Website Accessibility: An Explanation of the BFSG Requirements for SMEs

The Accessibility Enhancement Act (BFSG) has been in effect in Germany since June 28, 2025. Many companies still don’t know if they’re affected at all. And those who know they’re affected are asking themselves: Where do I start? How much will it cost? Do I have to implement everything at once?

 

We provide concrete answers to these questions. No blanket statements. Just what you really need.

First things first: What is the BFSG all about?

Since June 28, 2025, the Accessibility Enhancement Act (BFSG) has required companies in Germany to design digital offerings so that they are usable by everyone, including people with visual impairments, mobility limitations, or hearing difficulties. The law implements EU Directive 2019/882, which applies throughout the EU. It primarily affects online stores, booking systems, and apps that offer services to consumers. Purely informational websites without a shop or booking function are not subject to this requirement. Companies that do not comply with the regulations risk fines of up to 100,000 euros.

Are you affected at all?

That is the first question you need to clarify. The BFSG clearly distinguishes between websites that are affected and those that are not. The

 

following are affected:

• Online stores and e-commerce platforms
• Websites with booking or scheduling functions (e.g., doctors’ offices, tradespeople with appointment booking, event providers)
• Banking websites and payment service providers
• Apps, digital tickets, and similar services

The following are not affected:

• Purely informational websites without an online store or booking system
• Micro-enterprises with fewer than 10 employees and less than 2 million euros in annual revenue that offer services exclusively

Important:

Both conditions for the micro-enterprise exemption must be met simultaneously. Businesses with more than 10 employees or over 2 million euros in revenue are generally not exempt.

 

Typical B2B scenario from our practice:

A machine manufacturer in the Ravensburg area operates a company website with a product catalog and contact form. No shop, no booking system. This business is likely not affected by the BFSG. The situation is different if the same company operates an online configurator with an ordering function. In that case, the requirement applies.

What technical measures must be implemented?

The BFSG is based on WCAG 2.1 (Web Content Accessibility Guidelines) at Conformity Level AA. In Germany, the BITV 2.0 (Accessible Information Technology Ordinance) specifies this standard for public bodies. For private companies, the BFSG applies directly in accordance with WCAG 2.1 AA.

 

What this means in practice:

 

Check contrast:

Text and background must have a contrast ratio of at least 4.5 to 1. A ratio of 3 to 1 is not sufficient for normal text. For large text (18 points and above), a minimum of 3 to 1 applies.

 

Ensure keyboard navigation:

Every function on the website must be operable without a mouse. Users with motor impairments navigate using the keyboard. This applies to menus, forms, galleries, and all interactive elements.

 

Alt text for all images:

Every image requires a text description in the alt-attribute. Screen readers (programs that read text aloud) read this text aloud. Decorative images are given an empty altattribute.

 

Semantic HTML: Headings (h1 through h6), lists, forms, and tables must be correctly marked up. This helps screen readers navigate the site and is also good for SEO.

 

Publish an accessibility statement: You must publish a public statement on your website. In it, you describe which standards you meet, which gaps remain, and how users can report issues. This statement must be updated annually.

How do you get started? A realistic approach

Step 1: Self-check with free tools

Start with these free tools:

• WAVE (wave.webaim.org): Analyzes visible barriers directly in the browser. You can immediately see where contrast is missing or alt text is not set.
• axe DevTools: A browser extension for tech-savvy users. It also finds issues that WAVE misses.
• Colour Contrast Analyzer: Checks color contrast between text and background.

These tools are no substitute for a professional audit. However, they give you an initial overview of where the biggest problems lie. For a professional website audit, we recommend the next step.

Step 2: Commission a professional audit

An audit by an expert costs between 1,000 and 5,000 euros for a typical SME website. The expert not only performs automated checks but also conducts manual testing using a screen reader and keyboard. The result is a prioritized list of concrete actions, sorted by urgency.

Step 3: Prioritize and implement actions

Don’t do everything at once. Start with the actions that have the greatest impact and can be implemented the fastest:

• Add alt text (often done in a few hours)
• Adjust contrast (CSS changes, usually quick to implement)
• Improve link labels (replace “click here” with meaningful text)

More complex measures, such as full keyboard navigation or ARIA attributes (additional HTML markup for screen readers), follow afterward.

Step 4: Publish an accessibility statement

The statement is mandatory. It can document incomplete accessibility. So you don’t have to have everything perfect before publishing the statement. But you must openly communicate what is still missing.

What does it cost to make a website accessible?

Hard numbers instead of empty promises:

Measure	Cost (Approximate)
Self-check with free tools	0 euros
Professional audit (SME website, representative pages)	1,000 to 5,000 euros
Subsequent implementation (medium-sized website)	5,000 to 20,000 euros
Accessibility for new development (surcharge)	20 to 50 percent of the project price

The biggest cost trap: Retrofitting accessibility is significantly more expensive than planning for it from the start. Anyone having a new website developed now can save significantly by incorporating accessibility from the start. This is especially true for complex projects involving intricate forms, configurators, or booking systems.

 

For ongoing support and regular audits, we offer this as part of our website maintenance services.

What does this mean for TYPO3 and WordPress websites?

The BFSG applies regardless of the CMS (Content Management System, i.e., the system behind your website) used. However, the CMS influences the amount of effort required for implementation.

 

TYPO3:

TYPO3 has supported WCAG 2.1 AA in its core for years. This means: The system’s basic functions are designed with accessibility in mind. Our TYPO3 development

takes this into account from the very beginning. However, extensions can cause issues. A review of all extensions used is mandatory.

 

WordPress:

WordPress itself is largely accessible. The biggest barriers arise from themes (design templates) and plugins (extensions). Anyone using a popular theme without an explicit accessibility guarantee must expect to make adjustments. This is especially true for page builder themes. You can find a direct comparison of both systems in our article TYPO3 vs. WordPress: Which One Is Right for Your Project?

 

 

Overlays are not a solution:

Many providers promise to achieve accessibility with a single JavaScript snippet. That is not true. These so-called accessibility overlays solve only a small portion of the problems. True accessibility is built into the code, not through scripts added later. Using overlays does not protect you from legal warnings.

How we handle this at Waterproof Web Wizard

Accessibility is not a bonus feature that we add upon request. We plan it into new developments from the very beginning.

 

This means: Before we start a project, we clarify whether the BFSG applies and what that means for the project. For existing websites, we begin with an audit before recommending any measures. The result is a prioritized list that we go through together with the client. Dennis Hüttner personally oversees this process.

 

Waterproof Web Wizard GmbH has been developing and maintaining TYPO3 and WordPress websites for B2B companies in the DACH region since 2007.

 

We clearly explain what is necessary, what is optional, and what you can handle yourself. This saves budget and avoids measures that have no real effect.

 

If you’re currently in the process of planning a new website, be sure to read our article on the risks of using AI website builders for corporate sites first. There, we explain what’s often overlooked in quick website solutions—accessibility is a common example.

Conclusion

The BFSG has been in effect since June 2025. Anyone operating an online store or a booking system is affected. Those with only an informational website likely are not.

 

The first step is an honest self-assessment. This is followed by a professional audit. Then comes implementation, step by step.

 

Don’t wait for the first warning letter. Accessibility takes time and money. Retrofitting later costs more.

Frequently Asked Questions: Accessible Websites and the BFSG

What is the BFSG and who does it affect?

The Accessibility Enhancement Act (BFSG) has been in effect in Germany since June 28, 2025. It requires companies that offer digital products or services to consumers to ensure accessibility in accordance with WCAG 2.1 AA. Online stores, booking systems, and apps are affected. Purely informational websites without transactional functions are not.

How much does it cost to make a website accessible?

A professional audit for an SME website costs between 1,000 and 5,000 euros. Retrofitting costs between 5,000 and 20,000 euros, depending on the scope. Those who plan for accessibility from the start of a new development pay a surcharge of 20 to 50 percent on the project price but save on the cost of retrofitting.

Does the BFSG also apply to my WordPress or TYPO3 website?

The BFSG applies not based on the CMS, but on the purpose of the website. If you sell products or offer bookable services via your WordPress or TYPO3 website, you are affected. The CMS itself is only one factor. The theme, plugins, and editorial content play an equally important role.

What happens if I don’t comply with the BFSG?

Violations can result in fines of up to 100,000 euros. Before a penalty is imposed, there is usually an official request to rectify the situation. Warnings from competitors are also possible. The risk increases the more obvious and severe the barriers are.

Are micro-enterprises exempt from the BFSG?

Micro-enterprises with fewer than 10 employees and less than 2 million euros in annual revenue are exempt from the BFSG for service offerings if implementing accessibility would constitute a disproportionate burden. Both conditions must be met simultaneously. The exemption does not apply automatically but must be documented and justified.

 

 

 

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Is your website potentially affected by the BFSG and you’re not sure?

 

We’ll review it with you. Have your website’s potential assessed by

 

 

 

Dennis Hüttner, Waterproof Web Wizard GmbH

 

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Sources:

 

 

1. Federal Agency for Accessibility: Accessibility Enhancement Act

 

 

2. Full text of the BFSG: bfsg-gesetz.de

 

 

3. Lexware: The Accessibility Enhancement Act

 

Sources

 

• BMAS – Accessibility Enhancement Act
• BFIT-Bund – Federal Agency for Accessibility
• WCAG 2.1 – Web Content Accessibility Guidelines
• BIK Test – BITV Test for Accessibility
• EN 301 549 – European Standard for Accessible ICT