Sector guide · E-commerce
BFSG for online shops
If you sell to consumers online in Germany, the BFSG has applied to your shop since 28 June 2025. It is not a design guideline — it is product legislation, and the market surveillance authority acts on complaints. This is what it covers, where shops actually fail, and what to check first.
- Applies to B2C shops in the EU
- Benchmark: EN 301 549 → WCAG 2.2 AA
- Micro-enterprise exemption explained below
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 under €2m annual turnover — both, not either
- Selling a physical product is different from providing the service: hardware in scope has its own obligations
- You need an accessibility statement and a feedback channel people can actually reach
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.
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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.
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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.
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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.
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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.
What to do about it
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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.
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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 template and rank by pages affected.
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Write the accessibility statement honestly
It has to say what is not yet accessible. A statement claiming full conformance on the strength of an automated scan is the document that turns a complaint into a fine.
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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 under €2 million annual turnover are exempt. Both conditions have to hold. 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, a statement 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 2026-09-13; for a binding assessment of your obligations, ask a lawyer.
See what this finds on your site
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