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Accessibility for trade websites: what the law means

Which landscaping websites fall under the German accessibility act, which do not, and which adjustments are worth making regardless of the legal answer.

14 min read BarrierefreiheitBFSGWebsiteFormulareRecht

The German accessibility act (Barrierefreiheitsstärkungsgesetz, BFSG) came into force on 28 June 2025. Since then two opposing views have circulated among trade businesses: one holds that every company website now needs a costly rebuild, the other that trades are not covered at all, so nothing has to change. Both fall short, and clarifying the matter takes less than half an hour. This article sets out which landscaping websites fall under the act and which do not, which requirements apply if they do — and which adjustments pay off regardless of the legal answer, because more people can then see your projects and complete your enquiry form. It does not replace legal advice; assessing a specific case belongs in qualified hands.

German accessibility act: does it apply to my business?1 Contract, purchase or booking on the site?2 Is the offer aimed at consumers?3 Ten or more staff or over 2 million euro?Yes to all three: requirements applyplus a statement on accessibilityyesyesyesInformation site only: act does not applyBusiness customers only: does not applyMicro-enterprise: exemption for servicesnononoAssessing a specific case remains a matter for a lawyer.

Key takeaways

  • The German accessibility act has applied since 28 June 2025 (BFSG) and covers services provided through electronic commerce — that is, wherever consumers can book, order, pay or enter into a contract via the website.
  • A purely informational site with services, references, directions and a contact form is not treated as electronic commerce under the prevailing reading and therefore does not trigger the obligations of the act.
  • Businesses with fewer than ten employees and no more than two million euro in annual turnover or balance sheet total are exempt for services (BFSG); the exemption lapses as soon as the business grows past those thresholds.
  • Contrast of at least 4.5:1 for body text, full operation without a mouse and alternative text for project images (WCAG 2.2) are worth doing regardless of the law, because they work on small screens and in bright sunlight.
  • Overlay widgets that enlarge text at the press of a button do not replace an accessible site; what lasts are corrections to colours, structure, forms and image descriptions, done in winter without seasonal pressure.

What the act governs — and what it does not

The German accessibility act transposes a European directive into national law, creating uniform accessibility requirements for certain products and services across the single market (European Commission). The legislator pursues two aims: people with disabilities should be able to use digital offerings independently, and providers should encounter the same rules in every member state. What matters for classification is the scope: the act addresses the private sector and does not cover every website there, but a defined set of products and services.

Public bodies are not the subject of this act — authorities, municipalities and publicly controlled organisations have been governed by separate rules for years. For a landscaping business that matters in one respect: the requirements placed on a municipal tendering platform differ from those placed on your own company website. Anyone working on public contracts meets the topic from two sides without both sides triggering the same duties.

The act itself prescribes neither pixel values nor colour values. It refers to recognised technical standards; in practice that means the European standard EN 301 549, which in turn builds on the Web Content Accessibility Guidelines. Those guidelines currently exist in version 2.2 and set out testable success criteria at three levels. The middle level, AA, is the relevant one. So anyone asking what concretely needs doing inevitably arrives at that catalogue of criteria — even where the legal question is answered in the negative for their own business.

Keep three layers apart

The BFSG is the German act and determines who is obliged. EN 301 549 is the European standard it refers to. The Web Content Accessibility Guidelines version 2.2 contain the concrete, testable criteria. Anyone discussing contrast values or focus indicators is discussing the third layer — not the wording of the act.

Who in the trades is covered — and who is not

The decisive dividing line runs between a website that informs and a website through which business is transacted. Covered are services in electronic commerce aimed at consumers — put simply, processes in which someone orders, books, pays, holds an account or concludes a contract through the site. A company website that explains services, shows references, names the service area and offers a contact form does not, under the prevailing reading, meet those criteria. It is digital self-presentation, not electronic contracting.

The typical presence of a landscaping business therefore falls outside the obligations at first. That changes as soon as functions are added that go beyond information. A customer portal where facility managers view their maintenance contracts, a booking system with binding confirmation, a small shop for plants, grit or vouchers — such building blocks shift the classification. Before extending a landscaping website it is therefore worth asking whether the new function moves the site into a different legal state.

A second boundary runs between consumers and business customers. Anyone working exclusively for property managers, municipalities, developers and industrial clients, and making digital offerings available only to them, operates outside the consumer relationship the act attaches to. In landscaping, however, that separation is rarely clean: many businesses serve grounds maintenance and private gardens in parallel. As soon as an offering is open to private clients, the consumer perspective applies.

Element on the company websiteClassificationWhat follows from it
Services, references, team, contact formInformation without contractingObligations do not apply under the prevailing reading
Appointment booking with binding confirmationElectronic service aimed at consumersReview needed, mind the micro-enterprise exemption
Selling plants, grit or vouchersElectronic commerceRequirements apply above the thresholds
Customer portal for maintenance contractsElectronic serviceReview needed, even with few users
Portal open only to property managersNo consumer relationshipObligations of the act do not apply
Application form with file uploadNo contract concluded on the siteLegally uncritical in most cases, still worth building accessibly

The micro-enterprise exemption in plain terms

Even where a website offers business functions, an exemption applies to small providers. Anyone employing fewer than ten people in providing services and reaching no more than two million euro in annual turnover or annual balance sheet total is exempt from the requirements (BFSG). A large share of landscaping businesses sits below that threshold, particularly in rural areas.

That exemption comes with three catches which often get lost in the discussion. First, it applies to services only, not to products within the meaning of the act. Second, it is not a permanent licence: a business growing past the headcount or turnover limit loses it, and no one sends a notification. Third, it says nothing about other duties. A legal notice, a privacy policy and fair price information remain in place irrespective of company size.

For counting employees what matters is people rather than full-time equivalents in the bookkeeping sense — determining this precisely is a point for legal advice based on your figures. In practice that means a business with eight permanent staff and seasonal helpers should work the threshold through carefully before any larger extension of the website, rather than relying on the exemption in general terms.

The exemption does not end the thinking

Anyone below the thresholds need not implement anything — but may. And should check whether the reasons for accessibility apply anyway: older clients, screens in sunlight, one-handed operation on site. The legal finding and the business benefit are two different questions.

Worth doing anyway: contrast and font size

Regardless of the legal position, one sober fact remains: a considerable share of your clients no longer sees as well as they did at thirty. A good 22 per cent of the population in Germany is 65 or older (Federal Statistical Office), and more than 7.8 million people hold a recognised severe disability status (Federal Statistical Office). In landscaping this group is over-represented, because anyone having a terrace renewed or a garden rebuilt for low maintenance is often in the second half of life and has lived in the house for decades.

The single most effective lever is contrast. The criteria call for a ratio of at least 4.5:1 between text and background for normal body text, and 3:1 for large text from around 24 pixels (WCAG 2.2). This is exactly where many company websites fail, because light grey type on white looks elegant on an office monitor — and becomes unreadable on a phone in the partial shade of a building site. The value can be measured with free checking tools in minutes; it is not a matter of taste but a calculation.

The second lever is font size together with scalability. Content should enlarge to 200 per cent without text disappearing, overlapping or forcing horizontal scrolling (WCAG 2.2). Zooming your own site twice while watching whether the navigation stays operable and the phone number stays visible is a surprisingly informative test that takes a minute.

Measure contrast

Body text from 4.5:1, large headings from 3:1 (WCAG 2.2). The usual offenders are the footer, image captions and light text placed over photographs — the places nobody looked at during the build.

Keep type scalable

At 200 per cent nothing may disappear or overlap (WCAG 2.2). Fixed heights on cards and buttons are the most common cause of truncated lines.

Never let colour speak alone

A required field with only a red outline tells a colour-blind user nothing. Errors and states need an additional word or symbol.

Make focus visible

The element currently in focus needs a clearly recognisable outline. Many templates switch this indicator off for aesthetic reasons — which is a genuine exclusion.

Large enough targets

Controls should measure at least 24 by 24 pixels (WCAG 2.2). The usual offenders are small icons in image galleries and tightly spaced menu items in the phone layout.

Let motion be stopped

Automatically rotating image sliders are among the least loved elements. Anyone using them needs a way to pause them — a calm gallery is the better answer.

Keyboard operation: the ten-minute test

People with restricted movement, with tremor or with severe visual impairment operate websites without a mouse. They move from element to element with the tab key and trigger actions with the enter key. If that does not work, the site is not merely hard for them to use, it is unusable. That is the hard difference between accessibility and comfort: text that is too small is unpleasant, a button that cannot be reached is a closed door.

The test requires no expertise and no tooling. Open your home page, put the mouse aside and work through the page with the tab key until the enquiry form has been submitted. Note every point where you get stuck or lose sight of where you are. That list is already half the specification for putting things right.

  1. Open the home page, put the mouse aside and press tab — is the first element in focus visibly highlighted?
  2. Continue through the main navigation: can submenus be opened without hovering the pointer over them?
  3. Check the consent dialogue for data processing: does it capture focus, and can it be closed without a mouse?
  4. Move into the portfolio gallery: are individual images reachable, and can you leave an enlarged view again?
  5. Complete and submit the enquiry form — does it stay clear which field you are in at every step?
  6. Provoke an error, for instance an incomplete email address: is the message given as text and the focus moved to it?

Experience shows the run typically breaks down in two places: the consent dialogue and overlaid image galleries (project experience). Both are usually bought-in components that can be replaced or embedded differently without rebuilding the site. That is the good news about this task: the effort concentrates on a few parts.

Alternative text for project images

In landscaping the website lives on images. That is precisely where the largest barrier arises, because a photograph without a stored description is silent to a screen reader. Someone who cannot see hears a file name at best and nothing at worst — and leaves a portfolio gallery with the impression that there is nothing there. Alternative text is the drudgery of this topic: unspectacular, time-consuming on the first pass, then a matter of routine at upload.

A usable alternative text describes what can be seen in one short sentence. It does not repeat the caption, it does not stack search terms, and it does not begin with the words image or photo. For before-and-after pairs, stating the condition is decisive, otherwise the point of the comparison is lost. Purely decorative images — dividers, mood shots without content — deliberately stay without text so that the screen reader skips them.

Alternative text for a portfolio gallery
Image 1  Before shot of the old yard surface
  weak       IMG_20250614
  weak       Image1
  workable   Old concrete slab surface with moss growth before removal

Image 2  Finished terrace
  weak       Terrace garden paving landscaping natural stone
  workable   Terrace of grey sandstone slabs with lawn edge and kerb

Image 3  Interim state of the sub-base
  weak       Building site
  workable   Compacted gravel base layer with kerbstones set in place

Image 4  Decorative divider without content
  workable   Leave the field empty so the screen reader skips it

The side benefit is considerable. Descriptions make images interpretable for search engines, they appear as substitute text when a file fails to load, and they force a sorting of your own stock. Anyone who has done this pass once quickly notices which shots cannot be described at all — usually the ones that convince nobody either. How to build a usable stock from the outset is covered in our article on photos for your website.

Forms: where enquiries are actually lost

The enquiry form is where accessibility turns directly into revenue. Someone unable to complete a form rarely picks up the phone — they look for the next business. The typical defects are technically mundane: field labels that exist only as grey text inside the field and vanish while typing. Error messages expressed solely by a red outline. Required fields marked with an asterisk and no explanation.

Every one of these points can be fixed without rebuilding the site. Visible labels above the fields stay in place while text is entered. Error messages in plain words next to the field concerned help everyone, not only a screen reader. And a summary at the top of the form listing what is still missing saves time for a manager with thick fingers on a phone just as much as for a user with speech output. Which fields a landscaping form actually needs is covered in the article on the enquiry form.

Here accessibility is not an extra but craftsmanship

A form with visible labels, understandable error messages and large tap targets is easier for everyone to complete. The difference shows first among those who depend on assistive technology — it becomes measurable across everyone typing an enquiry one-handed on the sofa in the evening.

What you do not need: overlay widgets

Since the act took effect, providers have been promoting small icons at the edge of the screen hiding switches for larger type, stronger contrast or read-aloud functions. The appeal is obvious: one line of code, a monthly fee, topic closed. In practice such tools do not solve the actual problems. They sit on top of a page whose structure remains unchanged — missing image descriptions, inoperable menus and unlabelled form fields stay exactly as they are.

On top of that, these overlays can become a barrier themselves when they capture keyboard focus or clash with the settings of the operating system. Many people with visual impairment have long used the assistive features of their own device and do not want a second interface layered over them. Anyone willing to spend money is better off spending it on fixing the findings an honest review turns up. That is unspectacular, but it lasts and does not need paying for every month.

A switch that enlarges text helps nobody if the image underneath has no description and the form cannot be submitted without a mouse.

Guiding thought when assessing overlay tools

An approach for the winter months

Accessibility is a task for the quiet season. Between November and February landscaping businesses document projects, sort images and rework text anyway. That is where this review belongs — not in April, when the crews are fully booked and nobody has time to phrase an image description. A structured approach in four stages makes the task plannable.

Whether the work can be done by reworking what exists or whether a rebuild is the more sensible route depends on the age and condition of the site. Where a template provides no visible focus indicator and the colour values are too weak throughout, fixing individual items costs more than replacing them — more on that in the article on the website relaunch. Anyone wanting to hold the standard reached anchors the check in ongoing maintenance rather than reopening it every few years.

Start with the list of findings, not with the rebuild

Before money is spent, it should be clear how many places are actually affected. A structured review costs little time, produces a workable list and prevents a manageable topic from being inflated into a project.
This article is based on data from: the German accessibility act (Barrierefreiheitsstärkungsgesetz, BFSG), the European standard EN 301 549, the Web Content Accessibility Guidelines 2.2, the European Commission, the Federal Statistical Office and our own project experience from website projects in landscaping.

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