Since the German BFSG came into force, website accessibility has turned into a sore subject for a lot of small businesses. The Barrierefreiheitsstärkungsgesetz (Accessibility Reinforcement Act) has applied since 28 June 2025, and ever since, here in Fürstenfeldbruck we get almost the same question every week: “Do we have to rebuild our site now, or will we get legal warnings?” The short, honest answer first: most small business sites are not affected at all. And even when they are not, some of the measures are worth doing anyway. Let us sort this out, without the fear marketing.
The BFSG implements an EU directive, the European Accessibility Act. It targets specific products and services aimed at consumers. Not “every website in Germany.” That distinction decides almost everything.
Who is actually affected by the BFSG?
Affected parties are providers of services in “electronic commerce.” In plain terms: sites where consumers can enter into a contract online. An online shop with a cart and checkout. A booking system for appointments or overnight stays. Online banking, ticket sales, e-books. If your website is a pure digital business card, meaning it shows your services, lists opening hours, and has a contact form, then as a rule it does not fall under the law.
The second decisive lever is the size of your business. And for many, this is where the all-clear comes.
The micro-enterprise exemption
If you provide a service and you are a micro-enterprise, a clear exemption applies. Under German law, a micro-enterprise means fewer than 10 employees and no more than 2 million euros in annual turnover or annual balance sheet total. If you stay under that threshold, your service website is exempt from the BFSG. That takes a very large share of the trades, medical practices, cafés, and law firms in the region out of scope. Important: this exemption covers services, not products such as self-service terminals. And it does not exempt you from other obligations like the legal notice (Impressum).
And what if I run a shop or a booking system?
Then it gets more serious, as soon as you sit above the micro-enterprise threshold. A hotel in Olching with online booking and 15 employees? Affected. A fashion retailer with a proper web shop and matching turnover? Affected. In that case the booking flow or the ordering process has to be operable in an accessible way. The benchmark is the standard EN 301 549, which technically follows WCAG 2.1 at level AA. That sounds clunky, but at its core it means sensible, understandable things.
And even as an affected business, there is an emergency brake: if an adaptation leads to a “disproportionate burden,” you can invoke that under certain conditions. But it is not a free pass, it has to be documented and justified. I would not rely on it, I would simply implement the basics.
What does website accessibility actually involve?
The word puts people off, but behind it sit manageable, hands-on points. Here are the ones that make the biggest difference:
- Contrast. Text has to stand out clearly from its background. The rule: at least 4.5:1 for normal text. Light grey on white that still looks “classy” almost always fails here.
- Keyboard operation. The entire site has to be usable without a mouse, using only Tab and Enter. Forms, menus, the order button. Anyone working with the keyboard alone must never get stuck.
- Alt text for images. Every image that carries meaning needs a text description so screen readers can read it out. Purely decorative images stay empty, on purpose.
- Clear structure and labelling. Headings in the right order, form fields with real labels, links that make sense out of context (“Book an appointment” instead of “click here”).
This is not rocket science. Much of it is simply clean web design that should be standard anyway. We build our client projects this way from the start, because nobody wants to pay to retrofit it later.
Why better contrast pays off, even without an obligation
Now the anecdote I promised, because it makes the point better than any statute. A small café here in Bruck, clearly under the micro-enterprise threshold, so not affected by the BFSG at all. The owner still called, because the topic was everywhere and he got nervous. We told him honestly: you do not have to do anything. But his online menu was set in a very delicate grey, elegant on the designer's monitor, hard to read in real life. We just made the contrast stronger and the type a touch bigger.
The result had little to do with laws. His older regulars, who used to ask at the counter what was on today, suddenly read the menu themselves from their phones. He said it showed within a few days. Accessibility is rarely just for “people with disabilities.” It helps the 70-year-old regular, the construction worker on his lunch break squinting in harsh sunlight, anyone with a cheap phone screen. That is the part the pure obligation debate completely overlooks.
And as a side benefit, Google likes well-structured, readable pages. Clean HTML, clear headings, meaningful alt text, all of it feeds into visibility too. We wrote more about the link between good technology and mobile usability here: Mobile First 2026: What Many Designers Get Wrong.
Your priority list, honestly sorted
If you do not know where to start, then in this order:
- First clarify: am I even affected with my site? (Do I sell or take bookings online? Am I above the micro-enterprise threshold?)
- Check contrast. The fastest win, often done in an hour.
- Click through the whole site using only the keyboard once. Where does it snag?
- Add alt text for the important images.
- If you run a shop or booking: have the ordering and booking flow tested specifically, that is where it really counts.
Nothing mandatory for points one through four, but each of these steps makes the site better for everyone. That is not a legal obligation, that is just good work. We take a similarly pragmatic view of mandatory disclosures, see Legal Notice Requirement 2026: What Every Small Business Site Needs.
Frequently asked questions
Is my ordinary company website without a shop affected by the BFSG?
In the vast majority of cases, no. A pure information and contact site without online contract conclusion does not fall under the BFSG. But as soon as you sell online or let people make binding bookings and you are not a micro-enterprise, it looks different.
What exactly does the micro-enterprise exemption mean?
Fewer than 10 employees and no more than 2 million euros in annual turnover or balance sheet total. If you are below that and offer a service, you are exempt from the BFSG requirements for that service. Other obligations, like the legal notice, still stand.
What happens if you break the rules?
German market surveillance authorities are responsible; they can investigate on complaint or on their own initiative. Penalties include orders to fix issues and fines, at the upper end up to 100,000 euros. In practice it starts with requests to correct things, not immediate maximum penalties. Panic is still the wrong advisor, and so is ignoring it.
Do I have to buy an expensive accessibility audit?
For small sites, rarely. Contrast, keyboard operation, and alt text can be assessed well with free browser tools and a bit of know-how. A paid audit mostly pays off for real shop or booking systems where the legal relevance is genuine.
Not sure whether your site falls under the BFSG, and you do not want to lose time to scare tactics? We take a look as part of a free 30-minute check, tell you honestly whether you are affected, and which two or three fixes will actually help your site. Get in touch through our contact form, straight from Fürstenfeldbruck.
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