BFSG for online shops

Q: We are under the micro-enterprise threshold. Do we need to do anything?

For services — which is what a shop is — micro-enterprises with fewer than 10 employees and an annual turnover or balance sheet total of at most €2 million are exempt. The staff limit always applies; of the two financial figures, one is enough. The exemption does not cover products, and it does not stop a customer who cannot check out from going elsewhere.

Does it apply to your shop?

The BFSG covers services in electronic commerce provided to consumers. That is the shop itself, but also everything around the transaction — the account area, the order confirmation, the returns form, and the app if you have one.

You sell goods or services to consumers (B2C) — a pure B2B wholesale portal is out of scope
The service is provided in Germany, regardless of where your company sits
Micro-enterprises are exempt for services: fewer than 10 staff and an annual turnover or balance sheet total of at most €2m — one of the two figures is enough
Selling a physical product is different from providing the service: hardware in scope has its own obligations
You must publish the accessibility information Annex 3 BFSG asks for (section 14 BFSG): how your shop meets the requirements, and which authority supervises it. A statement with a feedback mechanism is the public-sector duty under BITV 2.0, not the BFSG's

Sector guide · E-commerce

Where shops actually fail

Across the shops we have scanned, the failures cluster in the same four places — and none of the four is the homepage everybody tests.

The checkout loses focus

A payment dialog opens and focus stays on the page behind it. Keyboard users are left tabbing through invisible elements while a modal they cannot reach waits for input. This is the single most expensive failure to ship, because it stops the purchase.
Product images say nothing

Catalogue imports bring their filenames with them, so a gallery announces “DSC_0041.jpg” eleven times. Variant swatches are usually worse: colour squares with no name at all.
Form errors are colour only

The address step marks failures with a red border and no text. Nothing is announced, nothing names the field, and the customer is told only that something is wrong.
Filters are unreachable

Faceted navigation built from div elements with click handlers, and a result count that updates silently — so the filter appears to do nothing at all.

The criteria a shop should check first

Not all fifty apply equally to a shop. These are the ones that decide whether somebody can complete a purchase — the failures a complaint would name first. Each links to a plain-language page on that criterion: what it asks for, how it fails in practice, and how far an automated check can get.

All WCAG 2.2 AA criteria

What to do about it

Test the purchase, not the homepage

Pick your highest-volume journey — search, product, basket, delivery, payment, confirmation — and walk it with the keyboard alone. Most shops find a blocker before the basket.
Fix the template, not the page

A shop has perhaps twelve templates and fifty thousand URLs. A finding on one product page is a finding on every product page, which is why our reports group by rule and rank by pages affected.
Publish the accessibility information honestly

Annex 3 BFSG asks how your service meets the requirements, so it has to say where it does not yet. Information claiming full conformance on the strength of an automated scan is the document that turns a complaint into a fine.
Keep it from coming back

You ship weekly; an audit is a snapshot. Re-crawl on a schedule so a regression shows up as a new finding rather than as a customer complaint.

Questions shops ask

We are under the micro-enterprise threshold. Do we need to do anything?

For services — which is what a shop is — micro-enterprises with fewer than 10 employees and an annual turnover or balance sheet total of at most €2 million are exempt. The staff limit always applies; of the two financial figures, one is enough. The exemption does not cover products, and it does not stop a customer who cannot check out from going elsewhere.

Our shop platform says it is accessible. Is that enough?

No. Platforms ship accessible components; themes, apps and custom checkout steps then break them. What matters legally is what your customers get, not what the vendor tested. Scan your live shop — that is the thing the law is about.

What happens if somebody complains?

The market surveillance authority can require you to remedy the defect, and can ultimately prohibit the service from being offered. In practice, the first contact is a request for information — which is much easier to answer if you already have a report, your Annex 3 accessibility information and a remediation plan.

Written to be useful, not to be legal advice. It reflects our reading of the BFSG and EN 301 549 as of 12 October 2026; for a binding assessment of your obligations, ask a lawyer.

BFSG for online shops

Does it apply to your shop?

Where shops actually fail

The checkout loses focus

Product images say nothing

Form errors are colour only

Filters are unreachable

The criteria a shop should check first

What to do about it

Test the purchase, not the homepage

Fix the template, not the page

Publish the accessibility information honestly

Keep it from coming back

Questions shops ask

Further reading

See what this finds on your site