2026 annual review · Editorial allocation: 5/2026. Added retrospectively on 13 November 2026. The allocation date is not the original publication date.
For e-commerce, navigation, authentication and payment need to work together. An add-on tool does not replace an assessment of the actual service.
Legal context
Covered consumer services have been subject to BFSG requirements since 28 June 2025. Scope, exemptions and transitional provisions require individual assessment. For e-commerce, section 19 BFSGV specifically addresses identification, authentication, security and payment functions. Businesses should combine technical testing with assigned responsibility and documented remediation.
Four practical examples
These illustrative scenarios are not reports of client mandates.
Checkout
A retailer tests completion using a keyboard and relevant assistive technology.
Authentication
A portal checks whether its login mechanism blocks access to the service.
Documents
Contract information is included in the accessibility assessment.
Supplier
A company agrees the scope of testing and remediation with its agency.
Preparing the next step
Preserve the relevant agreements, technical records and correspondence. Identify the decision required and any deadline. The legal assessment depends on the individual facts and applicable rules.