The verdict in three sentences
Since 28 June 2025, the European Accessibility Act, implemented in Germany by the Barrierefreiheitsstärkungsgesetz (BFSG), requires accessibility for e-commerce and several consumer digital services, unless the company is a microenterprise (fewer than 10 employees and no more than EUR 2 million turnover or balance sheet). For an affected Berlin SME, compliance means a WCAG 2.1 AA audit at EUR 1,500 to 4,500, fixes of EUR 3,000 to 15,000 on an existing site, or an accessible-by-design redesign that adds 10 to 20% to the budget. Doing nothing exposes the firm to fines of up to EUR 100,000, an order to withdraw the service and warning letters from competitors.
Who is covered, and which websites
The obligation targets services provided to consumers: online shops, paid appointment booking, reservations, banking services, ticketing, e-books. A purely corporate site of an SME that sells only to businesses is outside the scope, but many B2B firms have an order area open to consumers or an online quote tool that brings them in. Compliance is measured against EN 301 549, aligned with WCAG 2.1 level AA.
| SME situation | Covered by the EAA | Practical obligations |
|---|---|---|
| Fewer than 10 employees and EUR 2 million or less | No (microenterprise exemption) | Accessibility recommended |
| B2C e-commerce, 10 or more employees | Yes | WCAG AA compliance, accessibility statement |
| B2B corporate site without transactions | Generally no | Good practice, required by some public buyers |
| Ordering module open to consumers | Yes | Accessible checkout journey |
| Online booking or ticketing | Yes | Accessible forms and payment |
| Companion mobile app | Yes | Same requirements as the website |
Compliance budget in 2026
The ranges below are 2026 estimates for an SME with 10 to 100 employees, a site of 30 to 150 pages and a checkout flow.
| Item | 2026 range (EUR, excl. VAT) | Comment |
|---|---|---|
| WCAG audit on a 15 to 25 page sample | 1,500 to 4,500 | Criterion-by-criterion report, compliance rate |
| Fixes on an existing site | 3,000 to 15,000 | Depends on theme and plugin technical debt |
| Accessible-by-design redesign | +10 to 20% of budget | Cheaper than fixing an old site |
| Accessibility statement and service information | 400 to 1,200 | Mandatory publication under the BFSG |
| Editor training | 600 to 1,500 per day | Alt text, headings, links, PDFs |
| Accessible PDF remediation | 30 to 120 per document | Product sheets, terms, catalogs |
| Re-audit after fixes | 800 to 2,000 | Evidence of compliance if inspected |
Rule of thumb: above EUR 8,000 of estimated fixes on a site older than 5 years, an accessible redesign often costs less over 3 years than a retrofit that will need redoing.
The most expensive criteria and enforcement in Germany
The BFSG is enforced by the joint market surveillance authority of the federal states (MLBF), operating since 2025. Early checks focus on missing accessibility statements and blocking checkout journeys, and competitor warning letters (Abmahnungen) add a private enforcement risk. The criteria that drive the budget are rarely the most visible ones.
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| WCAG area | Indicative fix cost (EUR) | Why it is expensive |
|---|---|---|
| Full keyboard navigation (2.1) | 1,500 to 5,000 | Menus, carousels and modals to rework |
| Labeled forms and error messages (3.3) | 1,000 to 4,000 | Checkout, sign-up, payment |
| Color contrast (1.4.3) | 500 to 3,000 | May require brand color changes |
| JavaScript components with ARIA (4.1.2) | 1,500 to 6,000 | Product filters, variant pickers |
| Image alternatives (1.1.1) | 300 to 1,500 | Size of the product catalog |
| Accessible PDF documents | 30 to 120 per document | Often forgotten in estimates |
Mini case study
Sophie, managing director of a 28-employee Berlin SME with EUR 4.2 million turnover that sells office equipment to consumers and businesses, has her site audited: 41% WCAG compliance. Fixes are estimated at EUR 11,500 on a 7-year-old site, plus EUR 3,000 for audit and re-audit, EUR 14,500 in total. The redesign planned for 2027, budgeted at EUR 35,000, would rise to EUR 40,000 in an accessible-by-design version, a EUR 5,000 premium. She brings the redesign forward by a year and saves about EUR 9,500 compared with fixing first and redesigning later. A bonus measured on comparable sites: 5 to 10% lower cart abandonment thanks to clearer forms.
FAQ
My SME sells only to businesses, am I covered? In principle no, the EAA targets consumer services. But if your site accepts orders from consumers, even a minority, the checkout journey falls within scope.
What must the accessibility statement contain? A description of the service, how it meets accessibility requirements, known limitations and a contact for reporting issues. Drafting it costs EUR 400 to 1,200.
Is an accessibility overlay plugin enough? No, automated overlays at EUR 30 to 50 a month do not make a site compliant and are criticized by disability organizations. Only fixing code and content improves real compliance.
How long does compliance take? Allow 2 to 3 weeks for the audit, then 4 to 10 weeks of fixes depending on scope. An accessible redesign takes 10 to 16 weeks.
What is the concrete risk? An order to remedy, then fines of up to EUR 100,000 under the BFSG, possible withdrawal of the service and costly competitor warning letters, often EUR 1,000 to 3,000 each in legal fees.
Let's scope your project. For an SME with 10 to 250 employees, we scope the WCAG audit, fixes or accessible redesign with the accessibility statement, within EUR 4,500 to 20,000 depending on the state of the site, delivered in 6 to 16 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.
