Edip Kilinc is the founder of Webwavers. Together with his team, he develops websites, brands, and digital presences for ambitious companies – with over 250 completed projects, and honored with awards including the German Design Award 2026.
The Accessibility Strengthening Act implements an EU directive and applies as of 28 June 2025 to products and services offered thereafter.
Affected are, among others:
Online shops and e-commerce of all sizes. Banking and payment services. Telecommunication services. Websites of passenger transport services. Booking systems for hotels, travel and appointments. Generally: Services in electronic commerce with consumers.
Not affected are:
Pure B2B offers, provided it is recognizable that they are not aimed at consumers. Pure information websites without contract conclusion. And micro-enterprises for services – more on that in a moment.
The distinction is not always clear-cut in individual cases. A website where you can book an appointment is different from one that only has a contact form. In case of doubt, a specialist lawyer will clarify this – this article does not constitute legal advice.
The Accessibility Strengthening Act implements an EU directive and applies as of 28 June 2025 to products and services offered thereafter.
Affected are, among others:
Online shops and e-commerce of all sizes. Banking and payment services. Telecommunication services. Websites of passenger transport services. Booking systems for hotels, travel and appointments. Generally: Services in electronic commerce with consumers.
Not affected are:
Pure B2B offers, provided it is recognizable that they are not aimed at consumers. Pure information websites without contract conclusion. And micro-enterprises for services – more on that in a moment.
The distinction is not always clear-cut in individual cases. A website where you can book an appointment is different from one that only has a contact form. In case of doubt, a specialist lawyer will clarify this – this article does not constitute legal advice.
An exception applies to services if both conditions are met:
Fewer than ten employees (calculated in annual work units) and an annual turnover or an annual balance sheet total of no more than two million euros.
Important: This exception only applies to services, not to products. Anyone who manufactures physical products that fall under the law cannot rely on it.
Equally important: The threshold is crossed faster than many assume. Ten employees are quickly reached in a growing company, and the exception then no longer applies.
A practical note: Even those who are exempt should know the requirements. A company that is below the threshold today and above it in two years will otherwise have to build the website twice.
The law refers to the European standard EN 301 549, which for digital offerings refers to the Web Content Accessibility Guidelines in levels A and AA. Currently, this is WCAG 2.1; future versions will refer to 2.2.
The most practically important requirements:
Contrast. Body text at least 4.5:1 to the background, large font and control elements at least 3:1. This is where most websites fail – light grey text on white is very common.
Keyboard operation. Everything must be accessible and operable without a mouse, with a visible focus indicator.
Alternative texts for all images that convey information.
Forms with linked labels and understandable error messages.
Structure. Meaningful heading hierarchy, regions correctly marked up.
Scalability. Up to 200 percent text enlargement without loss of information.
Videos with subtitles.
In addition to the technical aspects, there are formal obligations that are easily overlooked.
An accessibility statement. It describes how the offer meets the requirements, which parts may not be accessible, and why. It belongs on the website, accessible in the same way as the legal notice and privacy policy.
A feedback mechanism. Users must be able to report barriers, with a designated point of contact.
Documentation. How the requirements were implemented – this is required during an audit by the market surveillance authority.
Regarding enforcement: The market surveillance authorities of the federal states are responsible and can impose fines. In addition, there is a risk of competition law warning letters from competitors or associations.
How the practice of warning letters will develop cannot be reliably predicted at this time. Those affected should not rely on the assumption that nothing will happen.
Step 1 – Assessment. An automatic test uncovers about thirty to forty percent of the problems: missing alternative texts, contrasts that are too weak, missing labels. There are free tools for this.
Step 2 – Manual testing. The larger part can only be checked by hand. The three most important tests: Navigate the entire website using only the tab key. Fill out and submit all forms without a mouse. Zoom the font to 200 percent and check if everything is still readable.
Step 3 – Prioritize. First the paths through which transactions are completed: product page, shopping cart, checkout, form, booking. Then the rest.
Step 4 – Fix. Contrast and alternative texts are usually done in hours. Keyboard navigation and forms can mean development effort.
Step 5 – Publish declaration and set up the feedback channel.
A large portion of companies is not affected – pure B2B providers, information websites, micro-businesses. Nevertheless, some of the measures are still worthwhile for them.
Contrast improves readability for everyone, especially on smartphones in sunlight. This is not a niche topic.
Keyboard accessibility and clean form labels generally improve usability and reduce drop-offs.
Alternative texts help image search and are evaluated by generative systems.
Clear heading structure is also an SEO foundation.
Then there is the target group itself: about one-tenth of the population has an impairment that makes use more difficult. The proportion increases with age – and decision-makers in B2B are on average not young.
The overlap with good implementation is so great that most of the points pay off anyway.
