Accessible E-Commerce: the BFSG Duties of Retail

The Accessibility Strengthening Act transposes EU Directive 2019/882 (European Accessibility Act) into German law and applies to certain products and services for consumers, including e-commerce services. In retail, that covers virtually every online shop selling to end customers. Micro-enterprises providing services are exempt: fewer than ten employees and no more than two million euros in annual turnover or balance sheet total. 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 the severe disability statistics of the Federal Statistical Office, just over 7.8 million (Statistisches Bundesamt, 2026) people with severe disabilities lived in Germany at the end of 2025. Add to that older users, people with temporary limitations and those using assistive technologies due to situational constraints. For retail, this group is a relevant customer base: 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 be visible (2.4.7 Focus Visible) and must not be entirely hidden by other content (2.4.11 Focus Not Obscured – Minimum, 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 text (3.3.1 Error Identification), 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 BFSG does not apply only to pure online shops. Payment terminals, interactive self-service terminals and apps for click-and-collect can also fall under the law. In omnichannel retail, complex audit scenarios arise: the web app must be operable by screen readers, the in-store terminal must meet its own requirements for output and operation, and the app must correctly use the iOS and Android accessibility APIs.

For physical retail, this means: under § 7 BFSGV, self-service terminals covered by the law must, among other things, provide speech output, allow the use of personal headphones and have any keys with sufficient contrast and tactile discernibility. Loyalty apps and voucher systems linked to the purchase process can also fall under the BFSG obligation if they are aimed at concluding a consumer contract. 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. We check the shop and web interfaces in the browser; for terminals and native apps we support the development, tests on real devices are not part of our assessment.

For the order journey itself we recommend the article on the accessible checkout. Where product comparisons, price tiers or availability appear in tables, the article on accessible data tables helps. And because login and payment increasingly include additional security steps, the article on accessible authentication and CAPTCHAs explains which methods remain acceptable.