Since 28 June 2025, accessibility has no longer been optional for many online shops -- it is a legal requirement. Germany's Accessibility Strengthening Act (BFSG) transposes the European Accessibility Act into national law and obliges operators to design their digital offerings so that people with disabilities can use them independently (Bundesfachstelle Barrierefreiheit, the German federal accessibility agency). The critical misconception in many projects: accessibility is treated as a one-off rebuild. In reality it is an ongoing process. Every theme update, every new plugin and every checkout change can break conformance that was already achieved. This article shows how a shop secures BFSG and EAA compliance over time -- through regular WCAG 2.2 AA checks, a maintained accessibility statement and a working feedback channel -- instead of establishing accessibility once and letting it decay. How this fits into the ongoing maintenance of an online shop is the common thread.
Why Accessibility Is Now Mandatory for Shops
The BFSG has been binding since 28 June 2025 and transposes EU Directive 2019/882, the European Accessibility Act, into national law (Bundesfachstelle Barrierefreiheit). It covers, among other things, services in electronic commerce -- the sale of goods and services to consumers via an online shop. Micro-enterprises in the service sector are exempt if they employ fewer than 10 people and at the same time reach less than 2 million euros in annual turnover or balance sheet total (Accessibility Strengthening Act (BFSG)). Anyone above that threshold who serves end customers must meet the requirements -- pure B2B shops are generally not covered, but can be as soon as they also sell to consumers.
The group that benefits is large. According to the European Commission, the European Accessibility Act makes access to products and services easier for at least 87 million people with disabilities in the EU -- almost one in five Europeans (European Accessibility Act (EAA)). In Germany, around 7.9 million people with severe disabilities lived at the end of 2023, which is 9.3 percent of the population (German Federal Statistical Office). Accessibility is therefore no niche topic: a representative survey shows that 71 percent of people in Germany want digital offerings to be designed accessibly, for example through simple operation and plain language (Bitkom).
Fines and Suspension of the Service
Accessibility Decays: Not a Project, but a State
Anyone who establishes accessibility once and then does not maintain it loses it gradually. The current WebAIM Million report examines the home pages of the one million most visited websites: 94.8 percent had automatically detectable WCAG failures, on average 51 errors per home page (WebAIM Million 2025). That figure describes a permanent condition, not a one-time problem. The reason lies in the nature of a shop: it is not a static document but a constantly changing application. With every release, markup, styles and scripts shift -- and with them the conditions for keyboard operation, focus, contrast and screen reader output.
Where Conformance Breaks Between Two Releases
Theme and Template Updates
An updated theme often brings new color values, changed focus styles or rebuilt components. Contrasts slip below the 4.5:1 threshold, the visible keyboard focus disappears -- and the previously passed check is void.
Plugin and App Updates
Extensions for filters, sliders or product configurators render their own markup. An update can remove ARIA attributes or break keyboard operation -- according to a test report, missing keyboard operability was the most common weakness (Aktion Mensch).
Checkout Changes
The order process is the most sensitive path. New payment methods or form fields without a linked label, without error output via role=alert, or with an illogical tab order make checkout unusable for screen reader users.
Everyday Content Editing
New category images without alt text, headings inserted via the editor in the wrong hierarchy, or untagged PDF data sheets introduce new barriers with no code change at all -- simply through the daily filling of the shop.
Embedded Third-Party Content
Review widgets, maps or chat windows deliver markup the operator can influence only partly. If the provider changes its script, focus traps or unlabeled controls can appear that affect the entire page.
Overlays and Cookie Banners
Consent dialogs that obscure content, fail to capture focus, or let tab navigation run into nowhere were among the most common barriers in the test (Aktion Mensch). An update of the banner tool can recreate these problems at any time.
Each of these triggers is unspectacular on its own -- together they cause conformance to erode slowly without accompanying oversight. This is exactly where structured regression testing after updates comes in, carrying accessibility as a fixed checkpoint instead of leaving it to chance. Anyone who tests changes first in a staging environment before the release catches regressions before they go live.
The Legal Framework: BFSG, EAA, EN 301 549 and WCAG 2.2
For practice, it matters how the rulebooks interlock. The BFSG forms the legal framework; the concrete requirements sit in the accompanying ordinance (BFSGV). For technical implementation, it refers to the harmonized European standard EN 301 549, which in turn references the Web Content Accessibility Guidelines (WCAG). Currently, EN 301 549 in version V3.2.1 incorporates WCAG version 2.1; an update to V4.1.1 referencing WCAG 2.2 is announced for 2026 (EN 301 549). Anyone aligning today with WCAG 2.2 at level AA is therefore already working toward the coming state.
| Layer | Role | What it governs |
|---|---|---|
| BFSG | Act (Germany) | Transposes the EAA, defines duties, exemptions and fines |
| BFSGV | Ordinance to the BFSG | Specifies the accessibility requirements for products and services |
| EN 301 549 | Harmonized EU standard | Technical reference standard with presumption of conformity |
| WCAG 2.2 | Technical guideline (W3C) | Testable success criteria under the principles perceivable, operable, understandable, robust |
| BITV 2.0 | Ordinance (public bodies) | Parallel rulebook for authorities -- same technical basis, EN 301 549 |
The concept of presumption of conformity is central here: if the requirements of the harmonized standard EN 301 549 in its respectively binding version are met, conformance with the legal accessibility requirements is presumed (EN 301 549 / WCAG 2.2). In practice this reverses the burden of proof in the operator's favor -- provided the fulfilment is documented and current. Without ongoing testing, this presumption remains a promise on paper, because the demonstrable state ages with every release.
What WCAG 2.2 at Level AA Concretely Requires
The WCAG are structured around four principles: content must be perceivable, operable, understandable and robust. Level AA is the conformance grade relevant for shops. Version 2.2 supplements the known criteria with new requirements, such as the keyboard focus not being obscured by other elements (2.4.11) and interactive controls having a sufficient target size (2.5.8). The following selection shows the points that most often break in a shop:
- Full operability by keyboard -- navigation, filters and checkout usable without a mouse.
- Visible, non-obscured keyboard focus on every interactive element (WCAG 2.2, 2.4.11 and 2.4.13).
- Sufficient color contrast of at least 4.5:1 for normal text and 3:1 for large text.
- Form fields with a firmly linked label, clear error messages and a reference via aria-describedby.
- Meaningful alternative texts for product images and functional graphics.
- A logical heading hierarchy and semantic structure for screen reader navigation.
- Sufficiently large click and tap targets plus consistent help and contact paths (WCAG 2.2, 2.5.8 and 3.2.6).
Keyboard Operation Is the Most Common Stumbling Block
Three Pillars of Lasting Conformance
Lasting accessibility rests on three pillars that together make the difference between a snapshot state and a resilient process. None of them is done with a single appointment -- all three must grow along with the shop as it changes.
Regular WCAG Testing
Automated tests cover part of the errors but do not replace a manual check with keyboard and screen reader. Only the combination of tooling and human review after each major release keeps the state reliably current.
A Maintained Accessibility Statement
A publicly available accessibility statement with a status, date and information on known limitations creates transparency. A template can be found in our own accessibility statement, which is updated with every relevant change.
A Working Feedback Channel
Users who encounter a barrier need a simple way to report it. A clearly named point of contact ensures that real problems become known promptly and feed into the next maintenance round.
The BFSG also obliges providers to supply generally understandable information on how their service meets the accessibility requirements. A maintained statement together with a feedback channel is therefore not just good form but pays directly into the legal information duties. Currency is key: a statement describing a state from three theme updates ago loses its value.
Anchoring Recurring Checks in the SLA Maintenance Contract
The three pillars only carry weight if they have a fixed place in operations. That is exactly what a maintenance contract with defined service levels delivers: it turns one-off actions into a recurring rhythm. Instead of leaving accessibility to itself after a relaunch, it becomes a checkpoint that is worked through again on every major release -- alongside security and functional tests. In an SLA maintenance contract, the cadence, scope and response times of these checks can be set out bindingly.
- After each major update, run a combined check of automated testing and manual review.
- Walk through the core flows -- catalog, product detail, cart and checkout -- deliberately by keyboard and screen reader.
- Re-check contrast, visible focus and heading structure on new or changed pages.
- Update the accessibility statement with a current date and known limitations.
- Review incoming feedback reports, prioritize them and route them into remediation.
- Document results and fixed barriers to keep the presumption of conformity demonstrable.
Accessibility is not a state you reach and tick off, but a property you have to reconfirm with every change.
In practice, interlocking with the rest of maintenance pays off. Anyone who couples the accessibility check to the same rhythm as Shopware maintenance or WordPress maintenance saves effort and catches regressions early. The checkout in particular deserves double attention: alongside operability, securing the payment flow against web skimming is also on the test plan. Ongoing care equally includes adjacent topics such as the deliverability of shop emails via DMARC and a regular plugin audit that checks extensions for currency.
Across 50+ supported projects (project experience), documented, recurring checks have proven the most solid basis for lasting conformance. Complemented by ongoing security updates and continuous monitoring of the core processes, this creates an operation in which accessibility is not re-fought on every release but preserved. Which checks make sense for your shop, we are happy to clarify in a personal conversation.
Sources and Studies