Germany's Barrierefreiheitsstärkungsgesetz (BFSG) has been in force since 28 June 2025 – and one question keeps reaching us: does every small website now have to be accessible, including the one for a club, a physiotherapy practice or a one-person business? The honest answer is a firm „it depends“. For pure service websites there is a genuine exemption for microenterprises, but it does not apply to online shops and products. Knowing the thresholds spares you unnecessary worry – and shows why an accessible site pays off even when there is no legal duty. In Germany alone, 7.8 million people (Federal Statistical Office) live with a recognised severe disability, and digital accessibility is essential for around ten percent of the population (Aktion Mensch). This guide explains the legal situation in plain terms, clears up misconceptions and shows how an accessible starter website at a fixed price succeeds without costly retrofitting. It is general information and does not replace individual legal advice.
Key takeaways
- The BFSG has applied since 28 June 2025 and requires many providers of digital products and services to be accessible.
- Microenterprises with fewer than ten employees and at most two million euros in annual turnover are exempt – but only for pure services.
- The exemption does not cover online shops or products placed on the market: e-commerce falls under the law even for microenterprises.
- Accessibility pays off even for the exempt: more reach, better findability and no costly retrofit when it is planned in from the start.
What the BFSG is and since when it applies
The Barrierefreiheitsstärkungsgesetz transposes the European Accessibility Act, the directive on accessibility requirements for products and services, into German law. Its requirements apply to certain products placed on the market since 28 June 2025 (Bundesfachstelle Barrierefreiheit), and to services provided to consumers since that date. On the product side this includes computers, smartphones and routers; among services it covers banking, telecommunications, e-books, passenger transport and – particularly relevant for small businesses – electronic commerce, that is, online shops. Transition periods apply to some areas, for example five years (Bundesfachstelle Barrierefreiheit) for certain service contracts and considerably longer periods for self-service terminals.
Two categories, two logics
Are small businesses really affected?
Here comes the relief that matters to many: microenterprises that offer or provide services are exempt from the BFSG (Bundesfachstelle Barrierefreiheit). A microenterprise is one with fewer than ten employees (Barrierefreiheitsstärkungsgesetz (BFSG)) and an annual turnover of at most two million euros (Barrierefreiheitsstärkungsgesetz (BFSG)) or an annual balance sheet total of at most two million euros. The little word „and“ is decisive: both conditions must be met together. A business with eight employees but three million euros in turnover is no longer a microenterprise – nor is one with twelve employees and low turnover.
Fewer than ten employees
The headcount of employees is decisive. Anyone reaching or exceeding this limit is no longer a microenterprise, regardless of turnover.
At most two million euros
Annual turnover or the annual balance sheet total must not exceed two million euros. Either of the two figures is enough for the classification.
Both criteria together
The threshold is a double one: only those below ten employees and below the turnover limit count as a microenterprise under the law.
The exemption is narrower than many think
As with other legal fundamentals – for instance the GDPR basics for the small website – a sober look at your own situation beats blanket panic or blanket reassurance. The good news for many clubs, practices and freelancers: a lean information website without a sales function generally falls under the exemption.
Service or online shop? The decisive difference
Whether the exemption applies depends less on company size than on what the website actually does. A pure information or business-card website that presents a service offering and provides a contact form counts as a service website. As soon as goods or services are sold online, however – from the classic shopping cart to a binding online booking against payment – it is electronic commerce, which the BFSG expressly covers (IHK).
| Website type | Microenterprise exempt? | Reason |
|---|---|---|
| Pure information website | Usually yes | Service without online sales |
| Website with contact form | Usually yes | No contract concluded on the page |
| Online shop with cart | not included | Electronic commerce |
| Binding online booking with payment | not included | Distance service |
| Sale of covered products | not included | Product falls under the BFSG |
In practice this means: the physiotherapy practice with a page that informs about services and offers a callback is likely exempt as a small service provider. But as soon as the same practice sells vouchers online or books appointments bindingly against prepayment, the classification shifts. Anyone who wants to start a small online shop should therefore plan accessibility in from the start rather than treat it as a nuisance duty.
Five persistent misconceptions about the BFSG
Plenty of half-truths circulate around the BFSG. They lead sometimes to needless worry, sometimes to false certainty. The following points come up especially often in conversations with small businesses, clubs and freelancers – alongside the clean page structure with the most important pages that every website needs anyway.
„My site is too small“
Size alone does not automatically protect you. What matters is whether it is a service and whether the thresholds are met – not the perceived importance of the site.
„Clubs are always exempt“
A pure information page is usually uncritical. But as soon as a club sells tickets, merchandise or services online, it can slip into electronic commerce.
„Accessible means ugly“
The opposite is true. Clear contrasts, good structure and readable typography look modern and tidy – accessible design is good design.
„It costs a fortune“
What gets expensive is mainly the later repair work. Built in from the start, accessibility adds little extra effort on a small website.
„An add-on tool fixes everything“
Automatic overlay tools mask symptoms but rarely address the causes. Real accessibility lives in the structure and the code of the site.
„No duty, no benefit“
Even those who are exempt gain reach, visibility and a professional image through accessibility – the benefit does not end at the legal boundary.
When in doubt, check rather than guess
What accessible actually means
Web accessibility follows the internationally recognised Web Content Accessibility Guidelines (WCAG). Their core can be summed up in four principles: content should be perceivable, operable, understandable and robust. For a small website this is not rocket science but solid craft at four concrete points that together make the biggest difference.
Clear structure and semantics
A sensible heading hierarchy, real HTML elements instead of image mock-ups and a logical reading order help screen readers and search engines alike to grasp the content.
Sufficient contrast
Text must stand out clearly from the background. WCAG level AA requires a contrast ratio of at least 4.5 to 1 for normal text – good for older eyes and bright sunlight too.
Keyboard operability
All functions must be reachable without a mouse. Poor keyboard operability is the most common barrier on the web (Aktion Mensch) and affects many groups of users.
Alt text and clear language
Meaningful alternative text for images, understandable forms and descriptive link text make content usable for everyone – from screen readers to voice control.
Accessible is also good for Google and mobile
Why accessibility pays off even for the exempt
Even those who are legally exempt give away reach without accessibility. In Germany around 7.8 million people (Federal Statistical Office) live with a recognised severe disability; adding milder impairments, according to Aktion Mensch about 13 million people (Aktion Mensch) rely on well-accessible digital services. A widely used rule of thumb puts it plainly: digital accessibility is essential for around ten percent (Aktion Mensch) of the population, necessary for at least thirty percent (Aktion Mensch) and helpful for one hundred percent (Aktion Mensch) – for example in glaring sunlight, on the move with a smartphone or in older age.
That need meets a thin supply. In a test by Aktion Mensch, only one third (Aktion Mensch) of the online shops examined were accessible, and merely one quarter (Aktion Mensch) of the most popular shopping portals allowed accessible navigation. Keyboard operation failed most often: only 20 of 65 (Aktion Mensch) tested pages could be operated by keyboard alone. Anyone who does better than average stands out visibly – an advantage that also applies to local visibility via the Google Business Profile.
- A larger audience: millions of people with disabilities and many older users are not excluded.
- Better findability, because clean, structured code works in favour of search engines.
- Higher usability on smartphones and in difficult situations such as bright light or time pressure.
- A positive image as an open, modern business that considers all its customers.
- Less risk should the classification of your own offering change in the future.
- Lower costs, because a site that is accessible from the start is cheaper than a later retrofit.
Accessibility is not a drawback for the majority but a benefit for everyone – the site becomes clearer, faster and easier for anyone to use.
Accessible from the start instead of a costly retrofit
How large the backlog is becomes clear from an annual analysis of one million most-visited home pages: 95.9 percent (WebAIM Million) had automatically detectable WCAG failures in 2026, on average 56.1 errors (WebAIM Million) per page. Many of these errors – missing alt text, insufficient contrast, unlabelled form fields – arise when accessibility is bolted on afterwards. That is exactly what gets expensive: retrofitting an established site often means rebuilding parts of its structure and design.
Building cleanly from the start is far more economical. Our fixed-price packages plan in clear structure, sufficient contrast, keyboard operability and mobile usability from the outset – for small businesses, clubs and freelancers alike. Whether an accessible starter website at a fixed price or a larger package makes sense depends on the scope; our services give an overview. If you run an ageing site, the signs you need a website relaunch offer a good basis for deciding.
Accessibility remains an ongoing task
Whether you fall under the exemption or not: a clearly structured, high-contrast and keyboard-operable site is the noticeably better site. It reaches more people, looks more professional and is future-proof should the legal situation or your offering change. Which path to your own website fits, and what it costs, can be weighed up with our comparison of website and site builder and our packages and prices.