Law & Practice

The German Accessibility Act: Does Your Website Have to Be Accessible Now?

Germany's Barrierefreiheitsstärkungsgesetz (BFSG), the country's Accessibility Strengthening Act, has applied since 28 June 2025, and since then many small businesses have been asking the same question: does my website have to be accessible now, and what happens if it is not? The honest answer: it depends on what your website actually does. This guide explains who the law covers, what it requires, and what to do in practice. We skip the scaremongering, and we skip answering questions that only a lawyer should answer.

What the BFSG requires

The BFSG is a German law that transposes an EU directive (the European Accessibility Act) into national law, and it has applied since 28 June 2025. It primarily covers websites with consumer-facing commerce: online shops, booking and appointment systems, customer accounts, and anywhere consumers conclude contracts or order services online. A plain company brochure site without ordering or booking functionality generally does not fall under it. The law targets websites through which something is actually sold, booked, or contracted online.

The benchmark is the European standard EN 301 549, which for websites essentially points to the internationally recognised WCAG 2.1 web standards at conformance level AA. This is not a newly invented catalogue but an established framework that public-sector websites have had to follow for years already.

Who is exempt

There is an exemption for services: micro-enterprises with fewer than ten employees and an annual turnover of no more than two million euros do not have to meet the BFSG's requirements. Many small trades and service businesses in Schleswig-Holstein fall under this threshold. Important: this exemption applies to the provision of services. Whether and how it applies to your specific website depends on details that cannot be answered in general terms.

What is at stake

For websites that fall under the law, the BFSG provides for market surveillance by the responsible state authorities. Where a violation is established, fines of up to 100,000 euros are possible. Alongside that, as with other legal information duties online, there is a real risk of formal warning notices (Abmahnungen) from competitors or industry associations.

Everything above is a general overview, not a legal assessment of your specific case. Whether the BFSG applies to your website in your particular situation, whether an exemption applies, and exactly what deadlines and obligations apply in detail is something a lawyer specialising in IT or competition law should clarify if in doubt. We build websites — we do not replace legal advice, and no one should expect that from a web agency.

The typical barriers — and why they are usually small

In practice, almost every website shows the same picture: rarely spectacular problems, but a handful of recurring issues.

  • Contrast: light grey text on a white background looks elegant but is barely readable for many people. WCAG AA requires a minimum contrast ratio between text and background colour.
  • Alt text: images without alternative text remain invisible to screen reader users and are missing as information for search engines too.
  • Keyboard and focus: anyone navigating by keyboard rather than mouse needs a visible focus outline and a logical tab order, without traps they cannot escape.
  • Heading structure: a clean hierarchy of h1, h2 and h3 is a screen reader's map of the page. Assigned purely by visual size rather than meaning, that orientation is lost.
  • Forms: input fields without a recognisable label, error messages signalled only through colour, or an enquiry form that cannot be submitted via keyboard.

None of these points requires a new page layout or a new design. They are fine adjustments to an existing website: adjusting colour values, adding missing alt text, labelling form fields properly.

Why a rebuild is rarely necessary

That is why accessibility can, in the vast majority of cases, be retrofitted into the existing website, regardless of which system it was built on. A complete rebuild only makes sense if one is due anyway, for example because the site is technically outdated. If you are already considering a relaunch, plan accessibility in from the start; that is cheaper than adding it later.

Even businesses formally exempt as micro-enterprises have good reasons to address the topic. A website with good contrast, a clear structure and working keyboard operation is more pleasant to use for everyone, for people with disabilities just as much as in bright sunlight on a phone screen or for older customers. Google's quality assessments measure some of the same criteria too, things like clean structure, labelled forms, functioning operation. Accessibility is rarely pure compliance. In many respects, it is simply good website practice.

The accessibility statement

For websites that fall under the law, implementation also includes a document: the accessibility statement. It describes how accessible the offering is, what exemptions may apply, and how to report barriers that are found. This document is published on the website. It should not be written only once: it needs updating whenever significant changes are made.

What it costs at PixAgentur

The first step is a BFSG check for 249 euros: a complete review of your website against WCAG 2.1 AA, using tools and manual testing, including a screen reader test, ending in a prioritised list of findings. If you go on to commission the fix, the check is fully credited against the fixed price. Implementation itself starts from 490 euros at a fixed price. You know the cost in advance, no open-ended hourly billing. If you want it to stay accessible through future changes, there is the accessibility watch for 19 euros a month, cancellable monthly. It covers a check after every major change, a full annual re-check, and keeps the accessibility statement current.

Conclusion

Whether the BFSG specifically applies to your website is a question a lawyer should answer if in doubt, not this page. Technically, though, regardless of that: the typical barriers can be fixed with manageable effort, and a rebuild is almost never necessary. In the end, an accessible website is simply the better website for every visitor. If you want to know exactly where your site stands today, the BFSG check gives you a clear, prioritised answer instead of a vague feeling.

More on testing, implementation and pricing is available on PixAgentur's BFSG page.

Frequently asked questions

Does the BFSG apply to my website?

It primarily covers websites with consumer-facing commerce: online shops, booking and appointment systems, contracts concluded online. A plain company website without such functions generally does not fall under it. Whether this applies to your specific website is a legal question: a lawyer should provide the binding assessment if in doubt.

Am I automatically exempt as a micro-enterprise?

For services, there is an exemption for micro-enterprises with fewer than ten employees and annual turnover of no more than two million euros. Whether this exemption applies in your specific case depends on details that cannot be answered in general terms. A lawyer should clarify this if in doubt.

What happens if I do nothing?

The law provides for market surveillance by the responsible authorities, with fines of up to 100,000 euros for established violations. There is also a real risk of formal warning notices from competitors or industry associations. Regardless of that, an inaccessible site excludes customers and gives away search-ranking points that Google measures too.

Does my website need to be completely rebuilt for this?

In the vast majority of cases, no. Typical problems such as poor contrast, missing alt text, invisible focus outlines, or a messy heading structure can be fixed within the existing website, regardless of the system it runs on. A rebuild only makes sense if one is due anyway.

What is the "accessibility statement"?

A document on your website describing how accessible the offering is, what exemptions apply, and how to report barriers. For websites that fall under the law, it is mandatory and needs updating after significant changes. At PixAgentur it is included as part of the implementation package.

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