Running a BFSG check on your website is the first step toward compliance with Germany's accessibility law. An automated scan catches about 30 to 40 percent of issues — missing alt text, contrast failures, unlabeled form fields — in under two minutes. But the remaining 60 percent requires manual testing: keyboard navigation, screen reader flows, and cognitive load assessment. This guide walks you through both, gives you a scoring framework, and shows you exactly where your site stands.
What a BFSG Check Actually Tests
A BFSG compliance check evaluates whether your website meets the technical requirements defined in EN 301 549, which maps to WCAG 2.1 Level AA. That means testing 50 success criteria across four categories: Perceivable (can users see or hear the content?), Operable (can users navigate and interact?), Understandable (can users comprehend the content and interface?), and Robust (does the content work with assistive technologies?).
A thorough BFSG check goes beyond just running a scanner. It should cover three layers: automated detection of code-level issues, semi-automated testing where a tool guides you through manual checks, and pure manual testing with keyboard-only navigation and screen readers.
The BFSG also requires a published accessibility statement (Erklärung zur Barrierefreiheit). Your check should verify that this statement exists, contains the required information, and reflects the actual state of your site.
Automated BFSG Scanning Tools
Automated tools are your starting point. They crawl your pages, inspect the HTML and CSS, and flag violations against WCAG 2.1 AA criteria. The best tools test for contrast ratios below 4.5:1, images without alt attributes, form inputs without associated labels, missing document language declaration, heading hierarchy violations, and ARIA roles used incorrectly.
A free scan with Web Accessibility Checker gives you an instant compliance score, a prioritized list of issues, and specific code-level fixes. The scanner tests against EN 301 549 and maps results directly to BFSG requirements — so you know exactly which legal obligations each issue relates to.
Other credible automated tools include axe DevTools (browser extension, good for developers), WAVE by WebAIM (visual overlay showing issues in context), and Lighthouse (built into Chrome DevTools, covers basic accessibility audits). Each has strengths, but none catches everything. A 2024 study by the UK Government Digital Service found that no single automated tool detected more than 42 percent of WCAG 2.1 AA failures.
Why Automated Testing Is Not Enough
Automated tools excel at finding structural issues in code. They struggle with context. Can a screen reader user understand the purpose of this link? Is the error message on this form actually helpful? Does the tab order through the checkout flow make logical sense? These questions require human judgment.
The GDS study found that 58 percent of accessibility issues required manual evaluation. For BFSG compliance specifically, these manual-only issues include whether video content has adequate audio descriptions, whether complex data tables have proper header associations, whether custom JavaScript widgets are keyboard-operable and announce state changes, and whether the reading order of content matches the visual layout.
Relying solely on automated scans creates a dangerous false sense of security. A site that passes every automated check can still have severe barriers for users with disabilities — and still face an Abmahnung.
Manual Testing: Keyboard and Screen Reader
Start with keyboard testing. Unplug your mouse (or disable your trackpad) and try to complete key tasks on your website using only the Tab, Enter, Escape, and arrow keys. Can you reach every interactive element? Can you see where the focus is at all times? Can you operate dropdown menus, modal dialogs, and carousels? Can you complete a purchase or fill out a contact form?
Keyboard traps are a common BFSG violation. These occur when focus enters a component (like a modal or embedded map) but cannot exit using standard keyboard controls. Users get stuck. This is a WCAG 2.1.2 failure and a clear BFSG violation.
Next, test with a screen reader. NVDA (free, Windows) and VoiceOver (built into macOS and iOS) are the most used. Navigate your entire site listening to how the screen reader announces headings, links, form labels, and dynamic content. Does the page title make sense? Are images described meaningfully? Do form errors announce themselves? Does the checkout confirmation read correctly?
For most businesses, an hour of keyboard testing and an hour of screen reader testing reveals more real-world barriers than a week of automated scanning.
A BFSG Compliance Scoring Framework
Quantifying your compliance level helps prioritize fixes and track progress. Here is a practical scoring framework aligned with BFSG requirements:
Level A — Automated Pass (0-40 points): All automated checks pass. No critical code-level violations. Contrast ratios meet minimums. All images have alt text. All forms have labels. Document language is declared. This is the baseline — necessary but not sufficient.
Level B — Keyboard Accessible (41-70 points): All interactive elements reachable and operable via keyboard. No keyboard traps. Visible focus indicators on all elements. Logical tab order through pages. Skip navigation link functional.
Level C — Screen Reader Compatible (71-90 points): Content reads in logical order. Dynamic updates announced via ARIA live regions. Form validation errors announced. Custom widgets follow WAI-ARIA patterns. Data tables properly associated with headers.
Level D — Full Compliance (91-100 points): Accessibility statement published with all required BFSG fields. Feedback mechanism operational. Ongoing monitoring in place. Staff trained on accessibility requirements. Documentation of compliance process maintained.
Most sites that have never been audited score between 15 and 30 on this framework. The DataPulse study that found 99 percent non-compliance was essentially measuring Level A failures — the most basic issues.
Running Your First BFSG Check: Step by Step
Step 1: Automated scan. Run your homepage, a product page, your checkout page, and your contact form through Web Accessibility Checker. Note the overall score and the top five issues by severity.
Step 2: Check your accessibility statement. Does it exist? Does it include the conformance level you claim, the date of the last assessment, a description of any known limitations, and contact information for accessibility feedback? If any of these are missing, you are non-compliant regardless of your technical score. Use our accessibility statement generator to create one.
Step 3: Keyboard walkthrough. Spend 30 minutes navigating your site with keyboard only. Document every point where you get stuck, lose visible focus, or cannot complete a task.
Step 4: Quick screen reader test. Enable VoiceOver (Cmd+F5 on Mac) or install NVDA on Windows. Navigate your homepage and one key user flow. Note where the screen reader output is confusing, missing, or incorrect.
Step 5: Prioritize and fix. Address critical issues first: keyboard traps, missing form labels, zero-contrast text, and the accessibility statement. These are the violations most likely to trigger Abmahnungen because they are easy to verify and clearly documented in the law.
How Often Should You Run a BFSG Check?
Accessibility is not a one-time project. Content changes, new features ship, third-party widgets update, and compliance drifts. A responsible approach includes automated scans after every deployment (integrate into your CI/CD pipeline), a full manual audit quarterly, a comprehensive third-party audit annually, and spot checks whenever you add new page templates, forms, or interactive components.
The BFSG does not specify audit frequency, but enforcement authorities and courts will look at whether you made reasonable ongoing efforts. A single audit from 2024 does not demonstrate compliance in 2026 if your site has changed significantly since then.
Setting up continuous monitoring — where automated checks run on every deployment and flag new issues before they reach production — is the most cost-effective approach. It catches regressions early, when they are cheap to fix, rather than letting them accumulate into an expensive remediation project or an Abmahnung.
Common BFSG Check Failures in German Online Shops
After scanning hundreds of German e-commerce sites, certain patterns emerge repeatedly. Product image carousels that trap keyboard focus and have no alt text beyond the filename. Cookie consent banners that cannot be dismissed via keyboard. Filter and sorting controls built with custom JavaScript that screen readers cannot operate. Checkout forms where error messages appear visually but are not announced to assistive technologies. Search autocomplete dropdowns that are invisible to screen readers.
These are not edge cases. They appear on major German retail sites and small Shopify stores alike. The difference is that major retailers have legal departments that negotiate Abmahnungen quietly, while small shop owners face disproportionate financial pressure from the same violations.
Fixing these specific patterns covers a large percentage of real-world BFSG violations in e-commerce. Start with your checkout flow — it is the highest-risk area because it is where accessibility failures directly prevent people from completing transactions.