The verdict in three sentences
Since 28 June 2025, the European Accessibility Act (EAA) applies in Germany through the Barrierefreiheitsstärkungsgesetz (BFSG), covering e-commerce, banking, transport and other consumer services. A 60-employee Berlin company in scope should plan 4,000 to 9,000 EUR for an audit and 6,000 to 18,000 EUR for fixes, over 6 to 10 weeks. The risk is concrete: market surveillance authorities can order compliance, take services off the market and impose fines of up to 100,000 EUR, while competitors and consumer associations can also bring claims.
Are you in scope? The decision table
The EAA does not treat every website the same way. It mainly targets services provided to consumers. A purely corporate B2B site may fall outside the legal obligation, but an online shop, customer account or booking module open to consumers falls inside. Service microenterprises (fewer than 10 employees and under 2 million EUR turnover) are exempt.
| Company situation | EAA / BFSG obligation | Recommendation |
|---|---|---|
| B2B brochure site with no transactions | No, in principle | Aim for WCAG anyway for tenders |
| Online sales also open to consumers | Yes | Audit and accessibility statement required |
| Banking or insurance customer portal | Yes | Priority audit |
| Ticketing, transport, travel booking | Yes | Priority audit |
| Service microenterprise (< 10 staff, < 2 M EUR) | Exempt | Good practice recommended |
| Supplier to a large corporate or public buyer | Often contractual | WCAG statement requested in bids |
The company in our example sells spare parts online to tradespeople but also to consumers: it falls within the BFSG.
The cost of compliance, step by step
The technical benchmark is EN 301 549, which references WCAG 2.1 level AA (50 success criteria). In Germany, the BITV 2.0 test procedure is often used as a practical checklist. The work runs in four steps.
| Step | Indicative cost (EUR) | Timeline | Deliverable |
|---|---|---|---|
| WCAG audit on a sample of 10 to 20 pages | 4,000 - 9,000 | 2 weeks | Criterion-by-criterion report, conformance rate |
| Theme and component fixes | 3,500 - 10,000 | 3 to 5 weeks | Menus, forms, contrast, keyboard focus |
| Content fixes (images, PDFs, videos) | 1,800 - 5,000 | 1 to 3 weeks | Text alternatives, captions |
| Checkout and customer account | 700 - 3,000 | Included | Journey tested with screen readers |
| Re-audit and accessibility statement | 1,000 - 2,000 | 1 week | Published statement in German and English |
| Editor training | 800 - 1,500 | 1 day | Accessible publishing rules |
In total, audit plus fixes, most SMEs land between 10,000 and 27,000 EUR. A recent site built on clean components is cheaper to fix; an older site on a heavy page builder may justify a partial rebuild.
The non-conformities we find most often
| Defect found | Share of B2B sites audited | Fix effort |
|---|---|---|
| Insufficient text contrast | 85% | Low |
| Form fields without associated labels | 70% | Low to medium |
| No keyboard navigation (menus, modals) | 60% | Medium |
| Images without meaningful alternatives | 75% | Low |
| Inaccessible technical PDFs | 80% | Medium to high |
| No accessibility statement | 90% | Low |
| Videos without captions | 65% | Medium |
Mini case study
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Katrin, managing director of a 60-employee industrial company in Berlin, makes 1.8 million EUR in online sales, 20% of it from consumers. She orders a WCAG audit at 6,500 EUR, then 11,000 EUR of fixes, 17,500 EUR over 8 weeks. Conformance rises from 41% to 87%. On the other side of the scale: a BFSG fine of up to 100,000 EUR, possible cease-and-desist claims and the risk of losing a corporate client worth 120,000 EUR a year that now asks for an accessibility statement. A measured bonus: mobile checkout completion rises 6%, about 21,600 EUR of extra yearly sales.
FAQ
Does the European Accessibility Act apply to a B2B website?
It mainly targets services provided to consumers: a purely B2B site without transactions is not, in principle, in scope. As soon as you sell online to consumers, even for 10% of turnover, the BFSG applies.
What are the penalties under the BFSG?
Market surveillance authorities can order corrections, restrict the service and impose fines of up to 100,000 EUR. Under German unfair competition law, competitors and associations can also send formal warnings.
How much does a WCAG audit cost in Berlin?
Count 4,000 to 9,000 EUR for a sample of 10 to 20 pages, with manual testing and screen readers (NVDA, VoiceOver). An automated scan alone catches about 30% of issues.
Do we need 100% conformance?
No, but you must publish your real status, the known exceptions and a remediation plan. A conformance rate above 75% usually supports a credible partial conformance statement.
How long does compliance take?
Between 6 and 10 weeks for an SME: 2 weeks of audit, 3 to 6 weeks of fixes, then 1 to 2 weeks of re-audit and statement drafting.
Let's scope your project. We audit your website against WCAG 2.1 AA, price every fix and draft your accessibility statement, for an indicative budget of 10,000 to 27,000 EUR and compliance in 6 to 10 weeks. 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.
