Germany's BFSG for online shops: what Shopify, WooCommerce and Shopware merchants must do

Your shop runs on Shopify, WooCommerce or Shopware, and orders from Germany are part of your daily business. Then the BFSG concerns you. Germany's accessibility law for the private sector, the Barrierefreiheitsstärkungsgesetz (BFSG), covers B2C online shops as e-commerce services, and it follows the market rather than the company seat: whoever sells to German consumers is in scope, no German subsidiary required. Enforcement is not theoretical either. The market surveillance authority has been scanning shops automatically since January 2026, and since August 2025 waves of warning letters (Abmahnung, a formal demand from a law firm to cease and pay) have targeted online shops. This guide clarifies in three checks whether your shop is covered, does the microenterprise maths precisely and shows where the typical barriers sit in the three big shop systems.

Does the BFSG cover your shop? Three checks

The law lists the covered products and services exhaustively in section 1 of the BFSG, and consumer online shops sit at the top of that list as e-commerce services. Whether you sell sneakers, coffee or spare parts makes no difference: the sector does not matter, the customer base does. The BFSG is Germany's implementation of the European Accessibility Act, so the same logic now exists in every EU member state; Germany simply enforces it visibly. The background of the law, from the EU directive to the deadlines, is covered in our guide to Germany's BFSG. Here we deal with shop practice, and coverage comes down to three checks:

1. Can German consumers order from you? What counts is not what you intend but what is technically possible. If a private individual with a German delivery address can complete a purchase, your shop addresses consumers in Germany.
2. Does the microenterprise exemption apply? Only with fewer than 10 employees and at most 2 million euros in annual turnover, both at once. The precise maths follows in the next section.
3. Are you genuinely B2B only? Only with an effective restriction to business customers, such as a mandatory trade credential check. A sentence in your terms and conditions is not enough.

If you answer check 1 with yes and checks 2 and 3 with no, you are in scope and can jump straight to the roadmap below. For everyone hesitating at check 2 or 3, here are the two places where self-assessment goes wrong most often.

The exemption, calculated correctly

Under section 3(3) of the BFSG, microenterprises are exempt for services. A microenterprise is a business with fewer than 10 employees that at the same time stays at 2 million euros or less in annual turnover or balance sheet total. The inconspicuous word 'and' is what most readers rush past: both conditions must be met at the same time. A small team alone does not free you, and neither does a small turnover.

The second row is the classic misjudgement: three people, a shop that runs well, 3 million euros in turnover, and the law applies in full. Recheck the numbers every year, too. A shop that grows past either threshold loses the exemption.

“We only sell to businesses”: the B2B trap

Purely B2B shops are not covered by the BFSG, that much is true. But 'purely B2B' is a state of affairs, not a notice. As long as any private individual can in fact order in your shop, the offer also addresses consumers, whatever the small print says. A line in the terms saying 'sales to trade customers only' convinces nobody when the order form has never heard of it.

The restriction becomes effective through technology: a mandatory check of trade credentials at registration, prices and cart unlocked only after approval, documented rejection of private order attempts. Whoever wants to rely on B2B should build that lock properly and keep records. Anything less is a bet that nobody looks closer. Since 2026, the authority and the warning-letter firms look closer.

A practical example: a tool wholesaler writes 'trade buyers only' into the terms, but the checkout accepts any private address and card payment. In practice that is a B2C shop with a B2B label, and it is the first thing an inspection finds, because a single test order proves it.

What has actually happened since 2026

The MLBF, Germany's joint market surveillance authority for the accessibility of products and services, has been testing actively since January 2026, following up complaints and running automated software checks of its own. Online shops are the most convenient target for such scans: every product page follows the same template, so one template error repeats a thousand times across the catalogue. How the authority proceeds and what a letter from it means is covered in our guide to MLBF market surveillance; official information is published at mlbf-barrierefrei.de.

At the end of the official escalation stand fines of up to 100,000 euros under section 37 BFSG. In parallel, a second risk has been running since August 2025: waves of Abmahnungen aimed specifically at online shops, with no sign of slowing down as of July 2026. If such a letter is already in your inbox: note the deadlines, pay nothing unchecked, and read our guide on what to do about a BFSG warning letter first. A real Abmahnung also calls for advice from a lawyer.

Shopify, WooCommerce, Shopware: the duty sits with the merchant

One widespread hope first: 'the platform will handle it' does not hold legally. The BFSG obliges the economic operator who provides the service to consumers, and that is the merchant. Shopify, WooCommerce and Shopware provide the technology. Whether your specific shop, with your theme, your apps and your content, is accessible is your responsibility.

The typical barriers rarely sit in the core of the shop system. They come from what is built on top of it:

• Checkout: the most critical path in the whole shop. Whoever gets stuck here with the keyboard, or meets unlabelled form fields, cannot buy, however accessible the home page may be.
• Sliders and carousels: auto-rotating content from theme or app, often with no way to pause it.
• Pop-ups and overlays: newsletter windows and banners that cannot be closed with the keyboard and effectively trap users.
• Product images without alt text: the most machine-detectable violation of all, and especially common in shops because of the sheer volume of images.
• Invoice PDFs: documents that are part of the service must be accessible too. This is the point almost everyone overlooks.

Shopify

The theme decides the foundations: heading structure, visible keyboard focus, operable navigation. On top come apps that load their own code into the shop, from the review widget to the countdown banner, and each one can bring new barriers. The alt texts of your product images are yours to maintain either way; no app writes the wording for you. Repeat the keyboard test after every app installation; what worked yesterday can be blocked today.

WooCommerce

WooCommerce inherits the strengths and weaknesses of its WordPress base: maximum freedom, maximum spread. Theme, page builder and plugins often come from a dozen different vendors, and every update can change accessibility, in both directions. How to set up the WordPress base properly is covered in our guide to WordPress accessibility. For the shop part the same rules apply with higher stakes, because at the end of the journey stands a purchase, not a blog post.

Shopware

Shopware follows the same division of labour: the system provides the base, barriers come from the chosen theme, from extensions and from your own content. Check the automatically generated documents as well. Invoices and order confirmations as PDF are part of the service; how to test such files right in the browser and what an accessible PDF looks like is explained in our guide to PDF accessibility checks.

For product images, a system beats improvisation: a shop with 2,000 items does not need 2,000 spontaneous ideas, it needs a workflow. The rules are in the W3C images tutorial and in our guide to writing alt text.

The roadmap: seven steps to a conformant shop

The path is the same for all three systems, only the tools differ. The technical yardstick is WCAG level AA, which the European standard EN 301 549 points to.

1. Clarify coverage: answer the three checks above, with the BFSG check if in doubt. The result decides how much speed the remaining steps need.
2. Scan the status quo: have the shop tested automatically against WCAG, including product pages, cart and checkout. The report is your prioritised work list.
3. Fix the checkout first: keyboard operation, labelled form fields, understandable error messages. An accessible catalogue is worth nothing if the purchase fails at the till.
4. Give product images alt text: close the gaps in the template first, then work through the inventory systematically, best-selling products first.
5. Publish the accessibility statement: document the state reached, name known gaps honestly, link it in the footer. What belongs in it is covered in our guide to accessibility statement requirements.
6. Change how you pick themes and apps: accessibility becomes a selection criterion for everything new that enters the shop. A barrier that never gets built in never needs repairing.
7. Set up monitoring: every theme update and every new app can bring barriers back. A regular automated scan catches regressions before the authority or your customers find them.

Frequently asked questions about the BFSG for online shops

For most merchants selling into Germany, the coverage question ends with a yes, and after that order beats panic: checkout, images, statement, monitoring. The first step takes the BFSG check above two minutes. It replaces guessing with a finding, and a finding is something you can work with.