The accessibility duty that started in June 2025
Whether it applies to you is a two part test with published numbers. The Barrierefreiheitsstärkungsgesetz requires products and services to be accessible, and exempts microenterprises providing services, defined as fewer than ten employees and either annual turnover or a balance sheet total of at most 2 million euros. The exemption covers services, not products.
The two questions that decide it
First: does your site conclude consumer contracts? The act covers services in electronic commerce, defined as digital services offered through websites and mobile applications, delivered electronically at the individual request of a consumer and aimed at concluding a consumer contract. A shop, a booking calendar and a paid appointment system fall inside. A page that lists your services and a telephone number is a different case.
Second: are you a microenterprise? The definition is exact: fewer than 10 employees, and either an annual turnover of at most 2 million euros or a balance sheet total of at most 2 million euros. Section 3 exempts microenterprises that provide services from the accessibility requirement.
What the numbers mean in practice
Put the thresholds together and the map is small. 2 conditions define a microenterprise, and the second is an either or, so a business under 10 employees with turnover above the line can still qualify through the balance sheet total, and the reverse holds too.
The exemption is narrower than it sounds in one respect: it covers services. A microenterprise that places a product on the market is not covered by that sentence. For a shop selling its own goods online, that distinction is worth reading carefully rather than assuming.
And the exemption is not a reason to build badly. The same measures that satisfy the act are the ones that make a site usable: text that resizes, contrast that holds, forms that can be completed with a keyboard. On a site with 9 pages that is an afternoon of work whether or not anyone can require it of you.
| Situation | Covered | Note |
|---|---|---|
| Online shop, ten or more employees | Yes | No microenterprise exemption |
| Booking system, fewer than 10 staff and under 2 million euros | Exempt as a service | Section 3 exemption |
| Brochure site, no contract concluded online | Different case | Not an electronic commerce service |
| Microenterprise placing a product on the market | Read carefully | The exemption names services |
Where to start if it does apply
Start with the contract flow, not the homepage. The pages that matter are the ones between choosing and paying, because that is what the act is about and it is also where an abandoned attempt costs you money.
Then fix the two failures that catch almost every small site: form fields without labels, and colour used as the only way to signal an error. Both are cheap, and both are visible to anyone testing you.
Questions and answers
What counts as a microenterprise?
Does the exemption cover everything?
Is a simple brochure site covered?
What should I fix first?
Sources
- Section 2 Barrierefreiheitsstärkungsgesetz (BFSG) The definition of a microenterprise and of electronic commerce services
- Section 3 Barrierefreiheitsstärkungsgesetz (BFSG) The accessibility requirement and the exemption for microenterprises
