Jurisdictions — Europe
Germany's BFSG: the accessibility law that started generating cease-and-desist letters
The question German-market clients are asking
If you build or maintain sites for clients selling in Germany, the acronym to know is BFSG — the Barrierefreiheitsstärkungsgesetz, Germany's transposition of the European Accessibility Act. It stopped being theoretical in 2025.
What is true, verified
- The BFSG applies since 28 June 2025. In-scope consumer-facing services — e-commerce prominently — must meet accessibility requirements. The technical benchmark is the European standard EN 301 549, which points to WCAG for web content.
- The microenterprise exemption is narrow. Service providers with fewer than 10 employees AND at most €2M turnover are exempt; product obligations are not covered by that carve-out. Many German SMEs assume they're exempt and aren't — check the two thresholds, both must hold.
- Enforcement has teeth on paper — fines up to €100,000 under the Act, with a central market-surveillance authority (MLBF).
- The real-world pressure arrived faster than the regulator: Abmahnungen. Germany's competitor cease-and-desist system means a non-compliant shop can receive a formal warning letter with a four-figure demand from a competitor's lawyer — reports of BFSG-based Abmahnung waves began in August 2025. Whatever one thinks of the practice, it makes "we'll wait for the regulator" a bad strategy in Germany specifically.
- The honest language note: German buyers search in German ("BFSG Website prüfen", "BFSG Abmahnung"), and this guide is in English. If you're an agency serving German clients in English, this is your brief; for the German-language conversation, point your client to the official sources — gesetze-im-internet.de (the law's text) and the Bundesfachstelle Barrierefreiheit FAQ.
How to check a client site yourself
- Accessibility signals: run an automated WCAG checker (axe-core is the open-source standard) on the key templates — home, product page, checkout, contact form. The mechanical failures automated checks catch are exactly what an Abmahnung letter lists first.
- Consent posture: load the site cold and watch what fires before consent (GDPR + TTDSG — German enforcement on cookies is among the strictest in the EU).
- Broken links and SEO basics: one pass should also cover what the client will ask about next.
- Document what you saw: capture the page state behind every finding — the difference between a defensible position and an expensive settlement.
The honest shortcut
We built SiteComply to do exactly that pass — accessibility signals, consent posture, broken links, SEO basics — in a single $29 audit where every finding points to the exact page state we observed. White-label friendly, built for agency portfolios, and it never claims more than it verified.