Accessibility
Accessible websites: Does the EAA apply to you?
Since 28 June 2025, the European Accessibility Act (EAA) applies across the EU. In Germany it is implemented by the Barrierefreiheitsstärkungsgesetz (BFSG). Many businesses are unsure whether their website is covered. Here you will find the answer and what the rules actually require.
In short
The EAA applies to websites through which consumers conclude a contract online: online shops, bookings, appointment scheduling and similar. Purely informational websites, contact forms and offers aimed only at businesses are generally not covered. Microenterprises with fewer than 10 employees and no more than €2 million in annual turnover or balance sheet total are exempt for services.
Quick check
What applies to your website?
The check gives an initial assessment and is not legal advice.
Overview
Which websites are covered.
| Type of website | Covered? |
|---|---|
| Online shop for private customers | Yes |
| Online booking or appointment scheduling, for example at a hairdresser | Generally yes |
| Ticket sales, course registration with a contract | Yes |
| Purely informational website | No |
| Contact form, callback request, newsletter | Generally no |
| Job ads and careers page | No |
| Shop or portal for business customers only | No |
What matters is whether consumers can conclude a contract through your website. How large or well known the website is does not matter.
Exemptions
Who is exempt.
Microenterprises
Businesses that provide services and meet both conditions are exempt:
- fewer than 10 employees
- no more than €2 million in annual turnover or annual balance sheet total
Apprentices are not counted, part-time staff count proportionally. The exemption only applies to services. Anyone who manufactures or sells certain products, such as computers, smartphones or e-readers, must still meet the requirements for those products.
Disproportionate burden
Larger businesses can, within narrow limits, argue that compliance would be a disproportionate burden. This must be justified, documented and reported to the authority. It rarely applies to ordinary websites and shops.
Requirements
What the rules require.
1
The website must be technically accessible
The benchmark is the European standard EN 301 549. For websites it refers to WCAG 2.1 at level AA. Among other things, this means:
- Everything can be operated with the keyboard alone, without a mouse.
- Text has enough contrast and can be enlarged.
- Images have a text description for screen readers.
- Forms are clearly labelled and error messages are easy to understand.
- Videos have captions.
2
Accessibility information
You must explain how your offer meets the requirements. This can be part of your terms and conditions or on a separate page that is easy to find. It also includes the competent market surveillance authority.
Deadlines
Deadlines, enforcement and penalties.
- Since 28 June 2025 the rules apply to new offers.
- Until 28 June 2030 there are transition periods for certain existing contracts. New or redesigned offers must be accessible right away.
- Enforcement: National market surveillance authorities are responsible. In Germany this is the MLBF in Magdeburg, which has been operating since September 2025.
- Penalties: Each EU country sets its own penalties. In Germany, fines of up to €100,000 are possible, and competitors or associations can also send formal warnings.
Quick fixes
Why overlay plugins are not enough.
Some providers promise accessibility through a plugin that shows a menu with contrast and font size switches. This does not solve the actual problems, such as missing labels or controls that only work with a mouse. Sometimes it even creates new barriers. Chambers of trade and industry associations advise against it as well. Accessibility comes from how the website itself is built.
Benefits
Why it pays off even if it is not required.
- More people can use your website, including older people and anyone with a temporary impairment.
- A clean structure helps search engines understand your pages.
- Clear controls and good contrast make the website easier to read on a phone and in bright sunlight.
- If you add an online shop or booking feature later, the foundation is already in place.
I consider accessibility from the start and check my websites for keyboard use, contrast and clean structure, guided by WCAG 2.1 AA.
FAQ
More questions.
Does the EAA also apply to my existing website?
Yes, if consumers can conclude a contract through it. The rules do not only apply to new websites. Transition periods only exist for certain contracts concluded before 28 June 2025. If the website is redesigned or rebuilt, it must meet the requirements.
Do I need to publish an accessibility statement, and what goes into it?
If your website is covered by the EAA, yes. It describes your offer, explains how it meets the accessibility requirements and names the competent market surveillance authority. The statement can be part of your terms and conditions or on a separate page that is easy to find, for example linked in the footer. It must itself be accessible.
How do I find out whether my website is accessible?
You can get a first impression quickly: use your website with the Tab key only, without a mouse. Free testing tools such as WAVE or axe find many technical errors, but not all of them. A reliable assessment requires manual testing, including with a screen reader.
What does it cost to make a website accessible?
That depends heavily on the website. If accessibility is considered from the start of a new build, there are hardly any extra costs. Retrofitting an existing website can be time-consuming, especially if the design and technology were not built for it. Sometimes a rebuild is then the more economical option.
Any questions about your website? Write to me. I reply within one business day.
This page gives a general overview and is not legal advice. As of October 2026. For a binding assessment, contact your chamber of commerce, trade association or a lawyer.
Sources
- Directive (EU) 2019/882, European Accessibility Act, eur-lex.europa.eu
- Barrierefreiheitsstärkungsgesetz (BFSG), German implementation, gesetze-im-internet.de
- MLBF, German market surveillance authority, mlbf-barrierefrei.de