BFSG for Online Shops: How to Make Your Shopify Shop Accessible (Obligations, Exceptions, Checklist)

Do you remember the fuss about the cancellation button? That was just a small ripple. A bigger wave is slowly approaching – and most retailers haven't even noticed it yet: Accessibility has been a legal requirement for online shops since June 2025. Not as a recommendation, not as a nice-to-have, but as a law with an authority, a schedule of fines, and a control mechanism.

In this guide, you'll get the lowdown on the topic without panic or legal jargon: who is actually affected (spoiler: there's an exception that saves many small shops – for now), what exactly is required, and how to make your Shopify shop compliant step-by-step.

What is the BFSG – and why does it affect online shops?

The Accessibility Strengthening Act is the German implementation of the European Accessibility Act (EU Directive 2019/882). Since June 28, 2025, certain products and services must be accessible – and "e-commerce services" are explicitly on the list. Translated: Your online shop is such a service. It's not just about people with visual impairments. Accessibility includes motor impairments (keyboard instead of mouse), hearing impairments (subtitles), cognitive impairments (understandable language, clear error messages) – and incidentally, every customer looking at their phone in sunlight or holding a baby with one hand. Several million people with disabilities live in Germany alone – this is not a fringe group, this is purchasing power.

The technical basis is the European standard EN 301 549, which, in the web sector, refers to WCAG 2.1, Level AA – the international standard for accessible websites. The four basic principles: content must be perceivable, operable, understandable, and robust.

Does the BFSG apply to your shop?

Honest assessment of the exemption: Yes, many small Shopify retailers are formally (still) exempt. Nevertheless, I wouldn't put the issue aside – for three reasons. First: Nobody checks the thresholds for you; if you grow beyond €2 million or hire the tenth person, you're in. Second: Whether competitors can send warning letters for violations is legally disputed – I wouldn't rely on that. Third: Accessibility is simply better UX – larger click areas, clearer forms, and better contrasts increase conversion for all customers.

What exactly is required

The requirements sound abstract but quickly become tangible:

• Perceivable: Images need alternative text, text needs sufficient contrast to the background (at least 4.5:1), videos need subtitles. Information must never be conveyed only by color ("correct the red field" is not enough).
• Operable: The entire shop – from the menu to the buy button – must be usable without a mouse, only with a keyboard. Visible focus outline included.
• Understandable: Forms need labeled fields and error messages that state what is wrong and how to fix it. Clear language instead of jargon.
• Robust: Clean code, correct heading hierarchy (H1 → H2 → H3), so screen readers can read the page.
• Accessibility Statement: Affected shops must also provide a public statement on how the requirements are met – similar to a privacy policy, a separate information page.

The 10-Point Checklist for Your Shopify Shop

1. Check Theme Basis: Official Shopify themes come with solid accessibility foundations (semantic HTML, focus states). An old or heavily customized theme is often the biggest risk. My free Theme Finder shows you which theme suits you.
2. Maintain Alt-Texts: Every product image gets a description that replaces the image ("Green wool sweater with round neck" instead of "IMG_2384"). Editable directly on the medium in Shopify.
3. Measure Contrasts: Brand colors on white often look good but still fail. Use contrast checkers, aim for 4.5:1 for body text – especially with light accent colors on buttons.
4. Perform Keyboard Test: Put your mouse away and try buying something using only Tab, Enter, and arrow keys – from product to checkout. Where you get stuck, your customer will also get stuck.
5. Clean Up Forms: Visible labels instead of just placeholder text, clear error messages next to the field. Applies to contact forms, newsletter sign-ups, and custom checkout fields.
6. Heading Hierarchy: One H1 per page, then logically H2/H3 – do not choose a heading "because it looks prettier". Screen readers navigate using these.
7. Zoom Test: Zoom the page to 200% – content must remain readable and operable without elements overlapping.
8. Videos with Subtitles: Product videos and tutorials need subtitles – most platforms now generate them automatically, but you still need to check them.
9. Check Apps and Pop-ups: The most common blind spot! Cookie banners, newsletter pop-ups, and third-party review widgets are often not keyboard-closable or cover content. Test each app individually – what you need to know about banner GDPR pages is in the article GDPR in Shopify Shops.
10. Create an Accessibility Statement: As a separate Shopify page, linked in the footer next to the impressum and privacy policy – with a description of the measures and a contact option for reporting barriers.

Important distinction: The Shopify checkout itself is maintained by Shopify – you benefit from the platform there. Your responsibility lies with the theme, content, images, apps, and everything you have customized. This is precisely where violations arise in practice.

Who controls – and what are the consequences?

The central market surveillance authority of the states for the accessibility of products and services (MLBF) is responsible. It can request evidence, order measures, and, in cases of persistent violations, prohibit the service – i.e., stop sales. The fine framework ranges up to €100,000 depending on the violation. Furthermore: consumers and recognized associations can actively report violations to the authority – so it doesn't require a random discovery. Realistically, the authority will not check every small shop on the first day. But the combination of reporting options, increasing awareness, and unclear warning letter situations makes waiting the worst strategy – especially since most measures are one-time and measurably improve your shop.

Note: This article explains the technical implementation from a Shopify perspective and does not constitute legal advice. For a legal assessment of your specific case, consult a law firm specializing in IT law.

You don't want to implement it yourself? With a fixed-price shop setup, the accessible basic configuration is included from the start – cheaper than any subsequent conversion.

Author: Dominik-Lukas Moral Falke – Shopify Freelancer & Shopify Plus Partner from Berlin. Over 115 completed Shopify projects in the DACH region.
Last updated: July 4, 2026