Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz): what online shops must comply with from 28 June 2025

In just under two weeks, on 28 June 2025, the Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) will become applicable. It implements EU Directive 2019/882, the European Accessibility Act. In addition to cash machines, banking services and e-books, it covers an area that many smaller businesses long overlooked: services in electronic commerce. This means online shops, booking processes and apps through which consumers conclude contracts.

Who is covered by the Act

The BFSG applies to services provided to consumers after 28 June 2025 (§ 1 Abs. 3 BFSG). A shop that sells exclusively to businesses is not covered. Neither is a purely corporate website on which no contracts are concluded with consumers.

Micro-enterprises providing services are exempt (§ 3 Abs. 3 BFSG). A micro-enterprise is one that employs fewer than ten people and has either an annual turnover of no more than 2 million euros or an annual balance sheet total of no more than 2 million euros (§ 2 Nr. 17 BFSG). The number of employees alone is therefore not enough.

What accessible means

A service is accessible if people with disabilities can find, access and use it in the generally customary manner, without particular difficulty and, in principle, without outside help (§ 3 Abs. 1 BFSG). The details are set out in the ordinance implementing the BFSG (BFSGV). For a shop, this concerns, for example, sufficient contrast, keyboard operation, alternative texts for product images, understandable error messages in forms and an ordering process that a screen reader can read out in full.

In addition, there is a duty to provide information. The provider must explain in an accessible form how its service meets the requirements (§ 14 Abs. 1 BFSG in conjunction with Anlage 3). This is usually done on a separate accessibility page that is easy to find from the shop.

Transitional rules and fines

Contracts for services concluded before 28 June 2025 may continue unchanged until 27 June 2030 at the latest (§ 38 Abs. 1 BFSG). There is no general grace period for the shop itself. Depending on the infringement, the Act provides for fines of up to 10,000 euros or up to 100,000 euros (§ 37 BFSG).

What you can still check before the deadline

• Go through the entire ordering process once using only the keyboard.
• Test with a screen reader whether the basket, forms and error messages are read out comprehensibly.
• Ask the provider of your shop system and design which requirements are already covered.
• Draft the accessibility statement and link to it on your website.