The Accessibility Enhancement Act (BFSG) has been in effect since June 28, 2025—including for online stores—and without the often-cited transition period extending to 2030. A little over a year after the effective date, it’s clear: market surveillance is in effect, competition law warnings have been documented—and many online stores are still relying on a grace period that never existed for them. This article clears up the misunderstandings and explains what the law actually requires.
At a Glance
- The BFSG has been in effect since June 28, 2025 —online stores provide “services in electronic commerce” and are covered by the law without a general grace period.
- The “transition period until 2030” essentially applies only to self-service terminals and ongoing contractual relationships entered into before the effective date— not to online stores.
- The de facto standard is WCAG 2.1 AA (via the European standard EN 301 549); in addition, there is a requirement to provide an accessibility statement.
- The market surveillance authority MLBF has been active since September 2025; fines can reach up to €100,000.
- The micro-enterprise exemption (fewer than 10 employees and a maximum annual revenue of €2 million) applies only to services—not to products placed on the market.
Does the BFSG already apply to my online store?
Yes—if your store sells to consumers, the BFSG has applied since June 28, 2025. Online stores, as “services in electronic commerce,” fall directly within the scope of the law, which transposes the European Accessibility Act (Directive (EU) 2019/882) into German law. The entire ordering process is covered: product presentation, shopping cart, checkout, account pages, and form pages. Pure B2B stores that sell exclusively to businesses are not covered—but anyone who sells to consumers even on the side, or who does not effectively exclude sales to consumers, should prepare for the law’s applicability.
What transition period actually applies—and to whom?
For the online store itself: none. The often-cited deadline of June 27, 2030, stems from the transitional provisions of the BFSG and essentially applies to two scenarios— self-service terminals that were already lawfully in use before the effective date (they may continue to operate until the end of their economic useful life, up to a maximum of 15 years), and service contracts concluded before June 28, 2025 (they may continue unchanged until June 27, 2030, at the latest). An online store enters into a new contract with every purchase—it cannot invoke these transitional rules. The assumption that “we have until 2030” is therefore simply incorrect for store operators and has been a real legal risk for over a year.
Who is exempt?
Micro-enterprises that provide services—including online stores operating as service providers—are exempt from the BFSG if they employ fewer than 10 employees and have an annual turnover or annual balance sheet total of no more than €2 million. Both conditions must be met simultaneously. Important: The exemption applies only to the provision of services. Anyone who themselves places products on the market that fall under the BFSG (such as smartphones, e-book readers, or routers, as a manufacturer or importer) remains subject to these obligations—regardless of the company’s size. Even exempted online stores should take a strategic view of this issue: If the company grows beyond the thresholds, the exemption ends—and accessible online stores simply reach more customers.
What specific requirements must the online store meet?
The standard is, in practice, the Web Content Accessibility Guidelines ( WCAG) 2.1 AA, as defined by the European standard EN 301 549. In addition, there is an obligation to explain in the Terms and Conditions or in another clearly visible location how the service meets the accessibility requirements (accessibility statement). The most common checkpoints in online store practice:
| Checkpoint | Requirement |
|---|---|
| Color Contrast | At least 4.5:1 for normal text, 3:1 for large text and UI components—including buttons, badges, and prices. |
| Keyboard navigation | All functions—navigation, variant selection, shopping cart, checkout—must be accessible and operable without a mouse. |
| Form Labels | Each input field has a programmatically linked label; error messages specify the affected field and the cause. |
| Focus indicators | Keyboard focus is visible at all times—no ` outline: none ` without an equivalent alternative. |
| Alt Text | Product images and functional graphics have meaningful alternative text; decorative graphics are labeled as such. |
| Structure & Semantics | A clean heading hierarchy, real buttons and links instead of clickable divs, and understandable link text. |
What is the penalty for a BFSG violation?
Fines can range up to €100,000, depending on the violation. The Central Market Surveillance Authority of the German States for the Accessibility of Products and Services (MLBF), which has been operational since September 2025, is responsible for enforcing the BFSG—it can initiate investigation proceedings, demand corrective action, and, in extreme cases, order the suspension of the service. In addition, a second risk has materialized: Violations of the BFSG are classified as antitrust violations, and the first warning letters from competitors and associations have been documented. Consumers and recognized associations can also file complaints with market surveillance authorities. The likelihood of remaining “unnoticed” is thus steadily decreasing—especially since accessibility deficiencies can be automatically detected from external sources.
How can I test my online store myself?
You can get a reliable first impression without specialized knowledge: Set the mouse aside and go through the entire ordering process using only the keyboard (Tab, Enter, arrow keys)—wherever you get stuck or lose focus, there’s a deficiency. Check contrasts using a contrast checker, zoom in to 200% (content must not be cut off), and run automated tools such as Lighthouse or axe. Important to note: Experience shows that automated tests identify only a portion of the barriers—they are a starting point, not definitive proof. For a binding evaluation and accessibility statement, a structured review based on the WCAG criteria is recommended; for larger online stores, this should be conducted by external experts.
The XONIC Shop System is developed in accordance with the WCAG 2.1 AA guidelines: color contrast, keyboard accessibility, visible focus indicators, and semantic HTML are mandatory requirements for front-end development. Responsibility for the specific online store remains with the operator—the store’s own content, alt text, and customizations must be included in every audit. The feature overview provides an overview of the system; the article on the GDPR-compliant online store system explains how XONIC generally addresses legal requirements.
Note: This article does not constitute legal advice. Specialized law firms and accessibility auditors provide binding clarification on whether and how the BFSG applies to your specific online store.
Frequently Asked Questions About the BFSG for Online Stores
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Stephan Dunger
Stephan Dunger is one of the brains behind the XONIC store system. He has been developing the platform together with the team since 2012 - from the database to the interfaces to the checkout.
A passionate programmer, technical mind and consultant at the same time: with his in-depth knowledge of store systems and e-commerce, Stephan combines the depth of a developer with an eye for the big picture. Together with the XONIC team, he shapes the technical direction, consistently thinks about functions from the retailer's perspective and advises on customized solutions.
The result is software with a face: customers don't get an anonymous provider, but a direct line to the people who develop XONIC. Pragmatic, fast and at eye level.
