BFSG and WordPress: What Operators Should Check Now

This article answers four questions: Does the BFSG apply to your WordPress site? What does the law require on an ongoing basis? What matters for themes and forms? And what do plugins deliver, and what not?

Does the BFSG apply to your WordPress site?

That depends on the offer, not on WordPress. The BFSG covers e-commerce services for consumers (Section 1(3) No. 5 BFSG, statute text read on 11/09/2026). These are digital services offered via websites and provided electronically, at a consumer's individual request, with a view to concluding a consumer contract (Section 2 No. 26 BFSG). A WooCommerce shop is a typical example. For a company site or a blog without a contract conclusion, the classification depends on the individual case.

The consumer definition is decisive: A consumer is, under Section 2 No. 16 BFSG, any natural person who buys or receives a product or service falling under this Act for purposes that cannot be attributed predominantly to their trade, business or profession. A shop that also sells to private individuals is therefore in a different position from an offer aimed exclusively at businesses. In case of doubt, you should have this assessed for your individual case.

Micro-enterprises that offer services are exempt (Section 3(3) BFSG). A micro-enterprise is one that employs fewer than ten people and has either an annual turnover of at most 2 million euros or an annual balance sheet total of at most 2 million euros (Section 2 No. 17 BFSG). The headcount and one of the two financial limits must be met together.

The law also exempts certain content, including archive content that is neither updated nor revised after 28 June 2025, and third-party content that the operator neither finances, develops nor controls (Section 1(4) No. 4 and 5 BFSG). Whether an old blog post or an embedded item falls under this is a case-by-case question. Who the law covers in detail is explained on the knowledge page BFSG: Who Is Affected by the Accessibility Strengthening Act? For the overview of obligation and benefit, see the article Digital Accessibility: Obligation or Opportunity?

What the law requires on an ongoing basis: updates included

Accessibility is not a one-off state with WordPress. Under Section 14(3) BFSG, the service provider must ensure that the accessibility requirements are always met for as long as it offers the service. It must give due account to changes in the way the service is provided, to changes in the applicable accessibility requirements and to changes in the harmonised standards or technical specifications (statute text read on 11/09/2026).

Whether a theme, plugin or WordPress update is such a change in the individual case depends on its effects. An update can, however, change contrast, focus display or forms, that is our assessment. If a service is not conformant, the provider must take the necessary corrective measures and inform the market surveillance authority without delay (Section 14(4) BFSG). It must also prepare the information under Annex 3 No. 1 and make it available to the public in an accessible form (Section 14(1) No. 2 BFSG): in its general terms and conditions or in another clearly perceivable way, how the service meets the accessibility requirements, including the competent market surveillance authority. This is a statutory information duty. The term “accessibility statement” does not appear in the text of the statute, but in practice it is often used for publishing this information. On the reasoned request of the market surveillance authority, it must in addition provide all information required to demonstrate conformity (Section 14(5) BFSG). Therefore keep a record of what you checked and when. How an accessibility statement is structured is shown on the knowledge page Accessibility Statement.

Accessible theme: What “Accessibility Ready” means

The “Accessibility Ready” tag in the WordPress theme directory is a minimum standard, not proof of conformity. The WordPress Developer Resources state that the tag does not mean a theme meets WCAG at Level AA. The Theme Review Handbook adds that such themes should not be construed as meeting any level of formal accessibility requirements (both read on 11/09/2026).

Themes with the tag go through an accessibility review before they are published. If a theme fails, it is still approved according to the Theme Review Handbook, but must remove the tag. The WordPress Accessibility Team revised the requirements for the tag in May 2026. Theme authors had until 30 June 2026 to update their themes or remove the tag. In the theme directory you can search for such themes using the “Accessibility Ready” filter. For your selection this means: The tag is a good starting point but does not replace your own check. Test the theme with your real content for keyboard operation, visible focus, contrast and a clean heading structure. Basics on this are on the knowledge page Accessible Design.

Forms, content and page builders: What to look out for

An accessible theme does not guarantee accessible content, because forms, images and page structure arise in everyday editorial work. For forms, visible labels, understandable error messages and keyboard operation count. The WordPress Developer Resources require, for example, that error messages also make sense when read out of context (read on 11/09/2026). More in the article Building Accessible Forms: A Guide for Online Shops.

For images, alternative texts belong in the media library, and for pages a logical heading hierarchy. This applies regardless of whether you work with Gutenberg, Elementor or WPBakery, because the editor determines the structure that ends up in the browser.

What plugins deliver and where their limits lie

A plugin can support implementation, but it does not replace the obligation under Section 14 BFSG, because that lies with the service provider. Roughly three groups can be distinguished: testing tools that find barriers, adjustment widgets that give visitors settings, and extensions that improve individual elements such as forms. Automated checks detect only what can be established by machine: They can see whether an alternative text exists, not whether it makes sense. That is our assessment. Before using a plugin, check how actively it is maintained, with which WordPress and PHP versions it has been tested and whether it changes your theme or your forms. A new plugin is also a change to the way you provide the service and therefore belongs in your checks. Why a widget alone is not enough is explained in the article The Overlay Problem: Why a Widget Will Not Protect You From an Accessibility Warning Letter.

The SiteCockpit plugin for WordPress integrates easyVision. According to the help center, you install and activate it via the WordPress plugin directory and enter the integration key from the SiteCockpit dashboard under “SiteCockpit Key” (read on 11/09/2026). If you prefer to work without a plugin or run a PHP version that is too old, you can integrate the script via a child theme, according to the help center. easyVision gives visitors adjustment options and complements the removal of barriers, it does not replace it.

SiteCockpit: Keeping accessibility in WordPress in view

Because themes, plugins and content keep changing, accessibility only works as a process. SiteCockpit supports it:

• ✓ easyMonitoring: Checks your website continuously, detects barriers after changes and delivers prioritised to-dos.
• ✓ easyStatement: Creates a current accessibility statement based on real test results.
• ✓ easyVision: Gives visitors adjustment options such as contrast, line spacing or a dyslexia-friendly font. It complements the removal of barriers and does not replace it.
• ✓ Manual audits: The audit combines the automated check with easyMonitoring with manual tests against WCAG 2.1 and 2.2 and delivers a report with recommendations.

The Livecheck is free: You enter your URL and receive an automated check of key criteria such as contrast, alternative texts and heading structure.

What makes sense now

No reason to rush, but a reason for structure. Anyone who runs an offer for consumers with WordPress and does not fall under the micro-enterprise exemption should proceed in this order:

• ✓ Classify your offer: Clarify whether your site falls under Section 1(3) BFSG and whether the exemption under Section 3(3) may apply. In case of doubt, seek legal advice.
• ✓ Check theme, forms and core pages: Start with the homepage, checkout and contact form and check keyboard operation, focus, contrast and labels.
• ✓ Define checks after changes: Decide who spot-checks the most important pages after theme, plugin and WordPress updates.

Where to start first is shown in the article The Costliest Barrier Mistakes: Where Companies Should Start First. easyMonitoring helps you measure progress and prioritise the next tasks.

Note: This article provides general information on the legal situation (as of 11/09/2026) and does not replace individual legal advice.