What is an accessible website?
The BFSG calls products and services accessible if people with disabilities can find, access and use them "in the generally customary way, without particular difficulty and in principle without help from others". For a website, this means every piece of content and every function must be reachable in more than one way. An image needs a text that a screen reader can read aloud. A menu has to open without a mouse, and a video needs subtitles.
Many groups benefit from this. Blind and partially sighted people use screen readers, magnification or high contrast. Deaf and hard-of-hearing people need subtitles or transcripts. People with motor impairments often control the computer with the keyboard or voice commands only. For people with cognitive impairments, clear structure and plain language matter. Older users, and anyone watching a video on a train with the sound off, gain something too.
How do the law and the standard work?
The BFSG transposes the European Accessibility Act, EU Directive 2019/882, into German law. It applies to services provided to consumers after 28.06.2025. For websites, the most relevant group is "services in electronic commerce" (Section 1(3) no. 5 BFSG). This means services offered through a website or app that aim at a consumer contract (Section 2 no. 26). An online shop clearly belongs here.
Under Section 3(3), micro-enterprises that provide services are exempt. The act defines them as businesses with fewer than ten employees and an annual turnover or annual balance sheet total of no more than 2 million euros. Purely informational websites without contract conclusion and pure B2B offers are not expressly mentioned in the act. Going by the wording, there is much to suggest they are not covered. An appointment booking that creates a contract or a payment area can change that assessment, though.
The act itself contains no HTML rules. Instead, the European standard EN 301 549, version V3.2.1, serves as the technical benchmark. Its Section 9 deals with websites and refers to the Web Content Accessibility Guidelines (WCAG) 2.1 of the World Wide Web Consortium (W3C).
The key building blocks
The four principles of WCAG
All WCAG requirements are grouped under four principles. Content must be perceivable, operable, understandable and robust. Robust means that assistive technologies such as screen readers can also read the content reliably. According to the W3C, people with disabilities cannot use the web if any one of these principles is violated.
Alternative text and media
Every image that carries content needs alternative text describing what it shows or what it is for. Purely decorative images get an empty alt attribute. Recorded videos with sound need subtitles, and podcasts need a transcript.
Keyboard operation
Menus, pop-ups, the shopping basket and the cookie banner must be reachable without a mouse. The focus must never get stuck anywhere and has to stay visible. Its order should follow the reading order.
Structure and language
A page has one H1, followed by H2 and H3 in a logical order. Screen reader users jump through the text using these headings. The lang attribute in the HTML, such as lang="de" on a German page, ensures correct pronunciation. Link texts should make sense even without the surrounding sentence.
Forms and colour
Every input field needs a visible label that is linked to the field in the code; placeholder text disappears as soon as someone types. Information must never be conveyed by colour alone. A required field marked in red also needs text or a symbol.
Common mistakes
- Focus outlines removed with CSS because they do not fit the design.
- A cookie banner that can only be closed with a mouse click.
- Light grey text on a white background with too little contrast.
- Link texts such as "click here" or "more".
- Images without alternative text, or with lists of keywords in the alt attribute.
- Input fields that only have placeholder text and no label.
- Missing information under Section 14 and Annex 3 BFSG, even though the website falls under the act.
How to check
You can complete a first review in about an hour. Take the home page, a typical subpage, the contact form and, if you have one, the checkout process. Put the mouse aside and move through the page with Tab, Shift+Tab, Enter and the arrow keys. Let your operating system's screen reader read the page aloud. Zoom in a long way in the browser and watch whether content overlaps or disappears. Automated testing tools find missing alternative text, weak contrast or fields without labels, yet they only detect some of the problems.
If your website falls under the BFSG, a self-test is usually not enough. An expert audit against EN 301 549 gives more certainty and provides a basis for the information obligation. Under Section 14 and Annex 3, this information belongs in the terms and conditions or in another clearly visible place, presented in an accessible way. It describes the service, explains how it meets the requirements and names the responsible market surveillance authority. The legal assessment of your individual case is a matter for a specialist lawyer.
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FAQ
Does my purely informational website have to be accessible?
The BFSG does not expressly mention purely informational sites without contract conclusion; going by the wording, they are probably not covered. Have your individual case checked, especially if you take bookings or orders.
What are the consequences of breaches?
Under German law, the market surveillance authorities of the federal states monitor compliance, and consumers and recognised associations can contact them. Depending on the breach, Section 37 BFSG provides for a fine of up to 100,000 euros, in other cases up to 10,000 euros.
Do I need an accessibility statement?
The term does not appear in the BFSG. What is required is the information under Annex 3, which in practice often appears under that name.
Does accessibility help with SEO?
Partly. Google uses alternative text to understand images, and clear headings help crawlers too. Do not expect a quick jump in rankings from it.
Sources: Germany's Accessibility Strengthening Act (BFSG) of 16.07.2021, Sections 1, 2, 3, 14, 37 and Annex 3; Directive (EU) 2019/882 (European Accessibility Act); European standard EN 301 549 V3.2.1; W3C Web Content Accessibility Guidelines (WCAG) 2.1; Google.