IIDigital MarketingAnalysis
Accessible Website: What Germany’s Accessibility Act Requires
Since June 28, 2025, Germany’s Accessibility Strengthening Act has required many companies to have accessible websites and apps. Many small businesses wonder whether they are affected. This analysis shows who the law applies to, what it requires and what makes sense even without an obligation.
Key takeaways
- The Accessibility Strengthening Act (BFSG) has applied since June 28, 2025, to certain products and services for consumers, including ordering, booking and payment functions on websites.
- Micro-enterprises with fewer than ten employees and no more than two million euros in turnover or balance sheet total are exempt for services. Purely B2B offerings are widely considered to fall outside the law if consumers are effectively excluded.
- The thinking model of the Web Content Accessibility Guidelines has four principles: perceivable, operable, understandable, robust.
- Studies find errors on most websites examined, above all missing image descriptions and empty links. Many of them can be fixed with little effort.
Why the topic reaches small businesses too
For a long time, accessibility was considered a task for public authorities. Public bodies in Germany have been required for years to make their websites accessible. With the Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG), this has changed for parts of the private sector. It implements an EU directive, the European Accessibility Act, and has applied since June 28, 2025. Since then, contradictory statements have been circulating among owners: some consider every website affected, others see the law as a topic only for online retailers.
This analysis therefore answers one question: What does the Accessibility Strengthening Act require, which businesses does it apply to, and what should a small business do regardless of the obligation? To answer it, we first clarify the scope and the exemptions, then the model by which accessibility on the web is assessed. Then we look at what studies show about the state of websites and weigh obligation against benefit. The article is a general overview based on German law and is not legal advice.
A website that not everyone can use does not only lose people with disabilities. It loses everyone who has only one hand free, poor eyesight or little time at that moment.
Who the law applies to and who it does not
The BFSG covers certain products, such as computers, smartphones, ATMs and ticket machines, and certain services provided to consumers. For websites, one group matters most: e-commerce services. These are offerings through which consumers can conclude a contract electronically, meaning online shops, booking and ordering processes and payment functions. According to specialist law firms, even a simple online appointment booking can bring an offering within scope. Whether a contact form alone is enough is disputed (Heuking 2025).
| Situation of the business | First assessment | What to check |
|---|---|---|
| Online shop or booking for private customers, ten or more employees or over two million euros turnover | usually covered | Implement the requirements, publish information on accessibility |
| As above, but a micro-enterprise | exempt for services | Check size precisely; products sold may still be covered |
| Purely B2B shop that effectively excludes consumers | widely considered not covered | Whether consumers are excluded technically and in practice, not just in the terms and conditions |
| Pure presentation of the business without contract conclusion | usually not covered | Whether functions such as appointment booking or ordering are offered |
| Mixed offering for businesses and private customers | more likely covered | Which parts of the website consumers can use |
The exemption for micro-enterprises only applies to services. Micro-enterprises are businesses with fewer than ten employees and annual turnover or an annual balance sheet total of no more than two million euros. For B2B businesses: purely business-to-business offerings are widely considered to fall outside the law. A note in the terms and conditions is not enough, however, if anyone can complete the ordering process. Anyone who wants to rely on this exemption should have the setup reviewed by a professional.
Source: Heuking (2025), BFSG
The thinking model: four principles of accessible web content
How accessible a website is, is assessed internationally according to the Web Content Accessibility Guidelines, WCAG for short. For the BFSG, specialist law firms recommend version 2.1 at level AA as the yardstick, because compliance with it is presumed to meet the requirements. The guidelines assign all criteria to four principles, abbreviated POUR. The model helps to check a website even without a law, because it asks where a visitor could fail.
Perceivable
Content must be perceivable with at least one sense. Images have a text description, videos have captions, text has enough contrast with the background and can be enlarged.
Operable
All functions must be usable without a mouse, for example with the keyboard. Buttons are large enough, nothing times out before you can react, nothing flashes rapidly.
Understandable
Texts are clear, operation is predictable, forms explain what to enter, and errors are reported understandably.
Robust
The page is technically built so that assistive technologies such as screen readers can read it correctly: real headings, labeled links and fields, clean code.
Behind the model is an idea that research calls the social model of disability. According to it, a disability does not arise from an impairment alone, but from the environment not being adapted to it. A website without image descriptions disables a blind visitor; a website with descriptions does not. For a business, this is a useful perspective, because it places responsibility where the business can change something.
How accessible are websites? What studies show
Giummarra and colleagues (2025) examined the websites of 124 health services in Australia that care for people after a stroke. Homepages and service pages were checked with an automated tool against WCAG 2.1 at level AA and with a checklist of their own for needs after a stroke. 150 of the pages examined, or 81.1 percent, had at least one error, with a median of five per page. The most common errors were easy to fix.
Source: Giummarra et al. (2025)
Other studies reach similar results. A review of the career pages of companies on the Turkish Fortune 500 list against WCAG 2.1 found that most pages did not even meet the basic level A, along with broken links and problems on smartphones (Macakoğlu, Güler and Peker 2025). A study of the 100 leading hotel websites found barriers mainly in text alternatives, navigation and technical robustness (Singh, PS and Bashir 2025).
The limits are clear. All three studies use automated testing tools that capture only some of the criteria. They look at health services, large corporations and hotels, not at small German businesses. The direction is nevertheless unambiguous: most websites have barriers, and the most common ones are not major technical projects but missing descriptions and labels.
Obligation or benefit: two views
The first view sees accessibility as an obligation that is met when the law requires it, and otherwise not. For a B2B business without an online shop, this means: no need for action. The second view sees accessibility as a quality feature that benefits all visitors. Good contrast helps in sunlight on a smartphone, large buttons help on the go, clear headings help anyone searching quickly, captions help anyone in an open-plan office without headphones.
Only as an obligation
- Question: am I affected?
- Yardstick: the law
- One-off implementation, often under time pressure
- Benefit: no fine, no warning letter
- Reaches only the mandatory parts of the website
As a quality feature
- Question: who fails at my website today?
- Yardstick: the four principles
- Step-by-step implementation with every change
- Benefit: more visitors reach their goal
- Works across the whole website
I consider the second view the wiser one, even for businesses that are not legally affected. The reason is sober: many accessibility measures are the same ones that make a website better anyway. The article A website that generates inquiries also calls for clear headings and labeled fields, and real headings help search engines, as the article The FAQ page shows. Demographics add to this. Many decision makers in customer businesses are older, and problems with eyesight and fine motor skills increase with age. The article Demographic change in the customer base describes how the age structure of customer business owners is changing.
What a small business can do in concrete terms
For businesses that fall under the law, there is no way around a professional review against WCAG 2.1 AA and publishing information on accessibility. For everyone else, there is a pragmatic way in with the most common errors. It takes a few hours and improves the website for everyone.
- Describe images: Every image that carries information has a short alternative text. Purely decorative images are marked as such.
- Label links and buttons: No link and no button without text. Instead of “here”, the text says where the link leads.
- Use real headings: Headings are marked up as such and follow an order, not just set in bold.
- Check contrast: Text stands out clearly from the background, including light gray text on a white background.
- Label forms: Every field has a visible label, error messages say what to do. What a good form looks like is described in the article The inquiry path on the website.
- Test with the keyboard: Go through the most important page once using only the Tab key. Can you reach every button, and can you see where you are?
- Test zoom: Enlarge the page to 200 percent. Does everything remain readable and usable?
- Check the cookie notice: It can be operated with the keyboard and does not permanently cover the content.
Automated testing tools find some of these errors in a few minutes. But they do not replace testing by people, because they cannot judge, for example, whether an image description makes sense. Many of the measures also improve load time or usability on smartphones, as the article Website load time describes.
What follows beyond the individual case
The BFSG is an example of how regulation makes visible a task that was previously considered voluntary. For businesses that are affected, it creates effort with a deadline. For everyone else, it creates a benchmark. When large shops and banks become accessible, users get used to it, and a website without image descriptions and contrast will soon look as outdated as one that does not work on a smartphone. How a new booking tool can affect obligations is therefore one of the questions to ask when choosing a tool, as the article Online appointment booking describes.
The limits of this analysis are clear. The legal situation is new, and authorities and courts have not yet decided many questions of scope. The studies cited come from Australia, Turkey and the hotel industry and use automated tools. How many additional inquiries an accessible website brings is not documented for small B2B businesses. What is documented is that most websites today have barriers and that the most common ones can be fixed with little effort.
Conclusion and next steps
The guiding question was what the Accessibility Strengthening Act requires, who it applies to and what a small business should do regardless. The answer: since June 28, 2025, the law has required accessible e-commerce services for consumers, meaning above all shops, bookings and payment functions, measured in practice against WCAG 2.1 AA. Micro-enterprises are exempt for services, and purely B2B offerings that effectively exclude consumers are widely considered exempt as well. Regardless of the obligation, starting with the most common errors pays off, because it makes the website better for all visitors.
- Check whether the website offers ordering, booking or payment functions for consumers.
- Compare the number of employees, turnover and balance sheet total with the limits for micro-enterprises.
- If in doubt, get a professional assessment before extending functions.
- Check the most important page with an automated tool and with the keyboard.
- Fix all images without alternative text and all links without text.
- Introduce a rule: no image and no form field goes online without a description.
For many small businesses, accessibility is not an obligation. But it is almost always a sign that someone has thought of all visitors.
Frequently asked questions
Does the German Accessibility Strengthening Act apply to my website?
That depends on whether you offer e-commerce services to consumers, such as an online shop, booking or payment function, and whether you are a micro-enterprise. Pure presentation websites without contract conclusion are usually not covered. If in doubt, get professional advice; this is not legal advice.
Are B2B websites exempt from the BFSG?
Purely B2B offerings aimed exclusively at businesses are widely considered to fall outside the law. The condition is that consumers are actually excluded; a note in the terms and conditions is not enough if anyone can order. Mixed offerings are more likely to be covered.
What is a micro-enterprise under the BFSG?
A business with fewer than ten employees and annual turnover or an annual balance sheet total of no more than two million euros. The exemption only applies to services. Anyone who manufactures or sells products covered by the law must meet the requirements for those products regardless of size.
Which standard applies to accessible websites?
In practice, the yardstick is the Web Content Accessibility Guidelines, WCAG 2.1, at level AA. They assign the requirements to four principles: perceivable, operable, understandable and robust.
What are the most common errors on websites?
Studies mainly find empty links without text, images without a text description, buttons without labels, form fields without a label and insufficient contrast. Most of these can be fixed with little effort once you know about them.
Sources
- Giummarra, M. J.; Brown, E.; Rose, T. A. et al. (2025): How accessible are the websites of health services for people who have had a stroke? International Journal for Equity in Health, 24(1), 1-15.
- Macakoğlu, Ş. S.; Güler, S.; Peker, S. (2025): Accessibility evaluation of corporates' human resources and career management web pages: The case of Türkiye. Journal of Internet Applications & Management, 16(2), 2-26.
- Singh, R.; PS, S.; Bashir, A. (2025): Inclusion or exclusion: Evaluation of hotel websites from an accessibility perspective. Tourism & Hospitality Research, 25(2), 304-310.
- Heuking (2025): Digital accessibility: what companies have had to observe since June 28, 2025. Article of July 9, 2025 (in German).
Note. This article is a general overview of the German Accessibility Strengthening Act and not legal advice. Many questions of scope have not yet been conclusively settled. Check the current status with professional support before making decisions.
