Shop accessibility: what applies since June 2025

Does it apply to your shop?

The Act covers “e-commerce services”: a website or app where a consumer concludes a contract at a distance. So a shop is covered even if the products you sell are not listed in the Act. The same goes for online appointment booking.

The only exemption is for microenterprises that provide services. Your shop is such a service. Micro means fewer than 10 employees plus either an annual turnover of no more than €2 million or a balance sheet total of no more than €2 million. The exemption covers services, not products. If you manufacture devices the Act lists, such as e-readers, it does not apply to those.

• Covered: your own shop with cart and checkout, an ordering app, a page for booking appointments.
• Not covered: a shop only for business customers, because no consumer contract is concluded there.
• Probably not covered: a pure showcase site where nobody can order. That is the reading of Germany’s Federal Accessibility Agency.
• Excluded: third-party content you neither pay for nor control, and videos or office files published before 28 June 2025.

What your shop actually has to do

The rules say your pages must be perceivable, operable, understandable and robust. Those are the four principles of WCAG, the Web Content Accessibility Guidelines. For shops, Germany’s Federal Accessibility Agency points to the standard EN 301 549, which requires WCAG levels A and AA for websites. And it means the whole shop, not just the way to the checkout.

For shops the rules add three things: login, security checks and payment have to be just as accessible. And if the manufacturer gives you accessibility information about a product, it belongs in your listing.

• Keyboard: everything works without a mouse, from the menu and filters to the pay button. You can always see where you are (visible focus).
• Contrast: normal text has at least 4.5 to 1 against the background. Buttons, input fields and icons at least 3 to 1.
• Images: every product image has a description (alt text) that says what is shown. Purely decorative images get an empty one.
• Forms: every field has a visible label. Errors are explained in words, not just shown in red.
• Buttons and links have a name. A cart icon without text is an empty button to a screen reader.
• Checkout: login, address entry, payment methods and confirmation work with keyboard and screen reader. Including embedded payment windows.
• Language: the page header states the page language. Otherwise a screen reader may read German text with an English accent.

The accessibility statement

You have to describe publicly how your shop meets the requirements. The rules allow this in your terms and conditions or in another clearly visible place. The simplest way is a separate page linked in the footer. That page has to be accessible itself, and in Germany it is one of the pages the authority looks at during a check.

• A general description of your service in an accessible format.
• What people need to know to use the shop, such as how ordering and payment work.
• How your shop meets the requirements. Honestly, including what does not work yet.
• The competent market surveillance authority; in Germany the MLBF in Magdeburg.

Who checks and what happens next

In Germany the federal states set up one joint authority for this: the MLBF (Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen) in Magdeburg. It checks shops by spot checks without any complaint. And any customer who cannot use your shop can file a request with it. Recognised associations can do so as well.

During a check, the authority goes through every step of an order in the usual sequence. Plus the home page, login, contact, help, legal pages, your accessibility statement and further pages picked at random.

If it finds problems, it first gives you a deadline. If that is not enough, it threatens a ban and can finally order you to stop running the shop. A fine of up to €100,000 can come on top.

Why an overlay does not help

Overlays are scripts that put an icon with settings on top of your shop: bigger text, different contrast, read-aloud. They promise accessibility at the push of a button. That does not hold.

The German Federation of the Blind and Partially Sighted writes that overlays cannot make a website accessible from the outside, least of all for blind people. In the US, the provider accessiBe had to pay 1 million dollars for claiming its tool could make any website WCAG compliant. The Federal Trade Commission called that deceptive.

Blind people already have their own screen reader. They do not need a second read-aloud tool; they need a shop with clean code: real buttons, labelled fields, images with descriptions. That has to be right in the shop itself.

The most common mistakes and where to start

Every year WebAIM runs an automated check on the home pages of the one million most visited websites. In February 2026, 95.9 percent had detectable WCAG failures. Six issues make up 96 percent of everything found, and they have been the same for years. These are not shop-only figures, but they are exactly the mistakes shops make too.

1. 1

   Low contrast

   On 83.9 percent of pages. Light grey text on white, white text on product photos. Check your colours with a contrast checker.

2. 2

   Images without descriptions

   On 53.1 percent. In shops mostly the product images. Every shop system has a field for this on the image.

3. 3

   Fields without labels

   On 51 percent. Often the search box or newsletter sign-up, with only a grey placeholder inside the field.

4. 4

   Empty links and buttons

   On 46.3 and 30.6 percent. Icons for cart, account, menu or close without a name.

5. 5

   No language set

   On 13.5 percent. A single setting in the page header, usually in the theme.

6. 6

   Try it yourself

   Put the mouse away and buy a product with the keyboard, all the way to the confirmation. Wherever you get stuck, your customers get stuck too.