Why You MUST Act NOW
• Law firm CLAIM RA has been sending systematic cease-and-desist letters since 08/2025 (~€595 each)
• Missing alt text is the #1 enforcement target — detectable by automated scans in seconds
• Market surveillance authorities actively auditing since 01/2026 — fines up to €100,000
• EU Commission reprimanded Germany in 03/2026 — enforcement escalation expected
The good news: You don't have to do everything at once
A full WCAG audit and rebuild takes weeks and costs thousands. But: authorities don’t expect a perfect score on day 1. They expect „good faith progress” — serious, documented improvements. And certain quick wins eliminate 80% of enforcement risk.
This guide focuses on the 5 measures with the highest impact-per-hour ratio. All are doable in 24 hours.
Which countries does this guide apply to?
The 24h plan works for all DACH countries and EU shops. The technical measures (WCAG 2.1 AA) are identical everywhere — only laws, fines, and authorities differ:
| Country | Law | Max. Fine | Authority | Status |
|---|---|---|---|---|
| 🇩🇪 Deutschland | BFSG | €100.000 | MLBF (State authorities) | Mandatory since 06/2025, audits since 01/2026 |
| 🇦🇹 Österreich | BaFG + BGStG | €80.000 | Sozialministeriumservice | Mandatory since 06/2025 + BGStG mediation |
| 🇨🇭 Schweiz | BehiG (Revision) | Noch offen | EBGB | Private from 01/2027 — for EU business now! |
| 🇫🇷 Frankreich | EAA-Umsetzung | €250.000 | ARCOM | First lawsuits 11/2025 (Auchan, Carrefour) |
| 🇪🇸 Spanien | EAA-Umsetzung | €1.000.000 | Countryesbehörden | Mandatory since 06/2025 |
| 🇳🇱 Niederlande | EAA-Umsetzung | €900.000 / 10% Umsatz | ACM | Mandatory since 06/2025 |
| 🇺🇸 USA | ADA | Ø $25.000+ (Klage) | Private lawsuits | 4.500+ Klagen in 2024 |
⚠️ For Swiss shops: If you sell to customers in the EU (z.B. nach Deutschland liefern), gelten die EAA-Anforderungen des jeweiligen EU-Countryes für Sie – auch mit Sitz in der Schweiz. Ein Schweizer Shop mit deutschen Kunden kann nach dem BFSG abgemahnt werden.
💡 Micro-enterprise exemption (DACH): Businesses with under 10 employees AND under €2M revenue are exempt from BFSG/BaFG for services. BUT: In Germany, unfair competition claims are still possible. In Austria, the BGStG applies (no size exemption!). The exemption is not a safe harbor.
Detailed country guides: Deutschland · Österreich · Schweiz · Alle EU-Länder
1. Assessment: How bad is it?
Before changing anything: run a quick scan to know where you stand. Takes 30-60 minutes and gives you a clear priority list.
3 free scan tools (use in parallel)
F12 → Lighthouse → Accessibility → “Analyze Page”. This provides a score from 0 to 100 and lists all issues by severity. Check your 5 most important pages: Homepage, a product page, shopping cart, checkout, and contact page.
Enter a URL → get a visual report with errors marked directly on the page. Particularly effective for missing alt text and contrast issues. Instantly highlights red flags.
Enter a URL → reveals missing alt texts, SEO potential, and compliance risks. Specifically focused on alt texts, showing exactly how many images are affected.
What you'll typically find
For most online shops that haven’t acted yet:
🔴 60-90% of images have no alt text (most common error, most common enforcement target)
🟡 30-50% of text have insufficient color contrast (< 4,5:1)
🟡 Form fields without labels (screen reader doesn’t know what to enter)
🟡 Keyboard traps in modals, sliders, or dropdowns (Tab doesn’t advance)
🟠 No accessibility statement on the website
💡 Die Reihenfolge in diesem Guide ist bewusst nach Impact-pro-Stunde sortiert: Alt-Texte zuerst (größter Hebel, schnellste Lösung per KI), dann Kontraste, dann Tastatur, dann Formulare, dann Erklärung. In dieser Reihenfolge eliminieren Sie das meiste Risiko pro investierter Stunde.
2. Quick Win #1: Generate alt text via AI
🏆 Biggest lever — eliminates the #1 enforcement target
Missing alt text is by far the most common WCAG violation and the easiest grounds for a legal warning—because it can be detected automatically in seconds. At the same time, it is the issue that can be resolved most quickly: using AI, in minutes rather than weeks.
AutoAlt.ai for WordPress/WooCommerce or Shopware. Create Account → 50 Free Credits/Month → API Key Set Automatically.
Set language(s), enable keyword integration, and select “Generate only missing” (this does not overwrite existing Alt texts). For WooCommerce: Enable product name integration. Multilingual shops (DE/EN/FR/IT): AutoAlt.ai generates Alt texts in all languages using 1 credit per image—compatible with WPML and Polylang.
Launch the Bulk Alt-Text Generator for your entire media library. The plugin processes in the background: 500 images ≈ 15–30 min, 1,000 images ≈ 30–60 min, 5,000 images ≈ 4–8 hours (run overnight).
Spot-check 20–30 generated alt texts. Are product names correct? Do the colors match? Are the descriptions appropriate? Edits do not cost any credits.
| Shop size | Images | AutoAlt.ai Duration | Cost |
|---|---|---|---|
| Small (< 50 products) | ~200 | ~10 Min. | €0 (50 free credits suffice) |
| Medium (50-200 products) | ~800 | ~25 Min. | €45 (Profi-Pack) |
| Large (200-500 products) | ~2.000 | ~60 Min. | €90 (2× Profi-Pack) |
| Enterprise (500+ products) | ~5.000+ | Overnight | €105/Month (Agency-Plan) |
✅ Result after Phase 1: All images have WCAG-compliant alt text. The most common ground for legal warnings has been eliminated. The processing history serves as proof of compliance. Estimated risk reduction: 40–50%.
3. Quick Win #2: Fix color contrast
Second most common WCAG error — often fixable in 2 hours
Insufficient color contrast is the second most common accessibility error. WCAG 2.1 AA requires a minimum contrast ratio of 4.5:1 for normal text and 3:1 for large text (18pt or larger, or 14pt bold).
Use the WebAIM Contrast Checker (webaim.org/resources/contrastchecker) or the browser extension “WCAG Color Contrast Checker”. Check: body text, headings, buttons, links, form labels, footer text, placeholder text.
Common problems: Light gray text on a white background, buttons with insufficient contrast, placeholder text in forms. Solution: Darken the text color or adjust the background. In most cases, an adjustment in the CSS file or theme customizer is sufficient.
Tab through your page – do you always see a visible frame around the active element? Many themes remove the default focus ring outline: none. This is a WCAG violation. Solution::focus { outline: 2px solid #0f172a; outline-offset: 2px; }
✅ Result after Phase 2: Text and controls are readable for visually impaired users. Focus indicators are visible. Estimated total risk reduction: 60-70%.
4. Quick Win #3: Check & fix keyboard navigation
Critical for screen reader users and motor-impaired users
Put the mouse aside and navigate your shop using only the keyboard. Can you reach every link, every button, every menu item? Can you complete the entire checkout process?
Tab = next item | Shift+Tab = previous | Enter = activate | Escape = close. Navigate through: Navigation → Product page → Shopping cart → Checkout. Note down every point where you get stuck.
• Hamburger menu: Must be accessible via Tab and openable with Enter.
• Modal/Popup: Focus must jump into the modal when opening and return when closing.
Slider/Carousel: Arrow keys for navigation, Tab for slides.
• Drop-down menus: Arrow keys for sub-items, Escape to close.
• Cookie banner: Must be the first element accessible via tab.
✅ Result after Phase 3: The entire purchasing process can be completed via keyboard. No more keyboard traps. Estimated total risk reduction: 75-80%.
5. Quick Win #4: Make forms accessible
Checkout is explicitly named in the BFSG
The checkout area is explicitly mentioned in the German Federal Training Assistance Act (BFSG) as an area that must be accessible. The most common problems are:
Not just a placeholder, but a real <label for="email">one linked to the input. A placeholder alone disappears when typing – screen reader users then no longer know which field it is.
Instead of just “Please fill in all required fields,” say “Please enter a valid email address.” Error messages should be announced with role="alert"and for screen readers.aria-live="polite"
Not just with a red star (*) – additionally requiredand aria-required="true". This is the only way screen readers know that the field needs to be filled in.
✅ Result after Phase 4: Checkout is fully usable for screen reader users. Error messages are clear. Estimated total risk reduction: 85-90%.
6. Quick Win #5: Publish accessibility statement
Fulfill documentation requirement — demonstrates “good faith”
The Federal Data Protection Act (BFSG) requires an accessibility statement on the website. It is mandatory – and at the same time, your proof that you are taking the issue seriously. Even if your website is not yet 100% compliant: An honest statement outlining known limitations and a plan of action demonstrates “good faith progress” to the authorities.
✓ Scope: Which website/URL does this declaration apply to?
✓ Compliance status: “Partially compliant with WCAG 2.1 Level AA”
✓ Assessment basis: Self-assessment according to WCAG 2.1 / EN 301 549
✓ Known limitations: Honestly list what is not yet compliant (e.g., videos without subtitles)
✓ Measures taken: “Alt text generated for all images on [date]” – the AutoAlt.ai documentation pays off here.
✓ Planned improvements: “Keyboard navigation will be optimized by [date]”
✓ Contact for feedback: Email address or accessibility feedback form
✓ Date of last update
Where to place it? In the footer of your shop, next to the legal notice and privacy policy. Ideally, linked as a separate page titled “Accessibility” or “Accessibility Statement”.
✅ Result after Phase 5: Documentation requirement fulfilled. “Good faith progress” demonstrable. Estimated total risk reduction: 90-95%.
7. After the 24 Hours: What's Next?
In 24 hours, you’ve closed the most critical gaps. But accessibility isn’t a one-off project – it’s an ongoing process. Here are your next steps for the weeks that follow:
Weeks 2-3: Add subtitles to videos (WCAG 1.2.2). Mark up complex tables with column headings. Make PDF documents accessible.
Week 4: Commission a professional WCAG audit or perform a full scan yourself using axe DevTools. Prioritize all identified issues and translate them into an action plan.
Months 2-3: Review semantic HTML (heading hierarchy, countrymark regions). Implement Aria labels for dynamic content. Add skip links.
Ongoing: Consider accessibility directly with every new product/page. Set AutoAlt.ai to “Auto-Generate on Upload” – every new image will automatically receive alt text.
→ Alt Text Requirement 2026: Complete guide to the legal situation
8. What Does Emergency Compliance Cost?
| Measure | DIY | Agency |
|---|---|---|
| Alt-Text (1,000 Images) | €45 (AutoAlt.ai Profi-Pack) | €4.000-8.000 (manual) |
| Fix contrast | €0 (CSS changes) | €500-1.500 |
| Keyboard fixes | €0-200 (depending on complexity) | €1.000-3.000 |
| Form fixes | €0-100 (Labels + ARIA) | €500-2.000 |
| Accessibility statement | €0 (self-written) | €200-500 (lawyer) |
| TOTAL (24h emergency plan) | €45-345 | €6.200-15.000 |
For comparison: A single cease-and-desist order costs approximately €595 plus legal fees for your defense (approximately €500-1,500). A fine under the German Road Traffic Act (BFSG) can reach up to €100,000. Emergency compliance insurance for €45-345 is the cheapest insurance available.
Start Phase 1 now — implement the biggest lever immediately
AutoAlt.ai generates BFSG-compliant alt text using AI. Plugin for WordPress, WooCommerce, Shopware, Joomla and Drupal. 50 credits/month forever free.
9. Frequently Asked Questions (FAQ)
Can I really become EAA-compliant in 24 hours?
Honestly, achieving 100% WCAG compliance in 24 hours is unrealistic for complex online stores. However, you can close the five most critical gaps within 24 hours, eliminating 90-95% of the risk of legal action: alt text, contrast, keyboard layout, forms, and explanations. This is sufficient for “good faith progress”—which is the minimum expected by authorities and courts.
What is "good faith progress" and why is it enough?
Market surveillance authorities not only examine the current situation but also the progress made. A company that has demonstrably taken measures (generated alt text, published a statement, created an action plan) will be treated differently than one that has done nothing. The accessibility statement with planned improvements serves as your proof of good faith.
Does an overlay widget like accessiBe suffice?
No. Overlay widgets are actively opposed by the accessibility community and disability organizations. The FTC fined accessiBe $1 million. Alt text from overlays is not included in the HTML source code and has no SEO value. For true compliance, you need true technical accessibility—real HTML alt attributes, real label elements, and real contrast.
What if I've already received a cease-and-desist?
Consult a specialized IT/competition law attorney immediately – do not sign any cease-and-desist declaration without legal review. In parallel: Implement this 24-hour plan to rectify the identified deficiencies as quickly as possible. Documented rectification (e.g., via AutoAlt.ai processing history) strengthens your position in negotiations.
Why is alt text the most important first step?
Three reasons: (1) Most frequent reason for cease-and-desist letters – missing alt text can be automatically detected in seconds, (2) fastest solution – fixable in minutes instead of weeks via AI, (3) additional SEO bonus – 22% more traffic through image search. No other WCAG violation offers this ratio of risk to speed of resolution.
How much does full accessibility cost for my shop?
The 24-hour emergency plan costs €45-345 for the most critical fixes. Full WCAG compliance (professional audit + implementation + testing) typically costs between €2,000 and €15,000, depending on the complexity of the shop. However, this 24-hour plan eliminates over 90% of the risk for under €345. You can systematically address the remaining 10% in the following weeks and months.
Do I need a professional WCAG audit?
Not immediately. For emergency compliance, a self-assessment using the aforementioned tools (Lighthouse, WAVE, AutoAlt.ai Scanner) is sufficient. However, a professional audit (starting at €500 for small shops) is recommended as the next step in week 4 to uncover hidden issues that automated tools might miss.
Does this guide apply to Austrian online shops?
Yes. The technical measures (alt text, contrast, keyboard, forms, explanation) are identical in all countries – the standard is WCAG 2.1 Level AA everywhere. The difference: In Austria, the BaFG (Federal Law on the Protection of Minors in the Public Sector) applies, with fines of up to €80,000 (tiered according to company size), and additionally the BGStG (Federal Law on the Protection of Minors in the Public Sector), which also covers micro-enterprises via conciliation procedures. Details: Alt text requirement Austria .
I'm a Swiss company — do I need to act now?
If you sell to customers in the EU: yes, immediately – the EAA applies to you in the respective EU country (e.g., BFSG in Germany). Swiss market only: The revision of the Disability Equality Act (BehiG) is expected on January 1, 2027. Nevertheless, it’s worth acting now – alt text improves your SEO and costs almost nothing with AutoAlt.ai. Details: Alt text requirement in Switzerland .
Does the micro-enterprise exemption apply to my shop?
Fewer than 10 employees AND less than €2 million in revenue? Then you are exempt from the German Federal Social Security Act (BFSG) and the Austrian Federal Employment Agency’s (BAFG) regulations for services. BUT: In Germany, you can still be issued a cease-and-desist letter under the Unfair Competition Act (UWG) (the exemption only protects against the BFSG itself). In Austria, the Austrian Federal Tax Act (BGStG) also applies, which does not recognize any size exemption. Recommendation: Implement this 24-hour plan anyway – alternative texts cost €45 and eliminate the biggest risk.
Is there a transition period for existing shops?
For existing service contracts concluded before June 28, 2025, a transition period applies until June 27, 2030 at the latest. Important: This only applies to the contracts, not the website itself. Your website must be compliant from June 28, 2025 onwards – regardless of the age of your customer relationships. New customers, new products = no transition period.
Start Phase 1: Generate alt text in minutes
AutoAlt.ai is the fastest way to the greatest impact. BFSG-compliant alt text generated by AI, directly in your CMS. 50 credits/month forever free.
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