Key Takeaways
- WCAG errors: 94.8 % of all websites have detectable WCAG errors, averaging 51 errors per home page (WebAIM, 2025).
- BFSG obligation: The Barrierefreiheitsstärkungsgesetz (BFSG) — Germany's Accessibility Strengthening Act — has been in force since 28 June 2025. Violations can result in fines of up to €100,000 (§ 37 BFSG).
- Micro-enterprises: Companies with fewer than 10 employees and annual turnover of no more than €2 million are exempt for services, but not for products.
- Retrofit costs: Adding accessibility after the fact is almost always more expensive and time-consuming than integrating it proactively during the initial website build.
Since 28 June 2025 the Barrierefreiheitsstärkungsgesetz (BFSG) has been in force. For many businesses, this is no longer an abstract compliance topic but a concrete project with time pressure, budget questions, and critical technical decisions to make.
94.8 % of websites analysed contain detectable WCAG errors, averaging 51 per home page (WebAIM Million Report 2025). At the same time, many decision-makers still do not fully understand who the law actually affects, what web accessibility means technically, and what a compliant website costs.
What Does Web Accessibility Mean?
WCAG as the International Standard
Web accessibility means that websites can be used by everyone, regardless of physical, sensory, or cognitive limitations. Visually impaired users rely on screen readers. Users with motor impairments navigate by keyboard or switch devices. People with cognitive disabilities need clear structures and plain language. Older users benefit from sufficiently large text and good contrast, without necessarily identifying as having a disability.
The international standard for web accessibility is the Web Content Accessibility Guidelines, known as WCAG. They are published by the World Wide Web Consortium (W3C). The current version is WCAG 2.2; the legally relevant baseline for Germany references WCAG 2.1. Public-sector bodies are additionally subject to the BITV 2.0 (Barrierefreie Informationstechnik-Verordnung). For private-sector companies, the BFSG is the binding obligation.
The Three Conformance Levels at a Glance
WCAG defines three conformance levels that describe the scope of requirements met:
- Level A: The minimum threshold. Content is accessible in at least some form to all users, although usability may still be noticeably limited in places. Without Level A, certain user groups are entirely excluded.
- Level AA: The legal minimum standard under the BFSG and the binding target for business websites in Germany. It covers adequate contrast requirements, full keyboard navigation, and comprehensible error messages. For most websites, this is the realistic and sensible goal.
- Level AAA: The highest conformance level, intended for specialised contexts such as educational platforms or healthcare portals. Full AAA conformance is not a realistic overall target for a typical B2B business website.
What surprises many decision-makers: WCAG Level AA is not a technical extreme sport. Sufficient colour contrast, a meaningful heading structure, alt text for images, keyboard-navigable forms. Looked at soberly, this is simply good web design. The fact that almost all websites still fail to meet it is due primarily to legacy systems and the absence of quality standards in the development process.
Who Does the BFSG Actually Affect?
When Does the Law Apply?
The Barrierefreiheitsstärkungsgesetz came into force on 28 June 2025. For products placed on the market on or after that date, the obligation applies immediately. For existing services, § 38 BFSG provides a transitional period until 28 June 2030, but only on the condition that earlier adaptation would constitute a disproportionate burden. Any business that cannot demonstrate compliance would be unreasonably costly is therefore required to act now.
The Micro-Enterprise Exemption
The BFSG exempts micro-enterprises with fewer than 10 employees and annual turnover of no more than €2 million. Crucially, this exemption applies only to services, not to products. A micro-enterprise that sells physical or digital products still falls under the law.
For most mid-sized B2B companies, this exemption is not relevant. Any business with more than 10 employees or annual turnover exceeding €2 million is fully subject to the obligation without restriction.
Which Websites Are Specifically Affected?
The obligation applies to all online offerings through which users can take transactional actions: buying, booking, enquiring, paying. Information websites without a direct transactional process do not automatically fall under the obligation, but they occupy a legal grey area. With fines of up to €100,000 possible, optimising on the margins of the rules is hardly advisable.
These online services may be subject to BFSG
- Online shops with purchase and ordering processes
- Websites with booking or appointment reservation functions
- Customer portals and self-service areas
- Mobile apps with direct consumer focus
- Banking and payment services
Anyone who intends to develop their website further should plan for WCAG 2.1 AA as a standard regardless of the formal obligation. The investment pays off.
What Are the 4 Principles of WCAG?
The WCAG are based on four core principles, known in the original as the POUR model. They structure all success criteria of WCAG 2.1 and give decision-makers a clear framework for understanding what kinds of problems to expect on their website.
Perceivable
Content must be accessible to all senses. Images need alt text so that screen readers can read them aloud. Videos need subtitles or transcripts. Text needs sufficient contrast against its background: at least 4.5:1 for normal text, 3:1 for large text.
This sounds like a modest requirement. In practice, 79.1 % of all websites examined fail on contrast alone, as the WebAIM Million Report 2025 demonstrates.
Operable
The entire website must be operable by keyboard, without a mouse. Keyboard navigation is not an edge-case requirement for a handful of exceptions. People with motor impairments, older users, and anyone who cannot use a pointing device depend on it. This also means that users must have enough time to read content: animations and automatically advancing elements must be pausable. A form that cannot be navigated with the Tab key excludes this group entirely before they even engage with the content.
Understandable
Content and interface behaviour must be predictable and understandable. This means clear error messages, consistent navigation, and language written in plain terms. A form that returns only "Error 400" on incorrect input is not understandable within the meaning of WCAG. A message such as "Please enter a valid email address" is.
Robust
Content must be processable by current and future assistive technologies. This means semantically correct HTML without proprietary custom structures. Screen readers, Braille displays, and other assistive tools rely on a button being recognisable as a button in the source code, not as a styled div element. Robust also means that validated, standards-compliant HTML forms the technical foundation so that assistive technologies continue to function correctly even after future software updates.
Which Accessibility Errors Appear Most Frequently on Business Websites?
The Most Common WCAG Errors According to WebAIM
The WebAIM Million Report analyses the home pages of the one million most-visited websites for WCAG conformance each year. It is considered the most comprehensive regular study of digital accessibility worldwide. The 2025 edition shows: 94.8 % of home pages analysed contain detectable WCAG errors, averaging 51 errors per page.
The six most common error categories:
The most common WCAG errors on German websites (WebAIM 2025)
- 79.1 % of pages: Insufficient colour contrast
- 55.5 % of pages: Missing alt texts for images
- 48.2 % of pages: Missing form labels
- 45.4 % of pages: Empty links without recognisable purpose
- 29.6 % of pages: Empty buttons
- 15.8 % of pages: Missing document language in HTML
Particularly Affected: B2B Websites in Germany
A study by Aktion Mensch, Google, and the Pfennigparade tested online shops for basic barriers. The finding: four in five German online shops fail the most basic accessibility tests. Keyboard navigation was the most frequently cited critical stumbling block.
The structural causes are well known: outdated WordPress themes that do not produce semantic HTML, page builders with uncontrolled output, and the absence of accessibility testing in the development process. These issues can be corrected; the effort required depends heavily on the underlying system.
Why Is an Accessible Website Also a Business Argument?
A Purchasing-Power Audience That Is Often Overlooked
7.9 million people in Germany have a recognised severe disability. This corresponds to 9.3 % of the total population. Added to this are people with temporary impairments, age-related vision deterioration, and users who simply do not have a pointing device to hand. Accessible websites reach these groups not as a special case but as regular users. According to an analysis by Google and Aktion Mensch, online shopping is central for 61 % of people with disabilities, compared to 51 % of people without disabilities.
Barriers Measurably Cost Revenue
The British Click-Away Pound Report examined how disabled users respond to inaccessible websites: 71 % leave the page immediately without purchasing. A Civey survey commissioned by Accessiway (August 2025, n=2,500) provides the German context: 80.7 % of consumers surveyed had abandoned a purchase at least once due to accessibility problems. This is not a niche problem. It is a systematic revenue gap.
Accessibility Strengthens Search Engine Visibility
Semantic HTML, clear heading hierarchies, alt text, and fast load times are simultaneously the technical foundations for good Google visibility. Both screen readers and search engine crawlers process the same HTML structure. Building accessibly also structurally improves rankings without setting up SEO as a separate project. Our article on CMS content strategy: an overview of all channels covers the connection between technical quality and content architecture in more detail.
What Does an Accessible Website Cost?
The Retrofitting Route
Retroactively correcting WCAG issues on existing websites is more expensive than it first appears. Outdated themes, proprietary page builders, and CMS systems without semantic output make isolated corrections time-consuming. Individual changes often touch dozens of template files simultaneously. According to W3C WAI, retrofitting is almost always more expensive than integration from the outset, because structural problems cannot be resolved through individual patches.
For businesses where a full rebuild is not on the table, retrofitting remains the viable path. The effort required varies considerably depending on the system and scope, and should be realistically assessed before the project begins.
Building Accessibility In from the Start
Anyone planning a relaunch can integrate accessibility as a baseline requirement into the architecture from the beginning. A headless CMS like Sanity structurally separates content from presentation. The frontend produces semantically correct HTML at component level. Once implemented correctly, the structure remains accessible regardless of who maintains content later.
Our article Why a Business Website Is Indispensable explains why a professionally built website is the foundation for lasting business success.
How Does an Accessible Website Relaunch Work?
A structured accessibility relaunch follows four phases.
Phase 1: Audit. Automated tests identify up to 57 % of all accessibility issues by number (Deque, 2021). The rest can only be found through manual testing: real keyboard navigation across all sections of the site, screen reader tests with different assistive software, and targeted contrast tests under varying output conditions.
Phase 2: Prioritisation. Not all errors carry the same weight. Critical barriers such as missing alt text on informative images or entirely inoperable forms come first. Lower-priority items such as decorative images with empty alt text are addressed afterwards.
Phase 3: Technical implementation. In a headless setup, structural corrections can be made at component level and then take effect across the entire site. This avoids the doubled and tripled effort that arises in monolithic systems when the same correction must be repeated across dozens of templates.
Phase 4: Testing and documentation. Before go-live, a systematic test using screen reader software is conducted. An internal conformance document records the implementation status and any justified exceptions.
Why Are Headless Websites Built with Next.js and Sanity Structurally Advantaged?
The Problem with Traditional CMS Systems
Many business websites on WordPress run on themes that were built years ago. The source code these themes produce is, technically speaking, a mixed bag: headings that are not headings at all, but large-styled text. Buttons built as image elements. Lists constructed from divs with spacing. To the human eye, this often looks fine. To screen readers and search engine crawlers, it is invisible noise.
Anyone who attempts to correct this after the fact quickly realises: every change pulls dozens of other places along with it. It is comparable to renovating an old building. You start in one place and encounter outdated wiring, hidden structural problems, and interdependencies that cannot be resolved in isolation.
How a Modern Setup Resolves This Structurally
Next.js and Sanity operate on a different principle. Sanity stores content as structured data: a heading is a heading, an image is an image with its own alt text field, a list is a list. The frontend in Next.js then defines how each of these elements appears on screen. Once, centrally, for the entire website.
When a paragraph is implemented in Next.js as a paragraph element with the correct language attribute, that applies to every page using that content type, whether there are ten or a thousand. Accessibility is therefore not a checklist at the end of the project, but an outcome of the architectural decision made at the beginning. Our article Turning Website Visitors into Customers: 9 Levers for More Enquiries explains how this improves user experience in practice and generates more leads.
From Evelan's Practice
In typical relaunch projects, we start with an accessibility audit of the existing website. What we regularly find: insufficient contrast, unlabelled form fields, images without alt text. On legacy systems with multiple CMS versions and page builders, these issues accumulate quickly.
When retrofitting fails due to fundamental technical limitations, we rebuild the website on a modern headless stack. After the relaunch, the site fully meets WCAG 2.1 AA requirements, and the internal team can maintain content independently, without needing developer support for every update.
Frequently Asked Questions
The BFSG affects all businesses that offer consumer-facing products or services in Germany, provided they do not qualify as micro-enterprises. Micro-enterprises (fewer than 10 employees, annual turnover of no more than €2 million) are exempt for services, but not for products. For the majority of mid-sized B2B companies, the obligation has applied without restriction since 28 June 2025.
Verwandte Evelan-Artikel
- CMS-Content-Strategie: Überblick über alle Kanäle
- Warum eine Unternehmens-Website unverzichtbar ist
- Website-Besucher zu Kunden machen: 9 Hebel für mehr Anfragen
Quellen
- WebAIM: The WebAIM Million — Accessibility Report 2025 (2025)
- Bundesfachstelle Barrierefreiheit: Testbericht barrierefreie Online-Shops (2024)
- gesetze-im-internet.de: Barrierefreiheitsstärkungsgesetz — § 37 Bußgeldvorschriften (2025)
- Destatis: Pressemitteilung Nr. 281 — Schwerbehinderte Menschen in Deutschland (2024)
- Google Blog / Aktion Mensch: Barrierefreiheit ist kein „Nice to have" (2023)
- Bundesfachstelle Barrierefreiheit: FAQ zum Barrierefreiheitsstärkungsgesetz (2025)
- Click-Away Pound: Business Case Report (2019)
- Accessiway / Civey: Digitale Barrieren kosten Unternehmen Kund:innen und Umsatz (2025)
- W3C: Web Content Accessibility Guidelines (WCAG) 2.2 (2024)
- Deque: Automated Testing Identifies 57 % of Digital Accessibility Issues (2021)



