What the BFSG is, in one paragraph
The BFSG is Germany's implementation of the European Accessibility Act (Directive 2019/882). The Directive sets EU-wide requirements for certain products and services; each member state passes its own law to enforce them. Germany's version took effect on 28 June 2025 and covers, among other things, e-commerce services aimed at consumers.
Does it apply to my shop?
Two questions decide most cases:
- Do you sell to consumers in Germany? The law follows the market, not your company's address. A Latvian, Polish or Dutch shop selling to German consumers is in scope of the German rules for that market.
- Are you a micro-enterprise? The BFSG contains an exemption for very small businesses providing services — broadly, fewer than 10 people and under €2m annual turnover. Whether it covers your specific setup is a legal question for your counsel, not something a tool can decide for you.
This page is information, not legal advice. Scope, exemptions and enforcement depend on your specific business. Ask a qualified lawyer before drawing conclusions about your own liability.
Which standard actually decides
The law does not describe buttons and contrast ratios. It points to the harmonised European standard EN 301 549, which for web content builds directly on WCAG 2.1 level AA. That is the practical checklist: if your storefront meets WCAG 2.1 AA, you are working against the same criteria the standard uses.
This is also why the work travels: one set of fixes applies whether you sell to Germany, France, Spain or any other EU market. The national laws differ — the technical standard behind them does not.
What a Shopify store owner runs into first
Across 25 European storefronts we scanned while building our tool, the median was 14 significant issues per store, and not one came back clean. The recurring ones are boringly consistent:
| Issue | Why it matters | Typical cause in a Shopify theme |
|---|---|---|
| Images without alt text | Screen-reader users hear a file name or nothing at all | Product images uploaded without descriptions |
| Low colour contrast | Text unreadable for people with low vision | Brand palette applied to small text and buttons |
| Icon-only links and buttons | Assistive tech announces “button” with no purpose | Cart, search and social icons without labels |
| Form fields without labels | Users cannot tell what to type where | Newsletter and checkout-adjacent widgets |
| Missing page language or title | Wrong pronunciation; tabs indistinguishable | Custom or heavily edited layout files |
The accessibility statement
Alongside the technical work, the law expects you to be transparent: publish information about the accessibility of your service, including a working feedback channel where users can report barriers. In practice that means a page on your store that states what the service does, what is known to be limited, and how to contact you — kept current, with a date.
A statement is only as good as the facts behind it. Publishing “fully accessible” without evidence is worse than publishing an honest one that names known limitations.
Where to start this week
- Measure honestly. Run an automated check to see what is broken and how much of the standard was actually tested. Automated testing covers only a portion of the criteria — treat the result as a prioritised starting point.
- Fix the top of the list. Contrast, alt text and unlabelled controls usually account for most occurrences and are the cheapest to resolve.
- Write things down. Keep a dated record of what you found and what you changed. If anyone ever asks, evidence of good-faith action is what you have.
- Get human review for what machines cannot judge. Whether alt text is meaningful, whether the reading order makes sense, whether error messages help — those need a person.
See where your store stands — free, no install
Enter your domain and get a check against WCAG 2.1 AA and EN 301 549 in about 30 seconds. No account needed.
Run the free checka11y-guard is a tool, not a legal service, and does not guarantee compliance with the BFSG, the EAA or any other law. Automated testing detects only a portion of accessibility issues and does not replace an expert audit or testing with people who use assistive technology.