Guides
Accessibility statement: Who needs one, what goes in it and a template
Who needs an accessibility statement under Germany's accessibility law, which details it must include and a template for your online shop or booking site.
By Christian Schmitt
4 min readKey takeawaysThe main points and every section to jump to.Show or hide the summary
- 01
You need an accessibility statement if you offer consumers a contract through your website and aren't a microenterprise.
- 02
For services, microenterprises with fewer than 10 employees and no more than €2 million in annual turnover or balance sheet total are exempt.
- 03
The law requires four details: a description of the service, explanations of how to use it, how it meets the requirements and the responsible market surveillance authority.
- 04
The statement goes into your terms or onto a clearly visible page of its own, as text and accessible itself.
- 05
A generator gives you the structure. Only an audit tells you what your site meets and what it doesn't.
You need an accessibility statement if you offer consumers a contract through your website, for example in an online shop, for a paid booking or a subscription, and your company isn’t a microenterprise. That’s been the rule in Germany since June 28, 2025, under the Barrierefreiheitsstärkungsgesetz (BFSG), which implements the European Accessibility Act. The law calls the document accessibility information. Annex 3 of the BFSG lists what goes in it, and you’ll find a template at the end of this article.
This article isn’t legal advice. If you’re unsure whether your offer falls under the BFSG, ask a law firm.
Who needs an accessibility statement
- Businesses that offer consumers contracts through their website: online shops, paid bookings, subscriptions, tickets, online banking and ebooks. The BFSG calls these electronic commerce services.
- Microenterprises are exempt when they provide such services: fewer than 10 employees and no more than €2 million in annual turnover or balance sheet total (Section 3 (3) BFSG).
- Public bodies publish an accessibility statement under separate German rules for the public sector. There, a feedback channel and a reference to the conciliation body are required.
A website through which no contract with consumers is concluded isn’t covered. That applies to most B2B websites and to sites that only inform and have a contact form. Accessibility still pays off there: people with low vision, older visitors and anyone reading on a phone in bright sunlight get along better.
What goes into the statement
Annex 3 of the BFSG lists four details:
- a general description of the service in an accessible format,
- descriptions and explanations needed to understand how the service works,
- a description of how the service meets the accessibility requirements,
- the responsible market surveillance authority.
These details aren’t required, but they make the statement credible:
- the date of the last audit and how it was done (self-assessment or external audit),
- known limitations and when they’ll be fixed,
- a contact where customers can report barriers.
For websites, the benchmark is the EN 301 549 standard, which refers to WCAG 2.1 at level AA for web content.
Where the statement goes
The BFSG requires you to make the information available in your terms and conditions or in another clearly visible way. In practice, that means a separate “Accessibility” page linked in the footer next to the legal notice and privacy policy, plus a reference to it in your terms.
The page itself has to be accessible. A scanned PDF or an image of text doesn’t meet that. Plain text on a web page does.
Accessibility statement template
The template is written for an online shop. Replace everything in square brackets and delete what doesn’t apply.
Accessibility information for [shop name]
Last updated: [date]
Our service: Through [domain], we sell [products] to consumers. Customers can search for products, add them to the cart, create an account and pay with [payment methods].
How a purchase works: [The steps from choosing a product to the order confirmation, in three to five sentences.]
How we meet the requirements: The website follows EN 301 549 and WCAG 2.1 at level AA. [Specifically what’s in place, for example: All functions work with a keyboard. Images have alt text. Form fields are labeled. Text can be enlarged to 200 percent.] Audited on [date] by [self-assessment or name of the auditor].
Known limitations: [For example: Older invoices in PDF format aren’t accessible. We’ll replace them by [date].]
Report a barrier: [email address and phone number]
Responsible market surveillance authority: Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF), [current address from mlbf-barrierefrei.de]
Generator or write it yourself
Generators, like the ones offered by legal text providers, give you the structure and required details in minutes. The third point, how your website meets the requirements, is something no generator can know. That takes an audit of your website: keyboard use, contrast, alt text, forms, error messages and the full checkout flow.
Never write “fully accessible” if nobody has checked. An honest list of known limitations with dates is better than a promise a customer can disprove in one click.
What happens if the statement is missing
Market surveillance can require you to fix shortcomings and set a deadline. If you don’t comply, it can ultimately prohibit the service. The BFSG provides for fines, up to €100,000 in serious cases. Consumers and associations can bring in market surveillance.
For what a website that meets the requirements looks like, and how I audit and rebuild existing websites, see the page on accessible websites.
Questions
Under the BFSG, usually not. The law covers services where consumers enter into a contract through the website. A purely informational site, or one that only targets businesses, isn't covered. Public bodies have their own rules.
In the BFSG, the document for businesses is called accessibility information. Public bodies publish an accessibility statement under a separate German law on equal treatment of people with disabilities. In everyday use, most people call both an accessibility statement.
The BFSG exempts microenterprises that provide services: fewer than 10 employees and no more than €2 million in annual turnover or balance sheet total. The exemption doesn't apply to products.
The joint market surveillance office of the German states for accessibility (MLBF) in Magdeburg. Take its current address from its website, mlbf-barrierefrei.de.
A generator gives you the structure and the required details. The description of how your website meets the requirements has to match your website. If you write "fully accessible" without an audit, the statement is wrong. This article isn't legal advice.
