Accessible E-Commerce: BFSG Compliance for Online Retailers

The Accessibility Strengthening Act transposes EU Directive 2019/882 (European Accessibility Act) into German law and applies to providers of products and services offered to consumers. In retail, that covers virtually every online shop selling to end customers. Exceptions apply only to micro-enterprises with fewer than ten employees and an annual turnover below two million euros. For everyone else, from 28 June 2025, digital services – the shop itself, the checkout process, order confirmation emails and apps – must meet the requirements. Violations can be sanctioned by market surveillance authorities. Consumer organisations and disability associations also have the right to issue formal warnings.

According to a study by the Federal Statistical Office, approximately 7.8 million (Statistisches Bundesamt, 2024) severely disabled people lived in Germany at the end of 2023. Add to that older users, people with temporary limitations and those using assistive technologies due to situational constraints. This group is purchasing-ready and growing: demographics and digitalisation reinforce the need for accessible shopping experiences. An accessible online shop is therefore not only a legal obligation, but opens up a customer segment that has so far been excluded by inaccessible shops.

WCAG 2.2 is organised into four principles: perceivable, operable, understandable and robust. In e-commerce, each principle has concrete manifestations. The perceivability principle primarily concerns product images (Success Criterion 1.1.1 Text Alternatives), video content such as product videos (1.2.x Time-Based Media) and contrast ratios in price displays and buttons (1.4.3 Contrast). The operability principle goes to the heart of the purchase funnel: all interactive elements must be reachable by keyboard (2.1.1), the focus indicator must always be visible (2.4.11 Focus Appearance, new in WCAG 2.2), and for time-limited sessions (automatic logout in checkout) users must be warned and given the option to extend (2.2.1).

The understandability principle is especially critical in checkout: input fields must communicate the expected type of entry (3.3.2 Labels or Instructions), errors must be described in plain text (3.3.3 Error Suggestion), and for legally binding transactions such as orders, review and correction before completion must be possible (3.3.4 Error Prevention). The new success criterion 3.3.7 (Redundant Entry), also new in WCAG 2.2, protects users from having to enter the same data more than once – relevant for billing and delivery addresses in checkout. The robustness principle requires that all content can be correctly interpreted by current screen readers (4.1.2 Name, Role, Value for all UI components).

The choice of shop platform has a direct impact on the effort required for accessibility. Systems such as Shopware Community Edition, TYPO3 with shop extensions or WordPress offer different starting points. Shopware CE has included an improved accessibility mode since version 6.5 that sets basic ARIA attributes for forms and navigation – however, this must be systematically supplemented through templates and custom components. TYPO3 offers good conditions for accessible product pages through its semantic Fluid template system, while individual JavaScript extensions frequently introduce the weak points.

Regardless of platform, the rule applies: a shop's accessibility is only as good as its weakest link. An accessible product listing page is of little help if the checkout form has missing labels and silent error messages. That is why we audit the entire purchase funnel as a usage scenario: from product search through the product detail page, variant selection, shopping cart, checkout steps to order confirmation. We test with NVDA and VoiceOver, with keyboard-only navigation and with browser zoom at 400 per cent to cover all relevant WCAG criteria.

Accessible online shops reach more buyers. People with motor impairments who rely on keyboard navigation, older users with reduced vision and screen reader users only complete orders when the purchase funnel contains no technical dead ends. Studies show that 71 per cent (Click-Away Pound, 2019) of users with disabilities leave a website when they encounter a barrier. For e-commerce, that translates directly into measurable revenue loss: abandoned carts that result not from lack of purchase intent, but from technical inaccessibility.

In addition, accessibility improves overall usability for all users. A checkout with clear error messages and understandable labels reduces the abandonment rate even for users without disabilities. A logical page structure with semantic headings helps search engines crawl and index – WCAG conformance and SEO performance reinforce each other. The investment in accessibility therefore pays off in multiple ways: legal certainty, a broader target audience and measurable conversion improvements.

The BFSG does not apply only to pure online shops. Self-service terminals in retail stores, ordering kiosks, digital display systems and apps for click-and-collect must also meet the requirements. In omnichannel retail, complex audit scenarios arise: the web app must be operable by screen readers, the in-store ordering terminal must be usable via keyboard adapter or assistive device, and the app must correctly use the iOS and Android accessibility APIs.

For physical retail, this means: touchscreen kiosks must be operable with the built-in screen reader (iOS VoiceOver, Android TalkBack) or via a connected keyboard. Price and product displays on digital display systems must offer sufficient contrast. Loyalty apps and voucher systems linked to the purchase process also fall under the BFSG obligation. We guide retailers in analysing their entire digital ecosystem and prioritise measures by legal risk and usage frequency. We work closely with the services of accessible web development throughout.

Operators of marketplaces where third-party vendors list their products bear a particular responsibility: they must not only make the platform itself accessible, but also ensure that content uploaded by vendors meets the accessibility requirements. Product images without alt texts, vendor uploads without text descriptions and individual vendor landing pages within the platform can jeopardise BFSG conformance even if the platform structure itself is accessible.

We support marketplace operators in creating editorial guidelines that require vendors to submit accessible content, in integrating automated validations into the upload process (for example, a mandatory alt-text field for product images) and in training internal editorial teams. We also audit the marketplace's API interfaces: programmatic access points for vendors must also comply with the EAA when used as consumer-facing services. We are happy to share concrete reference projects in a personal conversation upon request.