Avoiding BFSG Warning Letters: A Checklist for Website Owners
Why accessibility is becoming a warning-letter topic
Germany's Accessibility Strengthening Act (BFSG) has applied since 28 June 2025. Unlike many internal obligations, accessibility violations are visible from the outside and in part even automatically checkable – a missing alt text or insufficient contrast can be spotted without insider knowledge. That is exactly what makes the topic attractive to warning-letter senders and competitors. Alongside market surveillance, which can impose fines of up to €100,000, the realistic day-to-day risk is the competition-law warning letter (Abmahnung).
This checklist walks through the ten points that stand out first in a surface-level review. It does not replace a full audit – but getting these under control removes the basis for the most common warning letters. Note: this is a technical assessment, not legal advice.
The checklist: 10 points that get checked first
- 1. Alt text for images: does every content-relevant image have a meaningful
altattribute? Purely decorative images should be hidden withalt="". - 2. Colour contrast: does text reach at least a 4.5:1 ratio (normal text) or 3:1 (large text)? Buttons, placeholder text and badges fail here especially often.
- 3. Keyboard operability: can the entire page – including menus, sliders and forms – be operated without a mouse?
- 4. Visible focus: is it always clear where the keyboard focus currently is? A focus ring removed via CSS is a classic violation.
- 5. Form labels: does every input field have a visible, programmatically linked
<label>? Placeholders alone are not enough. - 6. Unambiguous error messages: are form errors output as text and tied to the field concerned – not signalled by colour alone?
- 7. Heading structure: is there exactly one
<h1>and a logical hierarchy with no skipped levels? - 8. Language markup: does the
<html>element carry a correctlangattribute? Are foreign-language passages marked up? - 9. Video and motion content: do videos have captions? Can auto-playing animations or sliders be paused?
- 10. Accessibility statement: is there a publicly linked statement with a feedback mechanism? Its absence is particularly easy to prove.
Check yourself or get audited?
You can test some of these points yourself: navigate your site entirely by keyboard, check contrast with a free tool, and run an automated scan. Automated tools, however, find only around 30 to 40 percent of barriers – the semantic problems (mis-linked labels, illogical structure) are caught only by manual review. For WordPress sites, my plugin Kipphard Accessibility Audit handles the first diagnosis, checking right in the admin and generating the statement.
If the warning letter has already arrived
Stay calm and take the deadlines seriously. A warning letter usually contains a cease-and-desist declaration and a short deadline – this is where a specialist lawyer belongs (again, not legal advice from me). In parallel, start documented technical remediation: a demonstrable action plan improves your position and shows you are taking the matter seriously. Overlay tools are not a solution here – I explain why in Overlay tools vs. a real accessibility audit.
Conclusion
Most warning letters target the same, highly visible points. Working through this checklist and closing the gaps in code lowers your risk considerably. I handle the full path from audit to remediation as a BFSG service – just get in touch if you need a solid assessment of your website.