Shopify Accessibility: The BFSG Mandate Since 2025 — What You Need to Do Now

Most German Online Shops Are Currently Breaking the Law

Since June 28, 2025, every B2C online shop selling to customers in Germany must comply with the Barrierefreiheitsstaerkungsgesetz (BFSG) -- Germany's implementation of the European Accessibility Act (EAA). That is not a recommendation. It is the law.

The reality? The vast majority of Shopify stores operating in the German market are not compliant. Not even close. Most shops have critical accessibility issues on every single page: missing alt texts, broken keyboard navigation, insufficient color contrast, inaccessible forms. Each of these is now a legal violation that can result in fines of up to 100,000 EUR.

If you are reading this and thinking "this probably does not apply to me" -- it almost certainly does. The exemptions are narrow. The enforcement is real. And the deadline has already passed.

This guide covers exactly what the BFSG requires, what WCAG 2.1 AA compliance means for your Shopify store in practice, and a prioritized action plan to get compliant as quickly as possible.

What Is the BFSG?

The Barrierefreiheitsstaerkungsgesetz (Accessibility Strengthening Act) is Germany's national implementation of the European Accessibility Act (EAA), an EU-wide directive that mandates digital accessibility for products and services. The EAA was adopted in 2019 and gave member states until June 2025 to transpose it into national law.

Germany's implementation is among the strictest in Europe.

Who Does It Apply To?

The BFSG applies to all businesses that offer products or services to consumers (B2C) through digital channels -- including online shops, mobile apps, and e-commerce platforms. If you sell to end consumers in Germany, you are covered. It does not matter where your company is headquartered.

Key point: The BFSG applies based on where your customers are, not where your business is registered. A Shopify store based in the US, UK, or anywhere else that sells to German consumers must comply.

The Exemption: Micro Businesses

There is exactly one exemption. You are exempt if your business meets both of these criteria simultaneously:

Both conditions must be true. If you have 8 employees but generate 3 million EUR in revenue, you are not exempt. If you have 15 employees but only 1.5 million EUR in revenue, you are not exempt. The bar is set at the micro-business level for a reason -- the law is designed to cover essentially every commercially significant online shop.

What Are the Penalties?

The BFSG enforcement is handled by Germany's market surveillance authorities (Marktuebuerwachungsbehoerden). Penalties include:

• Fines from 10,000 EUR to 100,000 EUR per violation
• Orders to cease sales of non-compliant digital services
• Public naming of non-compliant businesses
• Repeated violations can result in escalating penalties

The enforcement is not theoretical. German authorities have a track record of enforcing consumer protection regulations aggressively, and accessibility is increasingly on their radar. Consumer protection organizations can also file complaints on behalf of affected users.

The Timeline

There is no grace period. There is no "we are working on it" defense. Since June 28, 2025, your shop must be accessible. If it is not, you are in violation.

What Does WCAG 2.1 AA Actually Require?

The BFSG references the EN 301 549 European standard, which in turn is based on WCAG 2.1 at the AA conformance level. WCAG stands for Web Content Accessibility Guidelines, published by the W3C (World Wide Web Consortium).

WCAG 2.1 AA is built on four principles, often remembered by the acronym POUR:

1. Perceivable

Content must be presentable to users in ways they can perceive -- regardless of whether they can see, hear, or process information the way most people do.

Concrete requirements:

• Text alternatives (alt text): Every non-decorative image must have a descriptive alt attribute. Product images need alt text that describes the product, not just "image" or "photo"
• Captions and transcripts: Video content needs captions. Audio content needs transcripts
• Color is not the only indicator: You cannot use color alone to convey information. A red "out of stock" label also needs text or an icon
• Contrast ratios: Normal text must have a contrast ratio of at least 4.5:1 against its background. Large text (18px+ bold or 24px+ regular) needs at least 3:1
• Text resizing: Content must remain functional when text is resized up to 200% without loss of content or functionality
• Reflow: Content must reflow properly at 320px viewport width (no horizontal scrolling)

2. Operable

Users must be able to operate all interface components and navigation, regardless of how they interact with the page.

Concrete requirements:

• Full keyboard accessibility: Every interactive element -- links, buttons, form fields, menus, modals, carousels -- must be reachable and operable with a keyboard alone
• Visible focus indicators: When tabbing through the page, a visible outline or highlight must show which element is currently focused
• No keyboard traps: Users must be able to navigate into and out of every component using only the keyboard
• Skip navigation: A "Skip to main content" link should be the first focusable element on the page
• Sufficient time: If content has time limits (e.g., checkout timers), users must be able to extend or disable them
• No seizure-inducing content: No flashing content that flashes more than 3 times per second
• Pause, stop, hide: Any automatically moving, blinking, or scrolling content (carousels, marquees, auto-playing videos) must have controls to pause, stop, or hide it

3. Understandable

Content and interface behavior must be understandable to users.

Concrete requirements:

• Language declaration: The page must declare its language in the HTML lang attribute (e.g., lang="de" for German)
• Consistent navigation: Navigation must be consistent across pages -- same order, same location
• Error identification: Form errors must be clearly identified in text, not just with color
• Error suggestion: When a form input error is detected, suggestions for correction should be provided
• Labels and instructions: Every form field needs a visible, associated label. Placeholder text alone is not sufficient
• Predictable behavior: Elements should behave predictably. No unexpected context changes on focus or input

4. Robust

Content must be robust enough to be interpreted reliably by a wide variety of user agents, including assistive technologies.

Concrete requirements:

• Valid HTML: Clean, valid markup that assistive technologies can parse correctly
• ARIA attributes: Proper use of WAI-ARIA roles, states, and properties where native HTML semantics are insufficient
• Name, role, value: All user interface components must have accessible names, roles, and states that can be programmatically determined
• Status messages: Dynamic status changes (cart updates, form submissions, error messages) must be announced to screen readers via ARIA live regions

Shopify-Specific Accessibility Checklist

Here is a practical checklist tailored specifically to Shopify stores. This covers the most common compliance gaps we find during accessibility audits:

Images and Media

Navigation and Interaction

Forms and Checkout

Color and Typography

Semantic HTML and ARIA

Common Accessibility Problems in Shopify Shops -- and How to Fix Them

These are the issues we encounter in nearly every Shopify store we audit. They are listed in order of how frequently they occur:

1. Missing or Useless Alt Text

The problem: Product images either have no alt text at all, or they have auto-generated text like "IMG_4832.jpg" or generic text like "product image." Screen reader users get no useful information about the product.

The fix: Write descriptive alt text for every product image. Describe what is actually in the image.

• Bad: alt="product" or alt="IMG_4832"
• Good: alt="Navy blue organic cotton t-shirt, front view, crew neck, regular fit"

For stores with hundreds or thousands of products, prioritize your top-selling products first. Use Shopify's bulk editor or CSV export/import to update alt text efficiently.

2. Insufficient Color Contrast

The problem: Light gray text on white backgrounds, pale colored buttons, low-contrast placeholder text. This affects not just screen reader users but anyone with reduced vision -- which includes a significant portion of your customer base.

The fix: Test every text/background combination with a contrast checker. Common offenders in Shopify themes:

• Sale price text (often light red on white)
• Placeholder text in search and form fields
• Footer text on dark backgrounds
• Disabled button states
• Breadcrumb text

Adjust your theme's color variables. A contrast ratio of 4.5:1 is the minimum for normal text. Aim for 7:1 where possible -- it is better for everyone.

3. Keyboard Navigation Broken

The problem: Custom JavaScript components (mega menus, product filters, image galleries, quick-view modals) that only work with mouse interaction. Keyboard users cannot access them at all.

The fix: Test your entire site using only a keyboard. Start at the top of the page and Tab through every element. You should be able to:

• Reach every interactive element
• See a visible focus indicator on each element
• Activate buttons and links with Enter
• Toggle checkboxes and radio buttons with Space
• Navigate dropdown menus with Arrow keys
• Close modals with Escape

If any of these fail, the component needs JavaScript modifications to handle keyboard events. This often requires editing your theme's JavaScript or switching to an accessible theme.

4. Missing Form Labels

The problem: Form fields that use placeholder text as the only label. When a user starts typing, the placeholder disappears and the field has no visible label. Screen readers may not announce the field's purpose at all.

The fix: Add visible <label> elements associated with each form field via the for attribute. The label should remain visible even when the field has content. Floating labels (that move above the field on focus) are an acceptable pattern if implemented correctly.

Common places where labels are missing in Shopify stores:

• Newsletter signup forms
• Search fields
• Contact forms
• Account registration and login forms
• Cart quantity fields

5. Inaccessible Cookie Banners and Popups

The problem: Cookie consent banners that cannot be dismissed with a keyboard, newsletter popups that trap focus, or modals that do not announce their presence to screen readers. These are often the first thing a user encounters -- and if they are inaccessible, the entire site is effectively blocked.

The fix: Ensure your cookie banner and any popups follow these rules:

• Focus moves to the modal when it appears
• Focus is trapped within the modal while it is open (Tab does not go behind it)
• The modal can be closed with the Escape key
• The modal has role="dialog" and aria-modal="true"
• The modal has an accessible name via aria-labelledby or aria-label
• When closed, focus returns to the element that triggered it

If you use a third-party cookie consent app, verify it meets these requirements. Many do not.

6. Auto-Playing Carousels Without Controls

The problem: Hero banners and product carousels that rotate automatically with no way to pause, stop, or manually control them. This is a WCAG 2.1 AA violation (Success Criterion 2.2.2) and is disorienting for many users.

The fix: Add visible Pause/Play controls. Add Previous/Next buttons with descriptive aria-labels. Ensure the carousel stops auto-playing when a user interacts with it or when it receives keyboard focus.

7. Missing Page Language Declaration

The problem: The HTML element does not have a lang attribute, or it has the wrong language. Screen readers use this to determine pronunciation. A German-language shop without lang="de" will have its content read with English pronunciation rules -- making it incomprehensible.

The fix: In your theme.liquid file, ensure the opening <html> tag includes the correct language attribute. For multilingual Shopify stores, use Shopify's request.locale.iso_code to set the language dynamically:

<html lang="{{ request.locale.iso_code }}">

Testing Tools for Accessibility Compliance

No single tool catches everything. Use a combination of automated tools and manual testing for comprehensive coverage.

Automated Testing Tools

Manual Testing Methods

Important: Automated tools catch approximately 30-40% of accessibility issues. The remaining 60-70% require manual testing. A Lighthouse score of 100 does not mean your site is accessible -- it means you passed the automated checks. Real accessibility testing requires a human navigating the site with assistive technology.

Implementation Priority: Where to Start

Not all accessibility fixes are equal. Here is a prioritized approach based on legal risk, user impact, and implementation effort:

Quick Wins (1-2 Days)

These fixes address the most common WCAG violations and require minimal technical skill:

Medium Effort (1-2 Weeks)

These require theme modifications and JavaScript changes:

Complex Changes (2-4 Weeks)

These may require significant development work or third-party solutions:

Cost Estimation: What Does BFSG Compliance Cost?

Let us be straightforward about costs. The investment depends heavily on the current state of your shop and the complexity of your theme:

Small Shopify Store (Standard Theme, < 100 Products)

Medium Shopify Store (Custom Theme, 100-1,000 Products)

Large Shopify Plus Store (Heavily Customized)

The Cost of Non-Compliance

Compare these investment figures to the cost of non-compliance:

• Single fine: 10,000 - 100,000 EUR
• Repeated violations: Escalating fines, potential sales ban
• Legal costs: If a consumer organization or affected individual takes action
• Lost revenue: An estimated 15-20% of the population has some form of disability. An inaccessible shop loses these customers entirely
• Reputation damage: Public naming of non-compliant businesses

The math is clear: Investing in accessibility is significantly cheaper than the penalties for ignoring it. And unlike a fine, accessibility improvements actually generate return -- through a larger addressable market, better SEO (Google rewards accessible sites), and improved usability for all customers.

Beyond Compliance: Why Accessibility Is Good Business

Legal compliance is the baseline, but the business case for accessibility goes much further:

SEO benefits: Many accessibility improvements directly improve SEO. Alt text helps Google understand your images. Proper heading structure helps crawlers parse your content. Semantic HTML improves how search engines index your pages. Google has explicitly stated that accessibility is a factor in search quality evaluation.

Larger market: In Germany alone, approximately 7.8 million people have a recognized severe disability (Schwerbehinderung). In the EU, 87 million people live with a disability. Add temporary impairments (broken arm, eye surgery recovery) and situational limitations (bright sunlight on a phone screen, noisy environment), and the number grows dramatically.

Better conversion rates: Accessible sites have lower bounce rates and higher conversion rates. Clearer navigation, better form usability, and improved readability benefit every customer -- not just those using assistive technology.

Mobile performance: Many accessibility best practices -- touch target sizes, readable text, simple navigation -- directly improve the mobile experience, which accounts for 63% of German e-commerce revenue.

The BFSG Compliance Summary

Here is what you need to do, distilled to the essentials:

1. Audit your store now. Run automated tests (axe DevTools, WAVE, Lighthouse) and perform manual keyboard and screen reader testing. Document every issue.

2. Prioritize by legal risk. Fix the issues that affect the most users and carry the highest violation risk first: alt text, contrast, keyboard navigation, form labels, page language.

3. Fix your theme. Most Shopify themes are not fully accessible out of the box. Budget for theme modifications -- CSS, Liquid, and JavaScript changes.

4. Test with real assistive technology. Automated tools miss the majority of issues. Test with NVDA or VoiceOver. Test with keyboard only. Test at 200% zoom.

5. Document your compliance. The BFSG requires you to provide an accessibility statement (Erklaerung zur Barrierefreiheit) on your website. This statement must describe the accessibility status of your site, known limitations, and a feedback mechanism for users to report issues.

6. Monitor continuously. Accessibility is not a one-time project. Theme updates, new products, new apps, and content changes can introduce regressions. Build accessibility checks into your workflow.

How TG-AI Can Help

We perform comprehensive accessibility audits for Shopify stores, combining automated scanning with manual expert testing -- including screen reader and keyboard-only validation.

What our accessibility audit includes:

• Full WCAG 2.1 AA compliance assessment across all page types (homepage, product pages, collection pages, cart, checkout, blog, account pages)
• Automated scanning with axe-core, WAVE, and Lighthouse
• Manual keyboard navigation testing of every interactive component
• Screen reader testing with NVDA and VoiceOver
• Color contrast analysis across all theme color combinations
• Detailed report with every issue documented, prioritized by severity, and accompanied by specific fix instructions
• Accessibility statement (Erklaerung zur Barrierefreiheit) draft for your site
• Implementation support -- we do not just tell you what is wrong, we fix it

Why work with a Shopify-focused agency? Generic accessibility consultants often lack Shopify-specific knowledge. They will tell you to "fix the heading hierarchy" without knowing that it is controlled by the theme's product.liquid template and Shopify's default section schema. We know the platform, the Liquid template language, the Checkout Extensibility API, and the specific accessibility pitfalls of popular Shopify themes and apps.

Do not wait for an enforcement action to take this seriously. The BFSG deadline has passed. Every day your shop remains non-compliant is a day you are exposed to fines, lost customers, and legal risk. Get an audit, build a remediation plan, and start fixing issues -- in that order.

Contact TG-AI for a free initial accessibility assessment of your Shopify store.