Since summer 2025, the most expensive sentence in a manufacturing company has been: “The shop is only a side channel.” From a sales perspective that may be true, as most revenue still goes through retailers. For the Accessibility Strengthening Act, the category “side channel” does not exist. A shop through which a consumer can place an order is a service in electronic commerce, and has been from day one.
If your own D2C (direct-to-consumer) shop only brings in a small share of revenue, it is tempting to delegate the topic to the e-commerce team. Two reassuring assumptions usually come with it: perhaps you count as a micro-enterprise, and if all else fails, the transition period until 2030 applies. Without replacing legal advice: neither holds up to scrutiny.
Who the BFSG affects in e-commerce: manufacturers selling B2C
For a manufacturer, the question splits into two channels. The dealer portal, where only business customers with a customer number log in, is not consumer business. The D2C shop next to it is. A consumer within the meaning of § 2 No. 16 also includes the fitter at one of your specialist dealers who privately orders a device of your brand there.
The IHK Nordwestfalen (Chamber of Industry and Commerce) sums it up like this: pure B2B offers are not affected, provided they really are aimed only at businesses. The legal basis is § 1(3) No. 5 BFSG: the act applies to “services in electronic commerce”, which § 2 No. 26 defines as digital services provided via websites or apps at the individual request of a consumer with a view to concluding a consumer contract.
Whether you produce garden furniture, tools or pet food makes no difference to the shop obligation. Only if you also manufacture products listed in § 1(2), such as smartphones (as consumer terminal equipment for telecommunications services) or e-book readers, do you have additional manufacturer obligations for the product itself.
Why the micro-enterprise exemption rarely applies to manufacturers
The exemption is set out in § 3(3) BFSG: the accessibility requirement does not apply to micro-enterprises that provide services. Under § 2 No. 17, a micro-enterprise is one that employs fewer than ten people and has either an annual turnover of no more than €2 million or a balance sheet total of no more than €2 million. The headcount must always be below the threshold, plus one of the two financial figures.
The reference point is the company, not the channel. A manufacturer with 60 employees, two of them in e-commerce, is not a micro-enterprise, even if the shop only turns over €400,000. The exemption is aimed at very small businesses such as a craft business with a web shop; for a manufacturer with its own production, it is only relevant for very small workshop manufacturers.
An example scenario: a small manufacturing workshop with nine employees, €3 million turnover and a €1.5 million balance sheet total remains a micro-enterprise, because the balance sheet total is below the threshold. Turnover and balance sheet total are alternatives. The statement “as soon as one is exceeded, the obligation applies” is not what the act says.
The exemption also only applies to services; for products within the scope, § 16 and § 17 only provide relief on documentation and reporting. Moving the shop into a mini company below the threshold is a question for your lawyer. We advise against it.
What the act requires of a manufacturer’s shop
§ 3(1) BFSG requires that people with disabilities can find, access and use your shop in the generally customary way, without particular difficulty and, in principle, without outside help. The details are set out in the ordinance: § 3 BFSGV (the implementing ordinance to the BFSG) requires the “state of the art” and names neither WCAG nor a standard.
Anyone building today builds to WCAG 2.2 AA, with WCAG 2.1 AA as the minimum. The current version of the European standard EN 301 549, V4.1.1 (2026-09), bases its web chapters on WCAG 2.2 and is the first version written for Directive (EU) 2019/882.
As of October 2026, however, only the older V3.2.1, based on WCAG 2.1, is published in the EU Official Journal, cited under the Web Accessibility Directive for public sector bodies. That is why neither version currently triggers a presumption of conformity under § 4 BFSG. The standard nevertheless remains the yardstick for testing.
On top of this comes an information obligation that is often confused with the accessibility statement required of public bodies. § 14(1) BFSG requires the information listed in Annex 3. At a minimum, this includes:
- a general description of the service in an accessible format,
- explanations of how the service is carried out,
- a description of how the requirements are met,
- the name of the competent market surveillance authority.
So do you need the statement with conformity status, test date and feedback form that appears on every government website? No. Only public bodies owe that, under the BGG (German Disability Equality Act) and the BITV (German Barrier-Free Information Technology Ordinance) or the corresponding state law. A two-minute test: can you find at least the four items in the footer or in your terms and conditions, including the competent authority? If one is missing, you are in breach of § 14(1).
And § 14(3) turns this into an ongoing obligation: the requirements must continue to be met for as long as the service is offered, including changes to standards. For a manufacturer, this means every PIM import is a release, and both have to maintain the level.
In short: the current standard says WCAG 2.2 AA, the one cited in the Official Journal still says WCAG 2.1 AA; on top of that come at least four mandatory items of information, both on a permanent basis.
Where D2C shops typically get stuck: product data, configurators, satellites
Our assessment, and at the same time the core argument of this article: the biggest barriers in a manufacturer’s shop cannot be fixed in the theme, because the theme only displays the data. Images, variants and descriptions come from the ERP or the PIM, and there the alternative text is usually not a mandatory field. The result is thousands of product images whose alt text is empty, contains only the item number or, as the fallback of the Shopware default storefront, repeats the same product name for every image.
A worked example: 4,000 items with an average of five variants and three images per variant add up to 60,000 alt texts. If you add them in the shop afterwards, you type 60,000 times and risk the next PIM export overwriting everything.
Colour swatches without text labels, size selection by slider, availability shown only as a red or green icon: this is what configurators and variant selectors for manufacturers’ products often look like, and that is where keyboard and screen reader operation fails. If the colour cannot be selected, the visitor never gets as far as the basket.
Who owns the dealer locator? The map is embedded from a third-party service, the PDF data sheets and assembly instructions come from technical documentation, the product videos run without subtitles, and the campaign landing pages are built in the marketing tool. Legally, they are generally part of the service; organisationally, they belong to nobody.
Under § 1(4) BFSG, exemptions include videos and office documents such as PDFs published before 28 June 2025, online maps provided the essential information (for a dealer locator: the addresses) is also available in accessible form, and third-party content that you neither fund, develop nor control. New data sheets and videos have been fully subject to the obligation since then.
The trickiest case is mixed operation: B2B login and consumer shop in one frontend, where the same button shows net prices to the dealer and opens the basket for the guest. If a consumer can order there as a guest, in our reading the frontend as a whole is a B2C service. You can separate the two with separate sales channels, in Shopware two sales channels with their own domains, not with a password in front of the dealer area.
Procedure, fines and the 2030 misunderstanding
The competent body is the Market Surveillance Authority of the German Federal States for the Accessibility of Products and Services (MLBF). It monitors nationwide and provides forms for consumers to report barriers or file an application under § 32 BFSG. Your end customers are not the only ones who know your shop. Your dealers know it too.
The procedure is set out in three stages in § 29 BFSG: a request to remedy the issue within a reasonable period set by the authority, a renewed request with the threat of a prohibition, then an order to discontinue the offer. The act does not specify a fixed length for the period.
An example scenario: a customer using a screen reader cannot get past the colour swatches in the configurator and reports this to the MLBF. If the defect is confirmed, the first deadline starts. If the cause lies in the theme, it is a development ticket. If the colour names are missing in the PIM, the work starts in product data management, which until then knows nothing about the procedure.
Independently of this, fines apply under § 37 BFSG: up to €100,000 if a service is offered in breach of § 14(1), i.e. not accessible or without the information required by Annex 3. Failing to report an identified non-conformity to the authority, among other things, can cost up to €10,000.
What of this is real today, as of October 2026: we are not aware of any publicly documented individual fines under the BFSG, nor of any court decision on whether breaches can be challenged with cease-and-desist letters under competition law. Anyone quoting you cease-and-desist amounts for BFSG breaches is not citing a primary source. The risk lies in the procedure, in the remediation effort under time pressure and in your reputation with end customers and with the dealers who know your shop.
And on the 2030 misunderstanding: § 38 BFSG allows products that were lawfully in use before 28 June 2025 to continue to be used until 27 June 2030, and existing contracts to run out. For the website itself, this extends nothing. Your shop had to be accessible by the cut-off date.
Implementing the BFSG in Shopware: the order for manufacturers
Shopware 6 is a sensible foundation, but no customer ever sees the storefront in its out-of-the-box state. Themes, plugins and integrations rebuild it, and each part can introduce barriers. The detailed review of contrast, forms, checkout and cookie banners is in our BFSG checklist for Shopware 6, so we won’t repeat it here.
- Data. Alt texts, variant names and document titles get a mandatory field and an approval step at the source, in the PIM or ERP. This is the step where manufacturer projects tip over, because it takes place outside the shop and needs a responsible person in product data management.
- Automated first assessment. Our BFSG check tests the home page and one subpage against WCAG 2.1 and 2.2 and delivers a score with findings. It is not proof of conformity, as automated rules only cover some of the criteria. You have to walk through checkout, account creation and the configurator manually with a keyboard and screen reader.
- Theme and plugins. Every extension, one by one, against the findings. Typical cases: a configurator plugin whose colour swatches can only be reached with a mouse, or a slider plugin without a focus order. Whatever cannot be fixed gets replaced.
- Information under Annex 3. Accessible, with the MLBF named as the competent authority.
- Routine operation. Without it, the level is gone again after three plugin updates. Accessibility belongs in every release and every major PIM import as a test step. Whether in-house or through external Shopware support: what matters is that someone owns the test step and it is firmly part of the release plan.
Conclusion: accessibility starts in the product data
The act treats your D2C shop like any other shop, and as a manufacturer you generally cannot rely on the micro-enterprise exemption. Most of the requirements are solid craftsmanship, and Shopware 6 provides the foundation.
For a retailer, the problem is usually in the theme; for a manufacturer, it is in the product data. If you hand accessibility to an agency as a design project and leave the ERP and PIM untouched, you will have the same problem with new images in twelve months. So treat the topic like the ERP integration: as an integration task with a responsible person in-house.
How to set up D2C properly as a manufacturer, from ERP integration to the dealer portal, is shown on our page for manufacturers with D2C.