The verdict in three sentences
If your Berlin SME sells online to consumers and has at least 10 employees or more than 2 million euros in turnover, the BFSG (Germany's transposition of the European Accessibility Act) has applied since 28 June 2025. A webshop failing 60 % of WCAG criteria can be brought into compliance in 6 to 12 weeks for 8,500 to 31,000 EUR including the audit, and the bill depends mainly on the number of templates, not the number of pages. Waiting costs more: an accessibility statement is mandatory, and market surveillance authorities can impose fines of up to 100,000 EUR under the BFSG, plus competitor cease-and-desist letters (Abmahnungen).
Who is covered and what the law actually requires
The BFSG covers e-commerce services aimed at consumers. An SME selling to both businesses and consumers falls within scope as soon as a consumer can order. Only service micro-enterprises (fewer than 10 employees and under 2 million euros turnover) are exempt.
| Obligation | What it means | 2026 order of magnitude |
|---|---|---|
| WCAG 2.1 AA / EN 301 549 conformance | Keyboard navigation, contrast, forms, text alternatives | Target 75 % minimum, 100 % aimed for |
| Accessibility statement | Public page describing the service and how it meets requirements | 1 day of writing |
| Multi-year improvement plan | 3-year roadmap, updated annually | 0.5 to 1 day |
| Footer link | Visible link to the statement | Immediate |
| Feedback channel | Form or email to report a barrier | Less than a day |
| Penalty for non-compliance | Order to remedy, then administrative fine | Up to 100,000 EUR |
The most misunderstood point: compliance covers the entire purchase journey. Product page, cart, account creation, payment and confirmation email must all work with a keyboard and a screen reader. An inaccessible payment provider remains your problem.
How much compliance costs
Budget is calculated per template (home, product list, product page, cart, checkout, customer account, editorial content). Fixing one product page component fixes all 800 product pages at once.
| Item | Small site (5 to 8 templates) | Mid-size site (10 to 15 templates) | Complex site (20+ templates) |
|---|---|---|---|
| WCAG audit on sample | 2,500 EUR | 4,000 EUR | 6,000 EUR |
| Front-end fixes (HTML, ARIA, CSS) | 4,000 EUR | 10,000 EUR | 18,000 EUR |
| Checkout and form fixes | 1,500 EUR | 3,500 EUR | 5,000 EUR |
| Validation re-audit | 800 EUR | 1,500 EUR | 2,000 EUR |
| Statement and multi-year plan | 400 EUR | 600 EUR | 800 EUR |
| Content team training (1 day) | 900 EUR | 1,200 EUR | 1,500 EUR |
| Indicative total | 10,100 EUR | 20,800 EUR | 33,300 EUR |
| Timeline | 6 weeks | 8 to 10 weeks | 12 weeks |
When the site runs on an old theme or a heavily customised CMS, an accessible-by-design rebuild sometimes costs less than remediation: allow 18,000 to 35,000 EUR for a new B2B and B2C webshop with built-in compliance, versus 20,000 to 33,000 EUR to fix the existing site without modernising anything else.
Prioritising fixes without freezing the business
| Priority | Typical defects | Share of failures | Impact |
|---|---|---|---|
| 1 | Checkout unusable by keyboard | 15 to 20 % | Blocking, lost sales |
| 2 | Forms without labels or error messages | 15 % | Blocking |
| 3 | Insufficient contrast (below 4.5:1) | 20 % | Major |
| 4 | Product images without alternatives | 15 % | Major |
| 5 | Heading structure and landmarks | 10 % | Medium |
| 6 | PDF content (datasheets, terms) | 10 to 15 % | Medium, often exemptable |
Tackle the purchase journey first: it carries the highest legal exposure and the best return, since form fixes also cut cart abandonment by 3 to 8 % according to usability audits.
Mini case study
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Jonas, managing director of a Berlin office-supplies SME (34 employees, 4.2 million euros turnover, 40 % online), receives an audit: 58 failing criteria out of 106 applicable, a 45 % conformance rate. His site has 12 templates.
Approved budget: audit 4,000 EUR, fixes 13,500 EUR, re-audit 1,500 EUR, statement 600 EUR, for 19,600 EUR over 9 weeks. Expected gain: with 1.68 million euros in online sales and a 3-point drop in cart abandonment, the estimate is 25,000 to 50,000 EUR in extra annual revenue. The investment pays back in 5 to 9 months, not counting the fine risk removed.
FAQ
My site mostly sells to businesses, am I covered?
Yes, as soon as a consumer can place an order. A portal strictly limited to verified business accounts is in principle out of scope, but 80 % of SME B2B sites also accept consumers.
Do I need 100 % WCAG conformance?
The law requires compliance, and practice accepts a documented trajectory. A 75 % rate with a credible multi-year plan protects you far better than 45 % with no statement.
Is an accessibility overlay plugin enough?
No. Overlays at 50 to 200 EUR a month do not fix source code or make a checkout compliant. They can even interfere with screen readers.
What does staying compliant cost?
Allow an annual re-audit of 1,500 to 3,000 EUR and a check on every new template. Training content teams prevents 70 % of regressions.
Who enforces this in Germany?
The joint state market surveillance authority (MLBF) in Magdeburg, plus competitors and consumer associations through Abmahnungen, which often trigger the first actions.
Let's scope your project. Send us your site URL and we will price the WCAG audit, the number of templates to fix and a 6 to 12 week schedule. Detailed quote within 48 h. WhatsApp +221 77 596 93 33.
Mohamed Bah
Fondateur, Kolonell
Passionate about digital and entrepreneurship in Africa, Mohamed has been helping Sénégalese businesses with their digital transformation since 2020. Founder of Kolonell, he believes every SME deserves a professional and accessible online présence.
