sie wissen“, overview of legal principles, fines of up to 100,000 euros and sample requirements for information and user interfaces. (Weiß &amp; Partner Esslingen)



anatom5 - „BFSG and services in electronic commerce“, practice-oriented classification of the BFSG obligations, especially for online stores and service portals, including reference to market surveillance and fines. (Anatom5)



byte.law - „Barrierefreiheitsstärkungsgesetz (BFSG) - New obligations for digital products and services“, reference to BFSGV and WCAG 2.1 AA as a benchmark for digital accessibility. (Byte.law)



European Accessibility Act - Directive (EU) 2019/882, European framework for accessibility requirements, implemented by the BFSG in Germany. (Laws on the Internet)