In short and in plain language
Your shop should show facts about access for disabled people. These facts come from the maker of a device. For example: can the device read text out loud? Can the text be made big?
You do not have to test the device yourself. You pass on what the maker gives you. If something is missing, ask for it.
Make a separate field for this on each product. Show it on the page under a clear heading. People must find it with the keyboard and with a screen reader.
Some devices fall under the law themselves. These include computers, phones and e-book readers. Before you sell one, check the CE mark and the German manual.
Very small firms do not need to make their shop accessible. They still need to check such devices before they sell them.
Anyone selling an e-book reader, a notebook or a smartphone in an online shop for Black Week maintains the price, images, specifications and delivery time. One field is missing from many product templates: the device's accessibility information. That information is exactly what the ordinance to the German Accessibility Strengthening Act asks for. Online shops must provide information on the accessibility of the products they sell, as far as the responsible economic operator makes it available (BFSGV, § 19 No. 1). The duty has applied since 28 June 2025 (BFSGV, § 22) and is easily lost in the debate about accessible shops, because it concerns the content of the page rather than how the page is operated. For devices that fall under the Act themselves, a second duty applies: the retailer may only make them available once the CE marking, the accompanying documents and the manufacturer and importer details are in place (BFSG, § 11(1)). This article shows where the information comes from, how it gets into the shop as a data field, how it appears accessibly on the product page and what you check before listing a device.
Key takeaways
- Since 28 June 2025, online shops must provide information on the accessibility of the products they offer, as far as the responsible economic operator supplies it (BFSGV, § 19 No. 1). The wording does not limit this to BFSG devices.
- Manufacturers of computers, smartphones and e-book readers must make their accessibility information publicly available; the ordinance sets 10 requirements for it, including a list of assistive devices tested with the product (BFSGV, § 4(2)).
- A dedicated product data field with features, activation, compatible assistive devices, source and date carries the manufacturer's information from import to product page instead of hiding it in the description text.
- On the product page the information belongs under its own heading or a labelled tab whose name and role a screen reader announces (W3C, WCAG 2.2, SC 4.1.2). Linked data sheets must be accessible themselves (EN 301 549 V4.1.1, 12.1).
- Before listing a BFSG device, the retailer checks 4 conditions: CE marking, enclosed documents, manufacturer and importer details (BFSG, § 11(1)). Without CE marking, fines of up to 100,000 euros apply (BFSG, § 37).
- Microenterprises are exempt for their shop as a service (BFSG, § 3(3)), but not as retailers of BFSG devices. Where manufacturer information is missing, ask for it and record the status instead of writing your own promises.
The missing data field in the product template
A typical product page for consumer electronics follows a fixed pattern: title, image gallery, price, variant selection, followed by description, specifications and scope of delivery. The data comes from the merchandise management system, from supplier files or from a product information system and lands in predefined fields. Whether a device has text-to-speech, whether the font can be enlarged or whether it works with a braille display is usually not part of that. At most it appears somewhere in the description text, if the manufacturer happened to mention it in its marketing copy.
During Black Week this part of the range moves to the front. For Black Friday and Cyber Monday 2025, the German Retail Federation expected sales of 5.8 billion euros (HDE). In the accompanying survey of more than 1,000 online shoppers (HDE) in October 2025, 48 percent (HDE) planned to buy discounted products on Black Friday. The promotions typically include notebooks, tablets, smartphones and e-book readers. These devices are products within the meaning of the German Accessibility Strengthening Act: it applies to consumer general purpose computer hardware systems, to terminal equipment used for telecommunications services and to e-book readers placed on the market after 28 June 2025 (BFSG, § 1(2)). The Act explicitly counts desktops, notebooks, smartphones and tablets as general purpose computers (BFSG, § 2 No. 35).
For the shop, this creates a task that sits in data maintenance rather than in the template. The manufacturer's accessibility information needs a fixed place in the product data model, a route from the supplier into that field and a presentation on the product page that is accessible itself. How the product page becomes accessible to operate, with variant selection, gallery and basket, is covered in our article on accessible product pages. This article is about the content that page has to carry.
The wording of § 19 No. 1 BFSGV in three building blocks
§ 19 BFSGV contains the additional requirements for e-commerce services. These are offers provided via websites and apps at the individual request of a consumer with a view to concluding a consumer contract (BFSG, § 2 No. 26), which in practice mainly means online shops. Numbers 2 and 3 concern identification, authentication, security and payment functions as well as electronic signatures (BFSGV, § 19 No. 2 and 3). Number 1 requires that information on the accessibility of the products for sale and of the services offered is provided, as far as this information is made available by the responsible economic operator (BFSGV, § 19 No. 1).
In practice, these building blocks create very different amounts of work:
- Information on accessibility: this means information on how people with disabilities can use a product, such as text-to-speech, magnification, contrast settings or interoperability with assistive technologies like screen readers and braille displays.
- of the products for sale: the wording does not limit the duty to devices that fall under the Act themselves. It refers to the range the shop offers.
- as far as made available by the responsible economic operator: the shop does not have to collect or measure the information itself. It passes on what the manufacturer, importer or supplier provides. Under the Act, an economic operator is a manufacturer, authorised representative, importer, distributor or service provider (BFSG, § 2 No. 15).
The rule comes from the European Accessibility Act. For e-commerce services, it lists “providing the information concerning accessibility of the products and services being sold when this information is provided by the responsible economic operator” (Directive (EU) 2019/882, Annex I Section IV). Recital 43 of the Directive makes clear that the e-commerce requirements should apply to the online sale of any product or service (Directive (EU) 2019/882, Recital 43). Accordingly, the Bundesfachstelle Barrierefreiheit, Germany's federal accessibility agency, states that an online shop falls under the Act even if it offers products not covered by the BFSG (Bundesfachstelle Barrierefreiheit). The same number also covers services: how a hotel describes the accessibility of its rooms is shown in our article on accessible hotel booking.
The Act draws a line at company size. Microenterprises that offer or provide services are exempt from the accessibility requirements (BFSG, § 3(3)). Microenterprises are companies with fewer than ten employees and an annual turnover or annual balance sheet total of no more than 2 million euros (BFSG, § 2 No. 17). For a very small shop, § 19 BFSGV therefore does not apply. The retailer duties for devices that fall under the Act themselves, however, remain. More on this in the section on § 11 BFSG and in our article on the microenterprise exemption.
Pass it on, do not invent it
Where the information comes from: the manufacturer's information
For devices within the scope of the BFSG, the source is regulated. The ordinance requires the manufacturer to make information on the product's accessibility functions, their activation and their interoperability with assistive technologies publicly available when the product is placed on the market, for example on a website (BFSGV, § 4(2)). The ordinance sets 10 requirements (BFSGV, § 4(2)) for this information. It must be available via more than one sensory channel, findable and understandable, be provided in text formats from which other formats can be generated, and contain descriptions of the user interface and the product functions.
For the shop, the last of these requirements is particularly useful. The description of the interface with assistive devices must include a list of the assistive devices tested together with the product (BFSGV, § 4(2) No. 10). That is exactly what a blind customer asks before ordering a smartphone: does it work with my braille display? If the list exists, it belongs in the shop. Equally helpful is the description of the user interfaces, meaning handling, control, feedback, input and output (BFSGV, § 4(2) No. 8).
E-book readers have an additional requirement of their own: they must be equipped with text-to-speech (BFSGV, § 8). For a reader placed on the market after 28 June 2025, text-to-speech is therefore not an optional extra but a mandatory feature, and how to activate and use it belongs in the manufacturer's information. What applies to the e-books themselves, from EPUB to metadata, is covered in our article on accessible e-books.
The European standard EN 301 549 follows the same route. In version V4.1.1 it requires documentation on the use of a device to lead, directly or via a link, to a web page with information on the accessibility features, how to use them and how to get support for them (EN 301 549 V4.1.1, 12.3). For the retailer this means: as a rule there is an official manufacturer page on the accessibility of the device. It is the most reliable source for the data field, more reliable than marketing copy or distributor catalogues.
| Manufacturer information | Legal basis | Field in the shop | Example e-book reader (illustrative) |
|---|---|---|---|
| Accessibility functions | BFSGV § 4(2) | Features | Text-to-speech, font size, contrast mode |
| Activation of the functions | BFSGV § 4(2) | Activation | Switch on text-to-speech in the accessibility menu |
| Assistive devices tested | BFSGV § 4(2) No. 10 | Compatible assistive devices | Headphones via Bluetooth |
| Description of operation | BFSGV § 4(2) No. 8 | Operation | Use without sight via text-to-speech |
| Text-to-speech | BFSGV § 8 | Mandatory feature | present |
| Origin of the information | BFSGV § 19 No. 1 | Source and date | Manufacturer page, date of import |
From data sheet to product data field
For the information to reach the product page reliably, it needs its own field in the product data model. A free paragraph in the product description is rarely enough: it gets overwritten by the next supplier import, cannot be displayed in a targeted way and cannot be checked. What works well is a dedicated field group “Accessibility” on the item, filled during import and carried along with every data transfer. In Shopware CE, for example, this can be set up as a custom field set on the product; in other shop systems the building blocks are called attributes, properties or free text fields. These fields have proven useful as a basic structure:
- Features: the accessibility functions as a short list, in the manufacturer's wording.
- Activation: how the functions are switched on, for example via a menu or a button at start-up.
- Compatible assistive devices: the assistive technologies the manufacturer tested together with the device.
- Manufacturer information: a link to the official accessibility information, with the format, such as web page or PDF.
- Source and date: who supplied the information and when it was imported.
- Status: available, requested from the supplier or not provided by the manufacturer.
{
"accessibility": {
"features": ["Text-to-speech", "Font size in steps", "Contrast mode"],
"activation": "Settings / Accessibility / Text-to-speech",
"tested_assistive_technology": ["Headphones via Bluetooth"],
"manufacturer_info_url": "https://manufacturer.example/accessibility",
"manufacturer_info_format": "Web page",
"source": "Manufacturer page",
"retrieved_at": "YYYY-MM-DD",
"status": "available"
}
}The import determines the quality. If the manufacturer supplies the information as structured data, it can be mapped directly. If it only exists as a web page or PDF, product data maintenance takes over the text and records the link. Mapping to the exact item matters: a reader in several storage sizes usually has the same functions, a successor model not necessarily. The field therefore belongs to the item being sold, not to a product family as a whole. After a firmware update that adds or removes functions, the status is updated.
Whoever maintains product data needs a short guide for it: what goes into which field, which manufacturer wording stays unchanged, when to ask. In our training for content teams this can be worked through on your own shop system, together with alt text for product images and understandable product copy.
Presentation on the product page
On the product page, the section needs a clear name and a fixed place. A tab or an expandable section next to the description and specifications, labelled “Accessibility”, is common. If it is built as a tab, its name and role must be programmatically determinable and changes of state must be notified to assistive technologies (W3C, WCAG 2.2, SC 4.1.2). A screen reader therefore has to announce that it is a tab, what it is called and whether it is selected. A tab that consists only of an icon has no name without a text alternative; how controls get an understandable name is covered in our article on empty links and buttons.
Within the section, the same rules apply as on any content page. Headings and labels describe topic or purpose (W3C, WCAG 2.2, SC 2.4.6), and the structure of a list or table must be programmatically determinable, not just visual (W3C, WCAG 2.2, SC 1.3.1). Icons for functions such as text-to-speech or contrast mode need a text alternative (W3C, WCAG 2.2, SC 1.1.1), and text must be resizable without assistive technology up to 200 percent (W3C, WCAG 2.2, SC 1.4.4) without loss of content or functionality.
If the shop links to a manufacturer data sheet, the document becomes part of the information. EN 301 549 requires digital information about a product to meet the requirements for web content in a web format and the requirements for documents as a document (EN 301 549 V4.1.1, 12.1). The standard's mapping table links the shop requirement from the Directive to clauses 12.1, 12.2 and 12.3, among others (EN 301 549 V4.1.1, Annex ZB). A scanned PDF without a text layer does not help a customer using a screen reader. It is better to take the key information into the shop as text and link the document in addition. What matters for accessible documents is shown on our page on PDF accessibility.
The test question for every product page
If information is missing, the section should say so instead of disappearing. A sentence such as “The manufacturer has not provided any accessibility information for this device” with a pointer to the contact channel is more honest than an empty tab. It also saves customer service some follow-up questions. Which information duties support services have for accessibility questions is covered in our article on accessible customer support.
Who looks for this information
Accessibility information is not niche information. At the end of 2025, a good 7.8 million people with a severe disability lived in Germany (Destatis), which is 9.4 percent (Destatis) of the population. A person counts as severely disabled if the pension office has recognised a degree of disability of at least 50 (Destatis) and issued a valid pass. For 4 percent (Destatis) of severely disabled people, blindness or a visual impairment was the most severe disability, and a good third, 34 percent (Destatis), were 75 or older.
Worldwide, the World Health Organization estimates the number of people with significant disability at 1.3 billion (WHO, 2023), or 16 percent (WHO, 2023) of the world's population. At least 2.2 billion people (WHO, 2026) have a near or distance vision impairment. For these groups, information such as font size, contrast mode and text-to-speech decides whether a device is an option at all. Those who find it on the product page do not have to search the manual or ask customer service first.
Then there are people who use a function temporarily or for convenience: text-to-speech while cooking, large print after eye surgery, contrast mode in bright sunlight. For them, the data field is product information like any other. And anyone choosing a device for parents or grandparents at Christmas finds the features there that help with the choice.
Retailer duty under § 11 BFSG: check first, then list
§ 19 No. 1 BFSGV governs what the shop shows. § 11 BFSG governs what the retailer checks beforehand, for devices that fall under the Act themselves. The retailer may only make such a product available on the market once 4 conditions (BFSG, § 11(1)) are met:
- CE marking: the product bears the CE marking under § 19 BFSG, visibly, legibly and indelibly on the product or its data plate, otherwise on the packaging and accompanying documents (BFSG, § 19(2)).
- Documents: the product comes with instructions for use and safety information in German (BFSG, § 7(3)).
- Manufacturer details: the manufacturer has applied a type, batch or serial number or another element allowing identification and stated its name, trade name or trade mark with a postal address (BFSG, § 7(1) and (2)).
- Importer details: for imported goods, the importer has stated its name, trade name or trade mark and postal address and ensured that instructions and safety information in German are enclosed (BFSG, § 10(1) and (2)).
For an online shop, this is a goods receipt check that is linked to the product data. What the manufacturer supplies, especially the instructions for use, is often also the source for the accessibility field. Doing the check under § 11 BFSG and the data import under § 19 No. 1 BFSGV in one step saves a second pass. The guidelines of the Federal Ministry of Labour and Social Affairs explicitly describe the retailer's main duty in light of its position in the supply chain (BMAS).
If the retailer knows or has reason to believe that a product does not meet the requirements, it may only make it available once conformity has been established (BFSG, § 11(2)). If it does not comply, the retailer informs the manufacturer or importer and the market surveillance authorities without delay. For goods already made available, it ensures that corrective measures are taken or the product is withdrawn (BFSG, § 11(4)). According to the BMAS guidelines, unlike manufacturer and importer, the retailer does not have to take measures to establish conformity itself (BMAS).
The fine provisions distinguish between cases. Making a product available without CE marking contrary to § 11(1) No. 1 BFSG risks a fine of up to 100,000 euros (BFSG, § 37). Failing to provide information owed under § 11(2), or providing it incorrectly or late, risks up to 10,000 euros (BFSG, § 37). How market surveillance proceeds and which steps come before a fine is covered in our article on BFSG market surveillance.
Microenterprises dealing with products within the scope of the BFSG are not exempt from the Act.
For small shops, this is the most important distinction. The microenterprise exemption concerns the service, meaning the shop as an offer. Anyone selling notebooks, smartphones or e-book readers remains bound by § 11 BFSG as a retailer, even as a very small business.
When information is missing or contradictory
In practice, the information is not complete for every item. Devices placed on the market before 28 June 2025 are not subject to the Act's product requirements (BFSG, § 1(2)); for remaining stock of such devices, manufacturer information under § 4 BFSGV may be missing. Accessories that are not BFSG products also often come without accessibility information. The words “as far as” in § 19 No. 1 BFSGV limit the shop's duty in this case: what is not supplied cannot be provided.
That does not, however, permit filling the gap with your own words. Phrases such as “fully accessible” or “suitable for blind people” without manufacturer information are the retailer's own claim, which it has to stand behind, and they can mislead customers. A fixed procedure for gaps has proven useful:
- Ask the supplier and record the request with its date in the status field.
- Look for the official manufacturer page on accessibility that the device documentation is meant to point to under EN 301 549 V4.1.1, clause 12.3.
- Do not resolve contradictions between data sheet and manufacturer page yourself; clarify them with the manufacturer and name the source of each statement until then.
- For BFSG devices without any accessibility information, check whether there is reason to believe conformity is lacking (BFSG, § 11(2)) and document the result.
- Update the status of the information when models change and new firmware versions are released.
No accessibility promises of your own
Template in the audit, data flow in house
An audit against WCAG 2.2 and EN 301 549 checks whether the product template presents the accessibility section so that it can be found, carries a label and can be reached by keyboard and screen reader, whether linked documents are accessible and whether a missing entry is shown in an understandable way. That covers the presentation. When we implement an accessible shop, we build the section into the template code of the product template instead of pushing the information into the description. How we test is described on the WCAG audit page; the legal basics are summarised on the page on BFSG requirements.
The data flow, by contrast, lies outside what an audit of the template covers. Whether the supplier provides accessibility information, whether the import carries it over and whether the goods receipt check under § 11 BFSG is documented lies with purchasing, product data maintenance and logistics. You organise these processes in house; in the report we show where in the template which information is expected. We also offer a check of what your product pages pass on to screen readers as a separate screen reader test, and the shop's accessibility statement can describe where customers find the product information.
Sources and legal basis
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