Accessible Website: BFSG, WCAG and a Practical Checklist

Web page with an accessibility symbol, surrounded by a keyboard, a magnifying glass and headphones.
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Published October 18, 2026 · Updated October 18, 2026 · 13 min

In brief

What makes a website accessible, who Germany's BFSG has covered since June 2025, and how to test your site by keyboard, screen reader and checklist.

In short: people with disabilities can use an accessible website without help from others, for example with a screen reader or with the keyboard alone. Since 28 June 2025, Germany's Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) has required this from many businesses that conclude contracts with consumers online. Micro-enterprises that provide services are exempt. The technical benchmark is the European standard EN 301 549, which refers to WCAG 2.1. Whether your website falls under the act is something you should have checked by a specialist. This article describes German and EU law. It is general information, not legal advice.

What does accessible mean for a website?

The BFSG puts it like this: products and services are accessible if people with disabilities can find, access and use them "in the usual way, without particular difficulty and, as a rule, without outside help". For a website, this means every piece of content and every function has to be reachable in more than one way. An image needs a text that a screen reader can read aloud. Menus have to open without a mouse as well. A video needs subtitles for people who cannot hear.

Digital accessibility affects many groups. Blind and partially sighted people use screen readers, magnification or high contrast. If you are deaf or hard of hearing, you need subtitles or transcripts. People with motor impairments often control their computer with the keyboard alone or with voice commands. For people with cognitive impairments, a clear structure and plain language count, sometimes also Easy Language (Leichte Sprache in German).

Users without disabilities benefit too. Anyone watching a video on a train with the sound off reads the subtitles. Older people cope better with large fonts and good contrast. A form with clear labels is quicker for everyone to fill in.

Germany's Accessibility Strengthening Act: who does it affect?

The BFSG transposes the European Accessibility Act, EU Directive 2019/882, into German national law. It applies to certain products and services that are placed on the market (products) or provided to consumers (services) after 28 June 2025. For websites, one group matters most: "services in electronic commerce" (§ 1(3) no. 5 BFSG).

This means services that run through a website or an app and are aimed at concluding a consumer contract (§ 2 no. 26 BFSG). An online shop clearly belongs here. Booking flows, online appointments with a contract or subscriptions taken out on a website can also fall under it. The deciding question is whether a consumer can conclude a contract through the website.

Exemption for micro-enterprises

Micro-enterprises that offer or provide services are exempt from the requirements (§ 3(3) BFSG). Under the act, a micro-enterprise is a business with fewer than ten employees and an annual turnover or annual balance sheet total of no more than €2 million. Both conditions have to be met together. The act words the exemption for services only. Going by its wording, it does not apply to products covered by the BFSG.

What about purely informational websites?

Many company websites only show services, opening hours and contact details. Nobody concludes a contract there. The act does not mention such sites explicitly. Based on the wording of § 2 no. 26, there is a lot to suggest they are not covered. In individual cases the line is not always clear, though. An appointment booking that concludes a contract, or an area for payments, can change the assessment. Going by the wording, offers aimed only at business customers (B2B) probably fall outside the BFSG too, because the act is about consumer contracts.

This is general information, not legal advice. If you are unsure whether your website is affected, have a specialist lawyer check it. Federal public bodies in Germany are covered by a separate regulation, the Barrier-Free Information Technology Ordinance (BITV 2.0).

Online shop on a laptop next to scales and a shield, symbolising legal duties for businesses.
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What obligations does an affected business have?

The first obligation is obvious: the service has to be accessible. For an online shop, that means the whole path from searching through the basket to placing the order works without barriers. On top of this come the BFSG's requirements on information.

Duty to inform under § 14 and Annex 3

If you offer a service covered by the act, you have to explain how it meets the requirements. This information belongs in your general terms and conditions or in another clearly visible place, and it has to be accessible itself. Annex 3 of the act sets out the content, including:

  • a general description of the service in an accessible format,
  • explanations of how the service meets the accessibility requirements,
  • the competent market surveillance authority.

In practice, this page is often called an "accessibility statement" (Barrierefreiheitserklärung or Erklärung zur Barrierefreiheit in German). The BFSG itself does not use the term. Similar pages are familiar from public authorities: BITV 2.0 requires public bodies to publish an "Erklärung zur Barrierefreiheit" that can be reached from every page of the website. For businesses, what counts is that the Annex 3 details are complete and easy to find. The name of the page is secondary.

What happens in case of violations?

The market surveillance authorities of the German federal states monitor compliance. Consumers can turn to the authority, and recognised associations may take legal action on their behalf or in their own name. Under § 37 BFSG, an administrative offence is committed by, among others, anyone who offers or provides a service that does not meet the requirements. Depending on the violation, the act provides for fines of up to €100,000, and in other cases up to €10,000.

Which technical standard applies?

The act itself contains no pixel values or HTML rules. As a technical yardstick, the European standard EN 301 549 in version V3.2.1 applies. Its section 9 deals with websites and refers to the Web Content Accessibility Guidelines, WCAG for short, in version 2.1.

WCAG comes from the World Wide Web Consortium (W3C), which also publishes many other web standards. Version 2.1 has been an official W3C Recommendation since 5 June 2018. There is now a version 2.2 as well. According to the W3C, content that conforms to WCAG 2.2 also conforms to WCAG 2.1 and 2.0. The guidelines have three levels: A as the lowest, then AA, and AAA as the highest.

The four principles of WCAG

All WCAG requirements belong to one of four principles. From their initial letters they are also known as the POUR principles:

  • Perceivable: information and user interface components have to be presented in ways users can perceive.
  • Operable: controls and the ways of moving through a site have to be operable.
  • Understandable: information and the operation of the interface have to be understandable.
  • Robust: content has to be robust enough for many different programs to read it reliably, including assistive technologies such as screen readers.

The W3C sums it up briefly: if any of these principles is not met, people with disabilities cannot use the web.

Checklist: how to make your website accessible

The points below do not cover every WCAG criterion. They cover mistakes that are common and fairly easy to fix.

Alt text for images

Every image that carries content needs an alternative text in the alt attribute. It describes what the image shows or what it is for. A magnifying glass icon on a search button gets the text "Search", and the W3C uses exactly this example. Purely decorative images get an empty alt attribute so the screen reader skips them.

Sufficient contrast

Text has to stand out clearly from its background. At level AA, WCAG 2.1 requires a contrast ratio of at least 4.5:1 for normal text and at least 3:1 for large text. Light grey text on a white background often fails here. You can check the value with a contrast calculator.

Keyboard operation

All functions have to work without a mouse: menus, sliders, pop-ups, the basket. Focus must never get stuck anywhere. A cookie banner that can only be closed with a mouse click locks keyboard users out of the entire page.

Visible focus

When you jump through a page with the Tab key, you have to see where you are. Some designs remove the focus outline with CSS because it does not look nice, and keyboard users lose their bearings as a result. The focus order should also follow the reading order.

Clean heading structure

A page has one H1, followed by H2 and H3 in a logical order. Screen reader users jump from heading to heading, much as sighted people skim a text. Lists should be marked up as real lists, and tables should have header rows.

Forms with labels

Every input field needs a visible label that is linked to the field in the code. Placeholder text inside the field is not enough, because it disappears as soon as you type. Error messages should say what is wrong and how to correct it.

Videos with subtitles

Recorded videos with sound need subtitles. If a video shows important content only in the picture, audio description or a text version helps. For podcasts and audio-only recordings, a transcript makes sense.

Declare the language in the HTML

The html element states the main language of the page, so a German page uses lang="de". Without it, a screen reader may read German text with English pronunciation. If a section switches language, it gets its own lang attribute.

Never convey information through colour alone

People with colour vision deficiency will not notice a required field that is only marked in red. Add text, a symbol or an asterisk with an explanation to the colour. The same goes for links in running text: an underline makes them recognisable regardless of colour.

Link texts with a clear destination

Screen readers can list all the links on a page. If that list says "click here" or "more" five times, nobody knows where each link goes. Write link texts that make sense without the surrounding sentence, for example "Price list as PDF" or "Open contact form".

Plain language

Short sentences, familiar words and explained technical terms help people with cognitive impairments. They also help everyone reading in a language other than their mother tongue. For important content, a version in Easy Language can be useful. Easy Language follows its own rules and should be checked by trained people.

Clipboard with a ticked list next to symbols for image descriptions, contrast and keyboard use.
🤖 Image: AI-generated

How do you test your website for accessibility?

You can carry out a first review yourself. Set aside an hour for it and take your most important pages: the home page, a typical subpage, the contact form and, if you have one, the checkout process.

  • Keyboard test: put the mouse aside. Move through the page with Tab, Shift+Tab, Enter and the arrow keys. Can you reach everything? Is the focus always visible?
  • Screen reader test: many operating systems for computers and smartphones come with a built-in screen reader. Let it read a page aloud to you. You will soon notice whether images are described sensibly and whether the headings make sense as an outline.
  • Zoom test: enlarge the page a lot in your browser. Text should stay readable without content overlapping or disappearing.
  • Automated checkers: browser extensions and online checkers find missing alt texts, weak contrast or fields without labels. They only detect part of the problems, though. No program can judge whether an alt text makes sense.

For websites that fall under the BFSG, a self-test is usually not enough. An expert audit against EN 301 549 gives you more certainty and provides a basis for the information required under Annex 3. Ideally, plan accessibility in from the start of a relaunch. Fixing a theme and plugins afterwards takes more effort. The article Finding a WordPress agency covers what to look for when choosing a WordPress provider. If you are planning a website check anyway, you can test accessibility and security together: see the article Check website security.

Does an accessible website help with SEO?

Partly, yes. Some measures help people and search engines at the same time. According to Google, the search engine uses alt text together with image recognition and the page content to understand images. Google points out explicitly that good alt text also improves accessibility. It also warns against stuffing alt attributes with keywords.

A clear heading structure, descriptive link texts and clean HTML make content easier to process for screen readers and for crawlers alike. Subtitles and transcripts add extra text to videos. Taking accessibility seriously often improves the basics described in the article SEO for beginners as well. Do not expect a quick jump in rankings from it.

Summary

An accessible website can be used with a keyboard, a screen reader and magnification. Since June 2025, Germany's BFSG has made this mandatory for many online shops and other services with consumer contracts; micro-enterprises providing services are exempt. The benchmarks are EN 301 549 and WCAG 2.1. With the checklist and a keyboard test you can find the most common barriers yourself, while the legal assessment belongs in expert hands. You will find more background on our topic page Accessibility & Law.

Sources: Germany's Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) of 16.07.2021, §§ 1, 2, 3, 14, 33, 37 and Annex 3, gesetze-im-internet.de; Federal Accessibility Agency (Bundesfachstelle Barrierefreiheit) on the BFSG and on EN 301 549; Barrier-Free Information Technology Ordinance (BITV 2.0), § 7, gesetze-im-internet.de; W3C, "Web Content Accessibility Guidelines (WCAG) 2.1 is now a W3C Recommendation" (5 June 2018); W3C, "Web Content Accessibility Guidelines (WCAG) 2.2"; W3C WAI, "Introduction to Understanding WCAG 2.1"; W3C WAI, "Accessibility Principles"; W3C WAI, "How to Meet WCAG (Quick Reference)"; Google Search Central, "Image SEO Best Practices".

Frequently asked questions

Who has to provide an accessible website?

Under Germany's BFSG, mainly businesses that conclude contracts with consumers through their website or app, such as online shops. Micro-enterprises with fewer than ten employees and no more than €2 million in annual turnover or balance sheet total are exempt for services.

Since when has the BFSG applied?

The German act applies to services provided to consumers after 28 June 2025.

Does my purely informational website have to be accessible?

The BFSG does not explicitly mention purely informational sites without contract conclusion, and going by its wording they are probably not covered. Have your individual case checked by a specialist, especially if you offer bookings or orders.

What happens if my website is not accessible?

If it falls under the BFSG, the market surveillance authorities of the German federal states can step in. The fine can be up to €100,000.

Do I need an accessibility statement?

The BFSG requires the information listed in Annex 3, such as how the service meets the requirements and which authority is responsible. Although often used as the name for this page, the German word Barrierefreiheitserklärung (accessibility statement) does not appear in the act.

How can I check whether my website is accessible?

Test the page using only the keyboard, let a screen reader read it aloud and run an automated checker. For a reliable assessment against EN 301 549 you need experts.