Accessibility: 5 Myths Put to the Fact Check

This article tests five common myths against the statute, official statements and standards. For the overview of obligation and benefit, see the article Digital Accessibility: Obligation or Opportunity?

Myth 1: Accessibility only concerns people with disabilities

The protective purpose of the BFSG concerns people with disabilities, but the benefit of the measures reaches further. The law defines them as people with long-term physical, mental, intellectual or sensory impairments who, in interaction with barriers, may be hindered from participating fully and equally in society. Long-term means: with high probability longer than six months (Section 2 No. 1 BFSG, statute text read on 11/09/2026). Section 1(1) BFSG names accessibility in the interest of consumers and users as its purpose, which at the same time is meant to strengthen the right of people with disabilities to participate in society.

How large and how old this group is, the Federal Statistical Office shows: At the end of 2025, just over 7.8 million people with a severe disability lived in Germany, the large majority of them aged 55 or older (Destatis, July 2026). In addition there are people with short-term impairments, for example after breaking an arm, or in difficult situations such as glaring sunlight. The same measures matter for them: clear contrast, keyboard operation, understandable forms. That is our assessment, not a measurement.

A scenario: The checkout of an online shop has unlabelled input fields. A screen reader user cannot match up her address, and a customer on a smartphone in glaring sunlight cannot read light grey hints. The same cause affects both, but only one of them has a recognised disability.

Myth 2: Digital accessibility is too expensive and too much effort

A blanket answer would not be credible, because the costs depend on the starting condition of the website. What is certain: The law does not grant a free pass for “too expensive”. The requirements apply only insofar as complying with them would not lead to a disproportionate burden, and the economic operator must make and document this assessment itself (Section 17(1) and (2) BFSG).

The documentation must be kept for five years from the last provision of the service and presented to the market surveillance authority on request (Section 17(2) BFSG). Service providers must repeat the assessment for each category of service at least every five years, and also whenever the service offered changes or the competent authority asks them to (Section 17(3) BFSG). Anyone who relies on the disproportionate burden for a specific service must inform the competent market surveillance authority without delay, except micro-enterprises (Section 17(5) BFSG). Anyone who receives funding of a third party, public or private, to improve accessibility, for example grants, may not rely on the exemption (Section 17(4) BFSG).

The assessment criteria are set out in Annex 4 BFSG: the ratio of net costs to total costs, the estimated costs and benefits in relation to the estimated benefit for people with disabilities, and the ratio of net costs to net turnover. As types of cost, Annex 4 names, among others, additional staff with accessibility expertise, training, production processes and the preparation of documentation. According to the press release of the Saxony-Anhalt state government of 1 June 2026, the joint market surveillance authority of the federal states (MLBF) also handles claimed disproportionate burdens. Costs can be controlled by prioritising by impact and starting with the pages through which customers order or get in touch, such as checkout and contact form. How to do that is shown in the article The Costliest Barrier Mistakes: Where Companies Should Start First.

Myth 3: Accessibility harms the design

Accessibility sets limits on individual properties, not on style. One example is contrast: WCAG success criterion 1.4.3 (Level AA) requires a contrast ratio of at least 4.5:1 for normal text and at least 3:1 for large text, from 18 point or 14 point bold (W3C, Understanding SC 1.4.3, read on 11/09/2026).

The criterion also applies to placeholder text in form fields and to text that appears on hover or keyboard focus. Logos and brand names are exempt, so the brand stays untouched. You should mainly check light grey help texts and text on coloured buttons.

This limits the colour choice for text, not the overall impression of a page. Often it is enough to darken the text colour slightly and keep the brand colour for decorative surfaces. User interface components such as buttons and input fields, and graphics that are needed to understand the content, need a contrast of at least 3:1 against their surroundings under WCAG 1.4.11 (Level AA) (W3C, Understanding SC 1.4.11). What accessible design looks like as a whole is shown on the knowledge page of the same name. Further examples on contrast, focus and click targets are in the article Accessible Design: Why Accessibility and Good Design Are Not at Odds.

Myth 4: Our target group does not need an accessible website

The law does not ask about your own assessment of your target group, but about whether consumers can conclude contracts with you. What matters is whether you offer an e-commerce service to consumers, that is, a digital service provided electronically, at a consumer's individual request, with a view to concluding a consumer contract (Section 1(3) No. 5 and Section 2 No. 26 BFSG). These provisions name no exemption for an assumed target group. The exemption for micro-enterprises that offer services (Section 3(3) BFSG) is tied to the size and nature of the offer.

Who counts as a consumer is defined in 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 scenario: A workwear shop sees tradespeople as its target group but also sells to private individuals. It then concludes consumer contracts, and the question of the obligation is answered by this offer, not by the shop's own description of its target group. You should have offers aimed exclusively at businesses assessed for the individual case.

In addition: Affected people do not necessarily report barriers to the provider. According to the Saxony-Anhalt state government, the MLBF works, among other things, on complaints and tips from consumers. Anyone who leaves does not show up in any statistic, that is our assessment. Whether your offer is covered is explained on the knowledge page BFSG: Who Is Affected by the Accessibility Strengthening Act?

Myth 5: Accessibility can be added later

Technically it can, legally only to a limited extent. The BFSG applies to services provided to consumers after 28 June 2025 (Section 1(3) BFSG). The transitional period under Section 38(1) allows certain products that service providers had already lawfully used before that date to continue to be used, at most until 27 June 2030. Contracts concluded before 28 June 2025 may continue unchanged until their end, likewise at most until 27 June 2030. The word “unchanged” is decisive: Whether and from which change a contract no longer falls under the rule must be examined case by case.

According to Taylor Wessing (July 2025), this is not a general grace period for services that fall under the BFSG. Anyone planning new pages, relaunches or features can plan requirements in from the start. How much that saves compared with retrofitting cannot be proven in general terms, which is why we give no percentage here. Further notes on deadlines and warning letters are on the page Avoiding BFSG Enforcement.

SiteCockpit: Making accessibility plannable

The myths have one thing in common: They treat accessibility as a one-off project. In reality, content, themes and extensions keep changing, and new barriers arise with them. SiteCockpit supports this process:

• ✓ easyMonitoring: Detects barriers on your website automatically and delivers prioritised to-dos, so you fix first what brings the most.
• ✓ 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.

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.

What makes sense now

No myth is a reason to wait, but none is a reason for panic either. Anyone who runs an offer for consumers should clarify their situation soberly and proceed step by step:

• ✓ Establish your status: Use the Livecheck to see how your most important pages perform today.
• ✓ Clarify your legal position: Clarify whether your offer falls under Section 1(3) BFSG and whether the exemption for micro-enterprises under Section 3(3) may apply to you. In case of doubt, seek legal advice.
• ✓ Set priorities and document: Fix the barriers with the greatest impact first. If you want to rely on a disproportionate burden, record the assessment in writing (Section 17 BFSG).

easyMonitoring helps you measure progress and prioritise the next tasks. Plan accessibility like maintenance: with clear responsibility and a check after every major change to templates, plugins or content.

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