Accessible for Everyone - What the BFSG Means for Your Online Shop
What Is the BFSG?
The German Accessibility Strengthening Act (BFSG) implements the European Accessibility Act (EAA) into German law. It requires companies to make certain digital products and services accessible - including online shops.
The technical implementation is based on the international Web Content Accessibility Guidelines (WCAG) 2.1 - Level AA, a globally recognized standard for web accessibility.
More information is available from the Federal Ministry of Labour and Social Affairs and the Federal Accessibility Office.
Who Is Affected?
The BFSG generally applies to all B2C online shops – unless the company qualifies as a microenterprise. This is only the case if both of the following criteria are met:
- Less than 10 full-time equivalent employees
- Less than €2 million in annual turnover
These thresholds are based on EU Recommendation 2003/361/EC.
If either of these thresholds is exceeded, the company no longer qualifies as a microenterprise and is required to comply with the BFSG.
Companies that operate exclusively in the B2B sector are not affected by the BFSG.
Why Even Non-Obligated Shops Should Take Action
Even if your shop is not formally obligated under the BFSG, accessibility pays off both socially and commercially:
- Better usability for everyone: Accessibility improves user-friendliness for all users. An accessible site is often easier to use for older people, mobile users, or those with temporary impairments.
- Broader reach: Accessibility opens up user groups that would otherwise be excluded from shopping.
- Higher conversion rates: Enabling more people to use your shop increases the chances of purchases.
- Strong signal for inclusion: Shows that your company is forward-thinking and socially responsible. Accessibility may be a key factor in tenders or partnerships.
- SEO benefits: Many accessibility improvements (e.g., semantically clean HTML, alt texts) enhance visibility on Google.
What Accessibility Means for E-Commerce
Accessibility involves technology, content, and design. It supports people with a wide range of needs, for example, users with visual, hearing, or motor impairments who rely on assistive technologies such as screen readers, Braille displays, or voice control.
Here are some key requirements:
- Alt texts for images (required for screen readers)
- Sufficient color contrast, clear visual structure, and easily readable fonts
- Keyboard operability (no mouse needed)
- Easy-to-understand language, also for users with cognitive impairments
- No auto-advancing content without user interaction (e.g., automatic slideshows)
- Clearly labeled links (“Go to cart” instead of “Click here”) or additional link title attributes
- Accessibility statement, permanently and visibly linked on the website (e.g., in the footer)
- 👉 Trusted Shops offers a suitable template in their Legal Text Generator
This list is not exhaustive. What’s required depends on your shop, audience, and tech setup.
Complete accessibility is hardly achievable in practice. The goal is a shop with as few barriers as possible - and improvement is an ongoing process.
Magento & Accessibility - A Current Assessment
Magento out of the box does not provide a particularly good foundation for accessibility, as it was never developed with that focus.
Magento 1
- Outdated software, no longer maintained
- Many incompatible modules
- Accessibility only achievable with very high effort or not at all
Magento 2
- More modern but still not WCAG-compliant by default
- Themes and modules often lack accessibility
- Many areas require manual adjustments
- Achieving accessibility requires significant effort
Hyvä
- From version series 1.3.x onwards developed with accessibility in mind
- If you’re already using Hyvä, but an older version, consider upgrading
- Offers a much better starting point
- Third-party modules and customizations still need review
What Shop Owners Should Do Now
- Check BFSG relevance (employee count, revenue, B2C/B2B)
- Create and link your accessibility statement
- Review CMS content: alt texts, link texts, plain language
- Analyze design - adjust if necessary
- Continuously monitor content – accessibility is not a one-time project
Accessibility via Overlay?
Recently, so-called accessibility overlays have been increasingly promoted as an “easy fix” for accessibility - tools like DigiAccess or AccessiBe, for example. They can be quickly integrated into existing shops, add extra features like contrast switches or larger fonts, and promise to make the site “automatically accessible”.
Sounds good at first - or does it?
Why these tools are problematic:
- No real accessibility: Accessibility overlays act only as a visual layer on top of the website but do not fix structural barriers in the code, such as missing labels, unclear ARIA roles, or non-functional keyboard navigation. These fundamental issues in HTML and semantics are crucial for users of screen readers and other assistive technologies.
- Not sufficient for legal requirements: The requirements of the BFSG and the underlying WCAG 2.1 request that a site must be permanently and independently accessible without relying on additional tools. An overlay does not fulfill this requirement.
- Questionable user experience: Many people who rely on assistive technologies find such overlays disruptive - they are often difficult to use properly or interfere with existing accessibility aids.
- Typical for closed systems: These tools are especially common on platforms like Shopify, where developers have limited access to the theme and code. With systems like Magento, however, there is the possibility to implement accessibility properly and sustainably - directly in the code, where it really matters.
Overlays are no shortcut to accessibility; they’re more like a band-aid on an open wound. Anyone who wants to comply with the BFSG and provide truly accessible access to all users cannot avoid a careful implementation in the frontend.
How We Can Support You
As an agency, we are happy to help with:
- Analysis of your shop regarding accessibility
- Technical implementation (e.g., keyboard navigation, contrasts, structure)
- Design adjustments according to your requirements
- Integration of the accessibility statement
- Support and maintenance to keep future extensions accessible
What Happens If You Ignore It?
- Legal risks: Fines, warnings, or lawsuits are possible
- Reputational damage: Accessibility is increasingly perceived as a quality feature and sign of social responsibility
- Real-world consequences: For users who rely on assistive technologies, an inaccessible shop can be virtually unusable
But: Not everything has to be perfect by June 28, 2025. It’s enough to meet key requirements and communicate future improvements transparently in your accessibility statement.
Conclusion
The BFSG is more than a legal obligation. It’s a real opportunity for forward-ready, inclusive online stores. Acting early brings long-term benefits - legally, financially, and socially. Quick fixes like accessibility overlays may seem tempting, but real accessibility requires thoughtful implementation in the code and an understanding of all users’ needs.
Accessibility is not a trend but a quality feature with a future - it makes your shop accessible to people who were previously excluded. Reaching more people means selling more.
If you have questions or need support: Get in touch. Together, we’ll make your shop truly accessible! 🚀