Germany’s Accessibility Act: When Your Website Must Comply — and What That Means

What the law requires — and from whom

The BFSG implements an EU directive and obliges providers of certain products and services to make them accessible. What matters is the audience: the law targets services offered to consumers through electronic commerce. An online shop, a booking system, a customer portal or banking services fall within its scope.

A plain brochure website with no ordering or booking function, aimed exclusively at business clients, is generally not covered. That is exactly why it pays to look closely at your own site: the moment an appointment booker, a shop or a consumer login is built in, the assessment changes.

The micro-enterprise exemption — and its catch

For services there is an exemption for micro-enterprises. It only applies if both conditions are met at the same time:

• fewer than 10 employees, and
• no more than 2 million euros in annual turnover or balance sheet total.
• Important: the exemption covers services — it does not apply when you distribute products that fall under the act.
• Equally important: it can lapse. Grow past the threshold and the obligation applies, without anyone notifying you.

What accessible means technically

The benchmark is the European standard EN 301 549, which for web content points to WCAG 2.1 Level AA. That sounds abstract but translates well:

• Anything that works with a mouse must work with a keyboard — and the focus must be visible.
• Text needs sufficient contrast against its background (at least 4.5:1 at normal size).
• Images need meaningful alternative text, videos need captions.
• Forms need real labels and error messages that explain what to do.
• The page must remain usable at 200 % zoom and readable with a screen reader.

The five mistakes I find almost every time

• Grey helper text on a white ground — looks elegant, fails on contrast.
• Form fields with only a placeholder instead of a real label. Start typing and the label is gone.
• Menus, sliders and modals that can only be opened or closed with a mouse.
• Decorative images with alt text and meaningful images without — exactly the wrong way round.
• Headings chosen for looks rather than structure: three H1s on one page, no H2 in between.

How a project actually runs

It starts with an audit: automated tests cover the measurable points, and I find the remaining 40 per cent manually with keyboard and screen reader. That produces a prioritised list — what is legally critical, what genuinely blocks users, and what is cosmetic.

For a normal company website the work is usually smaller than feared: contrast, focus styles, form labels and heading structure cover most of it. At the end you get a documented accessibility statement, so you have something to show if anyone asks.