The Accessibility Enhancement Act (BFSG) has been in force since 2025. Anyone in the WordPress bubble who is still hoping that this issue will pass them by unnoticed not only risks legal trouble, but may also be missing out on revenue.
Accessibility isn’t just a tedious compliance project that ruins your design. If approached correctly, it can be a powerful driver of your Google ranking, your conversion rate and – for agencies – a profitable business model.
Key points at a glance
- Legal requirement for B2C: The BFSG will be fully in force from June 2025. Virtually all B2C websites with a transactional focus (WooCommerce shops, booking tools, portals) must be accessible. Purely B2B sites are exempt.
- Be careful with the micro-enterprise scheme: the exemption (fewer than 10 employees and a maximum turnover of €2 million) applies explicitly only to pure service provision. As soon as a WooCommerce shop is involved, this exemption no longer applies.
- The liability trap for agencies: Although the operator is legally liable, agencies face the risk of civil claims for defective work if they fail to provide their clients with verifiable information.
- Accessibility in WordPress Core: The core WordPress installation provides the basics, but isn’t perfect in terms of accessibility. Modern themes that cover the key features are a better option.
- The SEO & Performance Boost: Google works like a blind user. By making your website accessible, you’re also optimising it for Googlebot, which can lead to greater visibility, particularly in Google AI Overviews.
- Genuine quality assurance rather than tools: A 100% Lighthouse score does not provide legal certainty, as automated scans, by their very nature, only detect around 30 to 40 per cent of barriers. Only an official BITV/WCAG test, complete with a seal for the footer, can guarantee absolute certainty.
Digital barriers in everyday WordPress use
When we talk about accessibility, many people immediately think of those who are completely blind. But that is far too narrow a view. It affects over 15 per cent of the population – including older people, those with colour vision deficiencies, people with mobility impairments, and those with concentration difficulties.
In a typical WordPress infrastructure, these users face three major hurdles every day:
- The visual barrier: Many modern WooCommerce themes use extremely subtle, low-contrast shades of grey for input fields in the checkout area. Older customers or people with impaired vision abandon their purchase at this very stage because they simply cannot see where they are supposed to enter their details.
- The motor barrier: Anyone who cannot use a mouse has to navigate WordPress websites using only the keyboard. However, many popular slider plugins, pop-ups and cookie banners are designed to be used only with a mouse. Once a pop-up opens, it blocks keyboard focus – from that moment on, the website becomes a dead end for the user.
- The cognitive barrier: extremely convoluted mega-menus, overloaded with countless sub-items, overwhelm many people. What is intended to look ‘impressive’ visually actually causes confusion and high bounce rates in practice.
Why accessibility is good for your WordPress SEO and revenue
If you optimise your WordPress site in line with the official WCAG guidelines, you will automatically create a technically up-to-date website.
Google is the biggest ‘blind’ user of your website
The Google bot has no eyes. It analyses your page exactly as a screen reader would read it out: as plain source code.
- If you structure your content in the Gutenberg editor using a logical heading hierarchy (H1 – H2 – H3), the crawler will immediately understand the context of your page.
- If you enter accurate ALT text in the WordPress media library, this can lead to better rankings in Google Images.
- Clean HTML5 landmarks also tell the bot where the main content is located. This saves valuable crawl budget.
The ticket to Google’s AI Overview (AIO)
We are in the midst of the age of AI search. Large language models (LLMs) and Google’s AI search results draw their answers directly from structured website content.
The more semantic and accessible your WordPress site is, the easier it is for AI bots to identify your content as a trustworthy source and display it in AI result boxes. Unstructured code is increasingly being ignored by modern algorithms.
Loading times and Core Web Vitals
If you swap out outdated, bloated page builders for lean, accessible Full Site Editing (FSE) block themes, you’ll significantly reduce the DOM size (the number of HTML elements) of your WordPress site.
Less bloated code means the browser renders the page significantly faster. Your Core Web Vitals – particularly Largest Contentful Paint (LCP) and Interaction to Next Paint (INP) – improve noticeably.
Legal situation in 2026: Who must take action and who is liable?
The grace periods under the BFSG have now ended. Anyone operating a website that does not comply with accessibility requirements today risks costly warning letters and fines.
Who is responsible?
The purpose of your website is key to the law. The focus is on electronic commerce in the B2C sector. Immediate action is required in the following cases:
- WooCommerce shops: Any online shop that sells products to end consumers. The size of the business is irrelevant here.
- Booking platforms & appointment tools: Any WordPress site where services, appointments or tickets can be booked for a fee.
- Digital services: members’ areas, SaaS offerings or portals aimed at consumers.
Purely B2B websites and static corporate websites without any transactional or interactive functions are currently exempt from the strict penalties under the BFSG. Furthermore, the micro-enterprise exemption (fewer than 10 employees AND turnover of less than 2 million euros) applies explicitly only to pure service provision, and never to online retail.
The liability trap for WordPress agencies
Legally, it is always the owner (operator) of the website who is liable to the authorities.
However, if an agency is commissioned to create a website or an online shop in accordance with the ‘current state of the art’, compliance with the law is automatically part of the work to be delivered. If the agency delivers a shop that is not accessible, the client can sue them for damages and free rectification on the grounds of defective work.
Proactively inform your clients. Include accessibility as a standard, fixed item in your quotations. If a client wishes to omit the technical adjustments for budgetary reasons, ensure they sign this waiver in writing as part of the contract. This ensures that the risk is clearly documented and lies with the client.
Opportunities for agencies: generating revenue through relaunches and audits
The BFSG is not a necessary evil, but rather the strongest argument in favour of professional WordPress development. The era of ‘€500 website builders’ is over, because these systems rarely meet the legal requirements.
Make the most of this topic for your agency: proactively offer BFSG audits to your existing clients. Check their themes, form plugins and cookie banners for accessibility. In most cases, a controlled relaunch based on a modern block theme is the more cost-effective and higher-performing option for the client – and ensures predictable revenue for your agency.
The WordPress ecosystem: What does the core provide, and what doesn’t it?
The biggest challenge in the WordPress ecosystem is also its greatest strength: its modularity. A WordPress website rarely consists solely of the system itself. It is a combination of the WP core, a theme, various plugins (e.g. WooCommerce) and custom code snippets. And this is precisely where the accessibility pitfall lies.
WordPress ‘out of the box’: Where the CMS really shines
The WordPress Core Team is doing an excellent job. The Gutenberg block editor is designed to be accessible to use in the backend and to output semantically clean code in the frontend. When you insert an image, the editor practically forces you to think about the ALT text fields. Standard structural elements such as tables or lists are also cleanly marked up in the core HTML with the necessary attributes.
What can’t the basic version of WordPress do?
The problem arises as soon as third-party developers come into the picture. WordPress does not guarantee that plugins from the official repository are accessible.
- The page builder problem: Traditional drag-and-drop builders (such as older versions of Elementor, Divi or WPBakery) are, by their very design, prone to what is known as ‘DOM bloat’. They nest endless chains of meaningless <div> containers to create visual layouts. This poses a major challenge for screen readers, as there is no clear association between the content and its layout.
- Interactive plugins: A contact form plugin, a smart cookie banner or a fancy events calendar – many of these tools are programmed exclusively for mouse interaction. Keyboard users are often unable to close pop-ups, or these pop-ups jump around invisibly in the background of the page when they use the Tab key.
The solution: a modern theme
If you want to build your projects in a way that is future-proof and compliant with the BFSG, you should opt for a modern theme.
Full Site Editing (FSE) themes such as Ollie or the official default themes (such as Twenty Twenty-Five) do away with unnecessary code. They use native HTML5 and ensure that core functions such as the main menu or the search feature are fully keyboard-navigable by design – without any error-prone JavaScript workarounds.
Other modern themes, such as Kadence, Blocksy and Astra, also offer good built-in features for creating an accessible website.
Quality Assurance & Certificates: How to safeguard your WordPress projects
As an agency or online shop operator, how do you prove that your WordPress platform is legally compliant?
A 100% Lighthouse score is not enough
Free testing tools (such as Google Lighthouse in Chrome DevTools or the WAVE extension) are useful for getting an initial overview. However, their algorithms only detect around 30 to 40 per cent of all accessibility errors.
Example: A tool can check whether an image in your WordPress media library has an alt attribute. However, it cannot logically assess whether the text entered as alt=”blue background” provides a meaningful description of a complex infographic for a blind person or is simply keyword stuffing.
The reliable approach: the official BIK BITV / WCAG test
To ensure maximum legal certainty (and to present a genuine mark of quality to your customers), you should aim to have a professional audit carried out. The gold standard in German-speaking countries is the BIK BITV test (or the BIK WCAG test).
As part of this process, certified experts assess your website using over 90 specific checkpoints based on the WCAG 2.2 criteria. The process is modular:
- Page selection: A representative selection of your WordPress subpages (e.g. home page, blog post, WooCommerce product page, checkout process) is defined.
- Human testing: The experts test the pages manually using genuine assistive technologies (screen readers) and various keyboard scenarios.
- Audit Report & Seal: If you pass the test without any issues, your website will be added to the official list of accessible sites and you will receive a valid seal of approval, which you can display prominently in the footer of your WordPress site. For agencies, having such a seal in their portfolio is a great way to showcase their excellent craftsmanship.
Frequently Asked Questions (FAQ) about WordPress, the BFSG and accessibility
What are the key accessibility guidelines?
The technical framework is provided worldwide by the Web Content Accessibility Guidelines (WCAG 2.2) at Conformity Level AA. In Germany, these requirements are enshrined in the Accessible Information Technology Ordinance for public bodies. Since mid-2025, the Act to Strengthen Accessibility has also been in force, which legally obliges many private companies in the B2C sector – particularly in e-commerce and digital services – to ensure accessibility.
Are there any legal exemptions, for example for micro-enterprises?
The law provides for a specific exemption for micro-enterprises with fewer than ten employees and an annual turnover of no more than two million euros. However, this exemption applies expressly only to services. As soon as physical products are sold via the WordPress website through e-commerce – in other words, when a WooCommerce shop is active – this exemption ceases to apply entirely, and even small businesses must comply fully with the legal requirements.
Are documents uploaded to the WP media library, such as PDFs, also affected by the BFSG?
Yes, without exception. If a website or digital service falls within the scope of the law, this obligation applies to the entire service provided. This means that all documents offered for download that are necessary for the core process or for providing consumer information must be made accessible. Typical examples include product data sheets, terms and conditions documents or digital menus, which must comply with the official PDF/UA standard.
Is a 100% score on Google Lighthouse sufficient for legal protection?
No, that’s not enough. By their very nature, automated tools such as Lighthouse or WAVE can only detect around 30 to 40 per cent of all potential barriers. Whilst a tool can use an algorithm to detect whether an image has an alt attribute, it cannot logically verify whether the text provided accurately conveys the meaning of a complex infographic to a blind person. Only a manual review by experts can ensure absolute legal certainty.
What impact does accessibility have on WordPress SEO and the Core Web Vitals?
This has a significant impact, as search engines analyse a website in a similar way to assistive technologies. If a WordPress site is structured using semantic HTML5 and clear headings, Googlebot can understand the context much more accurately, which forms the basis for its appearance in AI search results. Furthermore, accessible themes drastically reduce the DOM size, which improves rendering times and optimises your Core Web Vitals.
Who monitors compliance with the BFSG online, and what are the penalties for breaches?
Compliance with the law is monitored by the market surveillance authorities in the individual federal states; furthermore, civil law warnings may be issued by trade associations. The consequences of non-compliance are severe. In addition to heavy fines, the authorities may, in the worst-case scenario, order the immediate suspension of the digital service or the blocking of the online shop.
Leave a Reply