BFSG Checklist 2026: Making Your Website Accessible — What Small Businesses Really Need to Do

In August 2025, the first cease-and-desist letters landed in the mailboxes of German online retailers — a flat 595 euros per case. In February 2026, a second wave followed, this time with demands around 2,700 euros. And since January 2026, Germany’s Market Surveillance Authority (MLBF) has been actively checking whether websites meet legal accessibility requirements.

The Barrierefreiheitsstärkungsgesetz (BFSG) — Germany’s Accessibility Strengthening Act — has been in force since June 28, 2025. The grace period is over. Yet 99% of German online shops fail a complete accessibility audit — and most operators don’t even know if they’re affected.

This post isn’t another legal text. As a web designer who builds websites for small businesses every day, I’ll explain what you concretely need to do: which requirements actually apply, which errors are most common, what you can fix yourself — and what it costs.

What Is the BFSG?

The Barrierefreiheitsstärkungsgesetz is Germany’s national implementation of EU Directive 2019/882 (European Accessibility Act). It requires businesses to make their digital products and services accessible — meaning people with disabilities can use them equally.

Technically, the BFSG references the European standard EN 301 549, which in turn incorporates WCAG 2.1 Level AA. This means: your website must meet all WCAG success criteria at levels A and AA. An update to WCAG 2.2 is expected in the next revision of EN 301 549 — implementing WCAG 2.2 now puts you on the safe side.

The critical difference from previous legislation: Germany’s BITV 2.0 only applied to public sector websites. The BFSG extends accessibility requirements to the private sector for the first time.

Who Is Affected? And Who Isn’t.

This is the question that dominates every Reddit thread on the topic — and the one most frequently answered incorrectly.

Affected:

• Online shops and e-commerce — any website where a contract can be concluded
• Online banking and financial services
• Telecommunications services
• Electronic ticketing (concerts, trains, flights)
• E-book platforms
• Booking systems — doctor, hotel, car rental, if they work toward a contract conclusion
• Mobile apps falling under the above categories

Not affected:

• Pure B2B websites — offerings exclusively targeting business customers
• Purely informational websites without transaction functionality (no shop, no booking, no contract conclusion)
• Content predating June 28, 2025 — existing products/services that were on the market before this date and haven’t been substantially changed since

The Micro-Enterprise Exemption

Micro-enterprises are exempt from service obligations if they meet both criteria:

1. Fewer than 10 employees
2. Maximum 2 million euros annual revenue or balance sheet total

But beware — three common misconceptions:

• The exemption only applies to services, not products. If you sell physical products with a digital component, product obligations still apply.
• “Under 10 employees” alone is not enough. Both criteria must be met simultaneously.
• The exemption does not protect against competition law cease-and-desist letters from competitors. A competitor can send you a cease-and-desist even as a micro-enterprise.

My recommendation: Even if you’re formally exempt — implementing accessibility basics costs little but delivers better user experience, better SEO, and protection against future tightening. The EU Commission already issued a supplementary reasoned opinion against Germany in March 2026 for insufficient implementation.

What Happens If You Don’t Comply?

Official Sanctions

The Market Surveillance Authority (MLBF) can order:

Measure	Details
Fine	Up to 100,000 euros for serious violations
Fine (formal violations)	Up to 10,000 euros for missing documentation
Distribution ban	Ban on offering non-compliant products/services

Cease-and-Desist Letters from Competitors

Beyond official fines, there’s the cease-and-desist risk:

Wave 1 (August 2025): The law firm CLAIM sent cease-and-desist letters on behalf of “die-website-experten.de” — demand: ~595 euros. Legally assessed as challengeable.

Wave 2 (February 2026): Law firm MK (Berlin) with detailed audit reports — demand: ~2,700 euros. Assessed by experts as significantly more serious.

Over 500 proceedings are predicted for 2026. The first court rulings on whether BFSG violations are actionable under competition law (UWG) are expected in the second half of 2026.

The BFSG Checklist: What Your Website Needs

The WCAG has over 80 success criteria. But not all are equally important. This prioritized checklist is sorted by the principle: What fails most often and is easiest to fix comes first.

According to the WebAIM Million Report 2026, 96% of all errors fall into just six categories:

Error Type	Affected Pages	WCAG Criterion
Insufficient color contrast	83.9%	1.4.3
Missing image alt text	53.1%	1.1.1
Missing form labels	51.0%	1.3.1 / 3.3.2
Empty links	46.3%	2.4.4
Empty buttons	30.6%	4.1.2
Missing document language	13.5%	3.1.1

Priority 1: Quick Wins (Fix 80% of Errors)

Set the document language. The simplest fix — one line:

<html lang="de">

Without this attribute, no screen reader knows which language to use for reading aloud. 13.5% of all websites forget this.

Alt text for all images. Every informative image needs a descriptive alt text. Decorative images get an empty alt="" so screen readers skip them.

<!-- Informative image -->
<img src="/team.webp" alt="Three team members discussing a project at a whiteboard" />

<!-- Decorative image -->
<img src="/divider.svg" alt="" role="presentation" />

Check color contrast. Normal text needs at least a 4.5:1 contrast ratio, large text (18px bold or 24px regular and above) at least 3:1. UI elements like icons and form borders also need at least 3:1.

This is where many businesses start sweating over their brand colors. A Reddit user puts it bluntly: “Our CI colors give us extreme headaches with contrast.”

The solution: Don’t change the brand color, adjust how it’s used. Don’t use light accent colors as text on white backgrounds — use them as backgrounds with dark text on top.

Link form labels. Every input field needs a programmatically associated label:

<!-- Wrong -->
<input type="email" placeholder="Email address" />

<!-- Right -->
<label for="email">Email address</label>
<input type="email" id="email" name="email" />

Placeholder text is not a label. Screen readers don’t reliably read it, and it disappears when typing.

Fill empty links and buttons. Links without text (e.g., icon-only buttons) need an aria-label:

<!-- Wrong -->
<a href="/cart"><svg>...</svg></a>

<!-- Right -->
<a href="/cart" aria-label="Open shopping cart"><svg aria-hidden="true">...</svg></a>

Priority 2: Keyboard Accessibility

This is where most websites completely fail. The Aktion Mensch study 2025 shows: Only 20 out of 65 tested German shops were keyboard-navigable.

Everything must be reachable via keyboard. Every link, every button, every form field. Tab key to move forward, Shift+Tab to go back, Enter/Space to activate.

Don’t hide focus indicators. Many websites remove the browser’s focus ring for aesthetic reasons (outline: none). This makes the site unusable for keyboard users.

/* Don't do this */
*:focus { outline: none; }

/* Better: Custom focus ring that fits the design */
:focus-visible {
  outline: 3px solid var(--color-accent);
  outline-offset: 2px;
  border-radius: 2px;
}

:focus-visible only shows the ring during keyboard navigation, not on mouse clicks — keeping the design clean.

Logical tab order. The tab order should follow the visual layout. If you reposition elements via CSS (order, position: absolute), check the tab order manually.

Focus must not be obscured. Since WCAG 2.2 (criterion 2.4.11): The focused element must not be hidden behind sticky headers, cookie banners, or overlays. Test your site with an open cookie banner and tab navigation.

Priority 3: Semantic HTML

Maintain heading hierarchy. H1 → H2 → H3, without skipping levels. An H3 without a preceding H2 confuses screen reader users who navigate by heading.

Use landmarks. Screen reader users jump via landmarks — use the correct HTML5 elements:

<header>   <!-- Site header -->
<nav>      <!-- Navigation -->
<main>     <!-- Main content -->
<aside>    <!-- Sidebar -->
<footer>   <!-- Site footer -->

Mark up lists as lists. Navigation links, feature lists, and enumerations belong in <ul> or <ol> — not in a series of <div> elements.

Tables with headers. Data tables need <th> elements with scope="col" or scope="row":

<table>
  <thead>
    <tr>
      <th scope="col">Service</th>
      <th scope="col">Price</th>
    </tr>
  </thead>
  <tbody>
    <tr>
      <td>Website audit</td>
      <td>free</td>
    </tr>
  </tbody>
</table>

Priority 4: Forms and Error Messages

Name errors clearly. When a form fails, the error message must describe what went wrong and how to fix it. “Error” alone isn’t enough — “Please enter a valid email address” is.

<label for="email">Email address</label>
<input type="email" id="email" aria-describedby="email-error" aria-invalid="true" />
<p id="email-error" role="alert">Please enter a valid email address (e.g., name@example.com)</p>

Mark required fields. Not just visually (asterisks), but also programmatically:

<label for="name">Name <span aria-hidden="true">*</span></label>
<input type="text" id="name" required aria-required="true" />

Priority 5: Media and Content

• Add subtitles to videos (or provide a transcript)
• Make animated content pausable — carousels, animations, and auto-play videos need a stop button
• Touch targets at least 24×24 CSS pixels (WCAG 2.2, criterion 2.5.8) — especially relevant for mobile navigation
• No color-only information — “Red fields are required” doesn’t work for colorblind users

Making Your Website Accessible — Step by Step

Step 1: Analyze the Current State (30 Minutes)

Open your website and run these three quick tests:

1. Install the WAVE browser extension and run it on every page template. WAVE displays errors as visual overlay icons directly on the page — contrast issues, missing alt text, empty links, everything at a glance.

2. Keyboard test: Put the mouse away. Navigate your entire website using only Tab, Enter, and Escape. Can you reach everything? Can you always see where the focus is? Can you open and close the menu?

3. Lighthouse Accessibility Audit: Chrome DevTools → Lighthouse → check only “Accessibility” → run analysis. The score shows your baseline.

Step 2: Implement Quick Wins (2–4 Hours)

Fix the Priority 1 errors from the checklist:

• Set lang="de"
• Add alt text for all images
• Associate form labels
• Add aria-label to empty links and buttons
• Check and fix color contrasts

These measures alone typically fix 60–80% of all automatically detectable errors.

Step 3: Keyboard and Structure (4–8 Hours)

• Implement focus indicators (:focus-visible)
• Check and fix tab order
• Clean up semantic HTML (landmarks, heading hierarchy)
• Test cookie banners and sticky elements for focus obscuring

Step 4: Publish an Accessibility Statement

The BFSG requires a Barrierefreiheitserklärung (accessibility statement) — similar in legal standing to an imprint or privacy policy. It must:

• Be linked in the footer (like imprint and privacy policy)
• Describe the current state of accessibility
• Name known limitations
• Include a feedback mechanism (contact option to report barriers)
• Name the responsible market surveillance authority
• Be accessible itself

The statement doesn’t need to be perfect. It needs to be honest. “We’re working on accessibility, these areas aren’t yet optimized, here’s how to report barriers to us” — that’s a perfectly acceptable status.

Step 5: Monitor Continuously

Accessibility isn’t a one-time project. Every new blog post, product page, or content update can introduce new errors — an image without alt text, a button without a label. Schedule monthly quick checks with WAVE or axe, or integrate automated tests into your deployment process.

Testing Accessibility: The Right Tools

Free Tools for Getting Started

Tool	Type	Strength	Limitation
WAVE	Browser extension	Visual error overlay, immediately understandable	Can’t detect interaction issues
axe DevTools	Browser extension	Deepest WCAG coverage, EN 301 549 rules	Free version limited
Lighthouse	Built into Chrome	Quick overview, no setup needed	Less thorough than axe/WAVE
Pa11y	CLI tool (Node.js)	CI/CD integration, automated tests	Requires technical setup

Important: Automated Tools Only Find Half the Issues

According to a Deque study, automated scans only capture about 57% of all accessibility issues. The rest requires manual testing:

• Walk through keyboard navigation (Tab, Enter, Escape)
• Test with a screen reader — VoiceOver on Mac (CMD+F5), NVDA on Windows (free)
• Zoom to 200% — all content must remain readable, no horizontal scrolling
• Contrast checker for UI elements that automated tools miss

My approach: WAVE for a quick overview, axe DevTools for technical depth, then 15 minutes of manual keyboard testing. This catches 90% of all practically relevant issues.

Special Case: Online Shops and Shopify

Online shops are most heavily affected by the BFSG — by definition they are “services in electronic commerce” where contracts are concluded.

The Problem with Themes

The reality is sobering: In a test by apoio digital, 47 out of 50 Shopify themes marketed as “accessible” failed basic WCAG checks. Typical errors:

• 89% missing alt text on product images
• 54% contrast failures in buttons and links
• Checkout not screen reader operable — one of Germany’s largest shop systems never had a fully accessible checkout
• Cookie banners block focus navigation

What You Can Do on Shopify

1. Theme audit: Start with WAVE on the homepage, a product page, the cart, and checkout. Note all errors.
2. Alt text in Shopify Admin: Under “Products” → click image → enter alt text. This isn’t an optional SEO bonus — it’s a legal requirement.
3. Customize theme code: Missing labels, ARIA attributes, and focus styles must be added in Liquid code. The Dawn theme is the best starting point.
4. Check third-party apps: Every app that injects frontend elements (reviews, pop-ups, upsells) can break accessibility. Test each one individually.
5. Checkout: With Shopify Plus, you can customize the checkout. On the standard plan, you’re dependent on Shopify’s own accessibility updates — check the Shopify Changelog.

Why Overlay Tools Are Not a Solution

EyeAble, accessiBe, UserWay — the promises sound tempting: “Add one script, instantly accessible.” The reality:

• accessiBe was fined by the US Federal Trade Commission for misleading accessibility claims
• In a WebAIM survey, 72% of respondents with disabilities said overlays were not effective
• Overlay tools were cited as inadequate in over 1,000 lawsuits in 2024
• Germany’s DBSV (German Federation of the Blind and Partially Sighted) explicitly advises against them

The reason is technical: An overlay cannot retroactively create semantic HTML, add missing form labels, or fix broken keyboard navigation. It layers cosmetic fixes over structural problems.

Overlays solve accessibility the way a band-aid solves a broken bone. The actual problems — missing semantic HTML, broken keyboard navigation, insufficient contrast — remain. Invest the money in real fixes instead.

What Does Accessibility Cost?

The most frequently asked question — and the one most rarely answered honestly.

Scope	What’s Included	Cost
DIY	Alt text, labels, lang attribute, contrasts	0 euros + 4–8 hours of time
Quick-fix package	Audit + fix the 20 most common errors	500–2,000 euros
Comprehensive implementation	Full audit, code adjustments, accessibility statement, training	2,000–8,000 euros
Professional BITV test	92 test steps by certified BIK auditors	3,000–6,000 euros
Ongoing monitoring	Monthly scans, regression tests, updates	50–200 euros/month

The Pragmatic Approach

Most small businesses don’t need a 6,000-euro BITV test. What they need:

1. An audit listing concrete errors — prioritized by severity
2. Fixing the top 20 errors — that gets you 80% of compliance
3. An accessibility statement that honestly communicates where you stand
4. A monthly quick check to ensure new content doesn’t introduce errors

For a typical 5-page website with a contact form, the total effort is 500–1,500 euros for the initial implementation. That’s less than a single cease-and-desist letter from the second wave.

Accessibility and SEO: The Double Win

Accessibility and search engine optimization overlap more than most people think. A study by open.de shows: WCAG-compliant pages achieve 23% more organic traffic and rank for 27% more keywords than non-compliant pages.

This is because of shared fundamentals:

Accessibility	SEO Benefit
Image alt text	Google understands image content
Semantic headings (H1–H6)	Clear content structure for crawlers
Descriptive link text	Better anchor text signals
Fast load times	Core Web Vitals
Mobile usability	Mobile-First Indexing
Structured forms	Better crawlability
lang attribute	Correct language assignment

Implementing accessibility is therefore not just a compliance exercise — it’s an SEO measure that directly pays off in rankings.

Frequently Asked Questions About the BFSG

Does my website need to be accessible?

If you sell products or services to consumers (B2C) through your website, enable bookings, or facilitate contract conclusions — yes. Purely informational websites without transaction functionality and pure B2B offerings are generally not affected.

Does the BFSG apply to micro-enterprises?

Micro-enterprises with fewer than 10 employees and under 2 million euros annual revenue are exempt from service obligations. However, the exemption doesn’t protect against cease-and-desist letters from competitors and doesn’t apply to product obligations.

What happens if I do nothing?

You face fines up to 100,000 euros from the market surveillance authority, cease-and-desist letters from competitors (595–2,700 euros per case so far), and in the worst case, a distribution ban on your digital offering.

By when does my website need to be accessible?

The deadline has already passed — the BFSG has been in effect since June 28, 2025. There are no transition periods for websites and apps. The market surveillance authority has been actively checking since January 2026.

Is a Lighthouse score of 100 enough?

No. Automated tools only detect about 57% of all accessibility issues. A perfect Lighthouse score doesn’t mean your website is BFSG-compliant. Keyboard navigation, screen reader compatibility, and content comprehensibility require manual testing.

Does the BFSG apply to B2B websites?

Pure B2B websites exclusively targeting business customers are not affected. However: if your website also addresses consumers (mixed B2B/B2C model), it falls under the BFSG. When in doubt, actual usage counts, not your intent.

Who enforces compliance?

The Market Surveillance Authority for Accessibility (MLBF) in Sachsen-Anhalt, established by all 16 German federal states as a unified body. It conducts independent checks — separate from private cease-and-desist actions.

What needs to go in the accessibility statement?

An accessible description of your service, the current state of accessibility, known limitations, a feedback mechanism (contact option for reporting barriers), and the responsible market surveillance authority. The statement belongs in the footer — alongside the imprint and privacy policy.

What to Do Now

The situation is clear: The BFSG is in force, authorities are checking, cease-and-desist letters are circulating. But the good news: most problems aren’t rocket science. Adding alt text, adjusting contrast, linking form labels, testing keyboard navigation — these are craft fundamentals that an experienced web developer implements in a few hours.

Those who implement accessibility basics in 2026 not only protect themselves from cease-and-desist letters and fines but simultaneously build a better website: faster, more discoverable, usable for everyone.

If you want to know where your website currently stands — get a free audit. I’ll check your site for the most common BFSG violations and show you exactly what needs to be done.