In Germany, the EAA is implemented by the BFSG. From 28 June 2025, websites and applications providing B2C e-commerce services must be accessible on the basis of EN 301 549 (WCAG 2.1 AA level) and must publish an accessibility statement. Violations can be investigated ex officio and, in Germany, can become the subject of competitor and association warning notices (Abmahnung).
Overview
The European Accessibility Act (EAA) makes the accessibility of products and services to users with disabilities an internal market rule. E-commerce is one of the services the directive lists expressly: any store selling online to an EU consumer falls within its scope, wherever the store is established. Germany’s implementing act, the BFSG, entered into force on 28 June 2025.
What is required?
The practical benchmark is the harmonised standard EN 301 549 (corresponding to WCAG 2.1 level AA): an interface that is perceivable, operable, understandable and robust. In concrete terms that means full keyboard navigation, sufficient colour contrast, compatibility with screen readers, programmatic labels on form fields, understandable error messages and accessible validation flows. The obligation covers not only the storefront but the whole product search → cart → checkout → confirmation flow.
Why this gap is visible from outside
Accessibility failings can be found with automated tools, and a missing accessibility statement is obvious at a glance. In Germany that has opened a new line of business for the Abmahnung (formal warning notice) industry; administrative fines of up to €100,000 and, for repeat breaches, suspension of the service may follow.
Micro-enterprise exemption
Micro-enterprises providing services — fewer than 10 employees AND annual turnover or balance sheet total of no more than €2M — are exempt from the BFSG’s service obligations. The exemption is narrow, and a growing store can cross the threshold without noticing; operations approaching it should plan the transition.
Roadmap
(1) A quick accessibility scan of the current theme (automated plus keyboard testing); (2) fixing the critical flows; (3) publishing the accessibility statement; (4) adding accessibility regression testing to theme and plugin updates. On the legal side: the wording of the statement, a compliance undertaking in supplier (theme or agency) contracts, and a defence strategy in case a warning notice arrives.
Related content
This record is one of the external-visibility scan headings of the International E-Commerce Focus Area; for sales into Germany it is dealt with together with our market and regulatory compliance service. For how the Abmahnung works, see our guide.
What it means in practice
For businesses selling online from Türkiye to EU consumers, accessibility is now an obligation of the shop itself and not only of the product: the interface must meet the EN 301 549 baseline, an accessibility statement must be published, and the whole ordering flow is in scope. In Germany, breaches fall under the BFSG fine regime and can trigger competitor warnings (Abmahnung); self-service terminals follow the transitional rule in BFSG §38.
