Accessibility in E-commerce: How to make your online store legally compliant by 2025

E-Commerce

From mid-2025, B2C shops will also be obliged to comply with accessibility standards. The aim is for everyone – regardless of their abilities or impairments – to be able to participate in digital life without restrictions. The basis for this is the new Accessibility Strengthening Act (BFSG). In order to prepare you for these changes at an early stage, we are focussing on this topic today. Let’s go!

Why digital accessibility?

With the publication of the Accessibility Strengthening Act (BFSG) in the Federal Law Gazette on 22 July 2021 at the latest, it is clear: from 28 June 2025, all digital products and services mentioned in the law that are launched or offered on the market must comply with the legal accessibility requirements. However, accessibility should not only be seen as a legal obligation, but also as a key factor for inclusion, user-friendliness and long-term economic success. Here are some reasons why accessibility is crucial:

1. Inclusion and equal opportunities: Accessibility enables people with disabilities to participate in social and professional life on an equal footing. It promotes inclusion and ensures that no one is excluded.
2. Expanding the target group: Around 15% of the world’s population lives with a disability. By taking accessibility into account, companies can better reach this target group and expand their customer base.
3. Improving the user experience: Accessible websites and applications are often more user-friendly for all users. Features such as well-structured content, simple navigation and clear labelling also benefit people without disabilities.
4. SEO benefits: Accessible content, such as alt text for images and a well thought-out page structure, also improves visibility in search engines and thus contributes to better SEO performance.
5. Image and corporate ethics: Accessibility shows that a company acts in a socially responsible manner and is committed to the needs of all users, which strengthens the company’s image and reputation.

There are legal regulations on accessibility not only in Germany, but also in many other countries. For example, the Accessibility Strengthening Act (BFSG) transposes the European Accessibility Act (EAA) into German law, while the Americans with Disabilities Act (ADA) regulates similar standards in the USA. Companies that do not fulfil these requirements expose themselves to the risk of legal consequences. Under the BFSG, violations and non-compliance not only result in fines of up to 100,000 euros, but can even lead to the website or online shop being shut down. Compliance with the accessibility requirements is checked on a random basis by the market surveillance authorities of the federal states. However, it can also be initiated by specific complaints from consumers, recognised associations and competitors.

The basis for implementing the BFSG

Are you affected? Then your online store must fulfil the Web Content Accessibility Guidelines (WCAG). Why? The law, which implements EU Directive (EU) 2019/882, is accompanied by a legal ordinance – the so-called BFSGV. This regulates the requirements for products and services. This also applies to online shops, among other things. The technical requirements for this are provided by the DIN EN 301 549 standard, which in turn refers to the ‘WCAG’ guidelines of the Web Accessibility Initiative (WAI) of the World Wide Web Consortium (W3C).

The W3C is the body responsible for the standardisation of technologies on the World Wide Web. Within the committee, there is a working group called WAI, which deals specifically with accessibility to the web and has also developed the WCAG.

The original WCAG were published in May 1999 (WCAG 1.0). To ensure that the accessibility standards can keep pace with technological changes, the guidelines have been repeatedly updated with new versions.

• WCAG 1.0: Published in 1999 with a focus on the implementation of web content in HTML and CSS
• WCAG 2.0: Was published in 2008 and takes layouts and interaction as well as their design into account
• WCAG 2.1: Was published in 2018 and expands the previous version to include new device types and technologies (tablets, mobile devices)
• WCAG 2.2: Was published in 2023 and contains nine additional criteria to the existing A, AA and AAA level guidelines
• WCAG 3.0: The first draft was published in May 2024 and is intended to take new requirements into account with a special focus on additional tests and different evaluation mechanisms

Currently, the European Standard (EN) 301 549 still refers to version 2.1. However, it is also advised that you should follow the latest version, i.e. version 2.2, as the EN is to be adapted in the future (probably at the end of 2025). For you as the operator of your online store, this means that you currently have to comply with WCAG 2.1. There are 78 success criteria for this. If your online shop fulfils these requirements, it is said to be compliant. However, as a WCAG-compliant online store does not have to take all success criteria into account, these are divided into three different compliance levels to illustrate the degree of customisation:

• A (lowest level with 30 success criteria)
• AA (middle level with 20 success criteria)
• AAA (highest level with 28 success criteria)

For you and your online store, this means that you must fulfil all A and AA criteria. The WCAG can be compared to an onion: If you fulfil the AA criteria, you automatically also cover the A criteria. These success criteria are based on four fundamental principles, which are divided into several guidelines.

The four principles of WCAG 2.1

The four principles of WCAG 2.1 are known by the acronym POUR and stand for perceivability, operability, comprehensibility and robustness:

1. Perceptibility: The online store or the digital information in it must be perceptible to the user (text alternatives for non-text content such as images, subtitles for audio, adaptability of the display and sufficient contrast through colours, text size, etc.).
2. Usability: The online store should be operable in such a way that users can access the desired content (keyboard operation, sufficient time for entries, minimising the risk of failure, navigability and accessibility via other devices)
3. Comprehensibility: The online store should be designed in such a way that it is easy to use and the digital content is understandable (legibility, predictability and input aids)
4. Robustness: The online store should be compatible with assistive technologies (web browsers, assistive output devices, etc.) so that it is accessible to users

And what is WCAG 2.2 all about?

The new version 2.2 of the WCAG was published on 5 October 2023. Nine new success criteria were added, which, according to the WAI, were expanded for three target groups in particular: Users with cognitive or visual disabilities and disabilities that may exist when using mobile devices. These include keyboard use, other input mechanisms such as touchscreen and mouse operation and further support for limited cognitive abilities (e.g. alternative mechanisms for password entry and cognitive function tests). The planned changes in the new version can be found in detail on the Federal Government’s accessibility portal for information technology: WCAG 2.2

The WCAG are normally downwards compatible. This means that the success criteria from the previous version are fully incorporated into the current standard. This is also the case here, with one exception: the syntax analysis success criterion (level A) from WCAG 2.1 has been labelled as obsolete and removed from the guideline.

As WCAG 2.2 is more of a supplement to WCAG 2.1 and will be required in the near future, it makes perfect sense to use WCAG 2.2 when customising your online store. Especially as WCAG is downwards compatible. This means that if you fulfil WCAG 2.2, you also fulfil 2.1.

Digital accessibility and the associated legal requirements may seem overwhelming at first glance and you may wonder where you should even start. But the more intensively you deal with the topic, the clearer the necessary steps become. And the sooner you start, the more relaxed you will be when the legal deadline of 28 June 2025 approaches. To make it easier for you to get started, we have also planned an online event. Take advantage of the personal opportunity on 5 November 2024 and get more free information on this topic. Details and registration can be found below (event tip). Just scroll!