Sellers who sell via Shopify, Amazon, eBay or Etsy almost always ask the same question: “Where do I put the accessibility statement?” It’s a valid question, but it comes a step too late. Before you even consider which field to use in your seller account, you need to be clear about what you’re actually describing there. In your own Shopify shop, you’re describing your own service. On a marketplace, however, you’re describing a service whose platform doesn’t even belong to you. This is precisely where the mistake I see most often in marketplace statements occurs.
In this guide, I’ll show you what the BFSG actually requires of sellers on platforms and e-commerce systems. You’ll also find out where the accessibility statement should be placed on Shopify, eBay, Amazon and Etsy, and how to word it so that it stands up to scrutiny. I’ve already outlined the general mandatory content in ‘Accessibility Statement: Mandatory Content, Structure and Common Mistakes’. This guide focuses on the specific requirements for platform-based retail, as of October 2026.
What the BFSG requires of retailers
This obligation is set out in § 14 of the BFSG. According to this, a service provider may only offer their service if two conditions are met. The service must comply with accessibility requirements, and the provider must have prepared the information in accordance with Annex 3 and made it accessible to the public in an accessible manner. An online shop through which consumers enter into contracts is such a service, namely a service in electronic commerce. You must also keep this information available for as long as you offer the service.
Appendix 3 sets out the content. You must provide this information in your terms and conditions or ‘in any other clearly visible manner’. In addition to the consumer information required under Section 246 of the EGBGB, the following details must be included, where applicable:
- a) a general description of the service in an accessible format,
- b) descriptions and explanations necessary for understanding how the service is to be provided,
- c) a description of how the service meets the accessibility requirements,
- d) the name of the competent market surveillance authority.
The Market Surveillance Authority of the Federal States for the Accessibility of Products and Services (MLBF) in Magdeburg is responsible for the whole of Germany. It has been operating nationwide since September 2025. If this information is missing, the statement is formally incomplete, regardless of how well the rest is written.
Practical tip: Part of your explanation usually already exists. The consumer information required under Section 246 of the EGBGB – that is, who you are, how to contact you and how the contract is concluded – is already set out in your legal notice and your terms and conditions. Refer to these rather than rewriting everything from scratch. The real work lies in points (a) to (d), particularly point (c).
Does this obligation also apply to sellers on Amazon, eBay and Etsy?
This is where it gets interesting, as this issue has not yet been conclusively settled in law. The Händlerbund believes that the primary responsibility for ensuring an accessible user interface lies with the platform operators. However, retailers should ensure their own content is accessible, insofar as they have any influence over it. IT-Recht Kanzlei, on the other hand, considers a declaration by platform retailers to be voluntary, as they lack the knowledge and control over the platform. Trusted Shops, meanwhile, sees strong arguments in favour of an obligation extending to platforms as well. Neither the law nor the European Directive limits responsibility to technical control over the infrastructure.
However, there is another question that matters for your business. Whether the law requires you to do so on the marketplace is a matter of debate. Whether the platform requires it is not – at least not on eBay. eBay expressly requires commercial sellers with customers in the EU to draw up an accessibility statement and add it to their account. This means that the statement is no longer a matter of legal interpretation, but part of the rules under which you sell.
There is also a second point that many people overlook. Section 19 of the BFSGV requires that, for services provided in electronic commerce, information on the accessibility of the products sold must be made available, provided that the relevant economic operator supplies it. The platform must therefore provide space for this information. However, it is the retailers who must fill in this information, as only they are aware of the manufacturer’s specifications for their products.
My recommendation is therefore as follows: anyone who sells on marketplaces on a commercial basis and does not fall under the exemption for micro-enterprises should provide a statement. It requires little effort, resolves an unresolved legal issue in your favour and shows customers that you take the matter seriously. However, this guide is no substitute for legal advice specific to your individual circumstances.
The mistake: You’re explaining someone else’s interface on the marketplace
This is where most marketplace disclaimers fall short. Many sellers copy and paste a template from the internet that was written for their own website. This text might state, for example, that the website largely meets the requirements of WCAG 2.1 Level AA. However, on Amazon, eBay or Etsy, you do not actually run a website at all. The platform provides the search function, filters, shopping basket, checkout, payment and customer account. You cannot change the contrast settings there, nor can you improve the keyboard navigation for the payment process.
Such a statement therefore makes a claim about something that you have neither verified nor can influence. This makes it vulnerable to challenge, rather than protecting you. I describe just how quickly an inaccurate statement can lead to a complaint or a formal warning in the article ‘Formal warning due to lack of accessibility’. A robust marketplace declaration therefore draws a clear distinction between two levels:
- What the platform is responsible for: navigation, search, filters, the shopping basket, checkout, payment and login functions, as well as the presentation of your shop. Here, you should refer to the platform operator’s statement, if one is available.
- Your responsibilities: product titles, descriptions, images, variants, product documents, invoices, your communication with customers and your contact channels. For this section, describe exactly what you have carried out.
eBay itself sets a good example. The explanation for eBay’s German services cites the EN 301 549 V3.2.1 standard as the benchmark. At the same time, it openly admits that, in some areas, the standard cannot always be implemented consistently. If even the platform operator does not claim full compliance, you certainly shouldn’t do so for its interface.
Shopify: Here, you’re in complete control
With your own Shopify shop, the situation is fundamentally different. Shopify provides the software, but you are the shop operator. You choose the theme, install apps, design pages and integrate payment methods. Shopify itself states that retailers have full control over their theme code. This means you are responsible for the entire process, from the homepage right through to the order confirmation. I outline which stages of the shop are particularly critical in ‘Accessible Online Shop: What the BFSG Means for E-commerce’.
Many Shopify merchants rely on the platform being accessible. It is therefore worth taking a look at Shopify’s own compliance report for the checkout. The report, dated March 2026, assesses the checkout against WCAG 2.2 at Levels A and AA. No criteria are marked as ‘not supported’, but 13 criteria are marked as ‘partially supported’. These include 1.4.3 Contrast (Minimum), 2.4.7 Focus Visibility, 3.3.1 Error Detection, 4.1.2 Name, Role, Value and 4.1.3 Status Messages. Shopify therefore openly documents where it is still making improvements. It is precisely this honesty that should also feature in your statement.
The same applies to the theme. In 2021, Shopify introduced a minimum average Lighthouse accessibility score of 90 for the Theme Store, measured across the homepage, product page, collection page and basket, and supplemented by manual testing. This is a good starting point, but it does not serve as proof of your shop’s compliance. As soon as you customise colours, rearrange sections or integrate apps for reviews, filters or pop-ups, the baseline score no longer reflects your shop’s actual accessibility. I explain why automated scores alone are insufficient in any case in ‘The Limitations of Automated Accessibility Testing’.
Caution is also advised with accessibility apps from the App Store that overlay a toolbar on the shop at the click of a button. They alter the display but do not fix errors in the theme code. An explanation based on such a widget therefore does not describe a genuine implementation. The background to this is set out in Overlays and one-click solutions: Why they do not resolve the BFSG risk.
Practical tip: Create the statement as a separate page in Shopify (in the admin panel under Online Shop, Pages, Add Page) and link to it in the footer menu. A dedicated link in the footer is much easier for customers to find than a paragraph buried deep within the terms and conditions. Then check that the page itself is accessible: proper headings, no text-based images, and a contact method that works without a mouse.
eBay, Amazon and Etsy: Where the explanation belongs
On marketplaces, the answer depends on what the platform offers. The three major platforms take very different approaches in this regard.
eBay: a dedicated section in your account
eBay has gone the furthest in this regard. You can upload your accessibility statement under Account Settings, Public Company Information, Accessibility Statement. Information on the accessibility of individual products can be uploaded as a product document in the product details, or included directly in the item description. eBay also highlights a detail that many people underestimate: a PDF will only be accessible if the source document was already accessible before conversion.
Amazon: no dedicated explanation field
To the best of my knowledge, Amazon has not introduced a dedicated field for an accessibility statement. According to Trusted Shops, Amazon directs sellers to the product description on the detail page for accessibility information. Amazon leaves open the question of whether it is advisable to include an additional statement in the seller profile. As Annex 3 expressly permits the Terms and Conditions as a location, I recommend placing the statement where your Terms and Conditions and mandatory information are located in the seller profile. You can see which text fields your profile currently offers in Seller Central.
Etsy: Alternative text – yes, description box – no
I’m not aware of a dedicated field for a disclaimer on Etsy either. Commercial sellers include their legal information in the shop policies, and that’s where the disclaimer should go. However, Etsy does offer something that’s missing elsewhere: a dedicated field for alternative text for each product photo. Etsy recommends up to 250 characters. If you do not provide your own text, Etsy may use an AI-generated description. However, Etsy does not alter any text you have written yourself.
What you can do yourself on the marketplace
Even though the platform builds the checkout process, you have a significant say in what your customers actually see. You should implement these points before describing them in your explanation:
- Alternative text for product images in accordance with WCAG Criterion 1.1.1 ‘Non-text content’, wherever the platform provides a field for this. I explain what good alternative text looks like in ‘How to write alternative text correctly’.
- Do not include important information solely in images: size charts, care instructions or details of what is included in the delivery presented as graphics are invisible to screen readers. Criterion 1.4.5 ‘Images of text’ requires text to be provided as actual text.
- Structured descriptions with bulleted lists and, where the platform allows, subheadings, so that the structure set out in 1.3.1 ‘Information and Relationships’ is maintained.
- Variations are not limited to colour: ‘Red’ and ‘Dark blue’ must appear as text, not just as coloured areas. This ensures compliance with 1.4.1 Use of colour.
- Accessible documents: user guides, data sheets and invoices as tagged PDFs. You can find out how to do this in ‘Creating accessible PDFs’.
- More than one way to get in touch: In addition to the platform’s messaging system, provide an email address so that customers can report barriers and request information in a different format.
Most of these points take time, but hardly any money. Some of them also pay off twice over. Etsy itself points out that search engines can read alternative text. Digital accessibility and visibility therefore go hand in hand here.
Practical tip: Try this out for yourself with your own product listing. Turn on VoiceOver (iPhone) or TalkBack (Android) on your smartphone and have the product page read aloud to you. Can you hear the price, size, variant and contents of the package? Or does the text for the images simply say ‘Image’? Anything you can’t hear will also be missing for your customers who use screen readers.
How to structure a marketplace statement
Appendix 3 and the separation of responsibilities provide a clear framework. I recommend that retailers adopt these seven building blocks:
- Scope: To which shop on which platform does this declaration apply, and who is the supplier? Please refer here to the legal notice and terms and conditions, which contain the information required under Section 246 of the EGBGB.
- Description of the service: What you sell and how a purchase is made, from searching for a product through to ordering, payment, delivery and returns (Annex 3, points (a) and (b)).
- Allocation of responsibility: Which functions the platform provides, with a reference to its own statement.
- Your actions: What you have implemented within your sphere of influence, such as alternative text, structured descriptions and accessible documents (point (c)).
- Known limitations: What is not yet accessible and by when you intend to rectify this.
- Contact: How customers can report barriers and request information in a different format.
- Market Surveillance Authority and date: Name and address of the MLBF in Magdeburg (point (d)) and the date of the last update.
The same structure applies to a Shopify shop, although the third section is largely omitted. Instead, you should describe which theme and which apps you are using, which standard you have used to carry out your assessment, and what the result was. The benchmark is currently the harmonised standard EN 301 549 V3.2.1, which refers to WCAG 2.1 Level AA. The new version, V4.1.1, based on WCAG 2.2, has been published since September 2026. It is expected to be published in the Official Journal of the EU in mid-December 2026. You can find out what this means for your timetable in ‘Digital Accessibility Deadlines for 2026 and 2027’.
Wording that is effective, and wording that leaves one open to criticism
Ultimately, it is your choice of words that determines whether your statement protects you. Three examples illustrate the difference.
Vulnerable: “Our shop is fully accessible.” On a marketplace, you cannot know this for certain, and in your own shop, it is rarely verified. Viable: “eBay provides the search, ordering and payment functions. We have implemented the following measures for our listing content.”
Vulnerable: “Some content may not be accessible.” This statement says nothing and merely shows that you are unaware of your own situation. Viable: “Size charts for older products are still available as images. We will make them available as text by the end of the quarter and will send them immediately by email on request.”
Vulnerable: “We use an accessibility tool that makes our shop accessible to everyone.” A widget does not constitute implementation in the code. Valid: “Our shop was tested against EN 301 549 in September 2026. The results and outstanding issues are listed below.” However, you may only make this statement if the test has actually taken place.
One company, four channels, one truth
Many retailers don’t just sell through a single channel. They have their own Shopify shop, plus Amazon and eBay, and perhaps even Etsy for a particular product range. This can quickly lead to four sets of information that contradict one another. The website states ‘largely compliant’, eBay features a copied boilerplate text, and Amazon has nothing at all. However, whoever is carrying out the checks won’t just look at one channel.
I therefore recommend creating a master version that you maintain on your own website. This describes the company, the contact details, the documents and the procedures that apply across all channels. For each platform, add a short section outlining the division of responsibilities. You can then copy the appropriate summary into the relevant fields on the marketplaces. If anything changes, update the master version first and then the channels. This ensures that the date is consistent across the board, and that no version contradicts another.
I therefore recommend creating a master version that you maintain on your own website. This describes the company, the contact details, the documents and the procedures that apply across all channels. For each platform, add a short section outlining the division of responsibilities. You can then copy the appropriate summary into the relevant fields on the marketplaces. If anything changes, update the master version first and then the channels. This ensures that the date is consistent across the board, and that no version contradicts another.
Micro-enterprises: When the obligation does not apply
There is good news for many Etsy shops and small marketplace sellers. Under Section 3(3) of the BFSG, the requirements relating to services do not apply to micro-enterprises. These are businesses with fewer than ten employees and an annual turnover or balance sheet total of no more than two million euros. Anyone falling into this category does not need to submit a declaration in accordance with Annex 3 for their shop.
There are, however, two restrictions you should be aware of. Firstly, the exemption applies only to services, not to products. If you sell products that fall under the BFSG themselves – such as e-book readers or computers – the obligations for retailers apply regardless of your size. Secondly, a successful online shop grows beyond the scope of the exemption. It is therefore worth considering alternative text and clear descriptions right from the start. You can check whether your business is affected overall by following the step-by-step guide in ‘Accessibility as a website requirement: Who is affected?’.
Comparison: Approaches to explaining accessibility
There are several ways to provide an explanation. They differ primarily in whether they actually cover paragraph (c) of Annex 3, i.e. whether they describe how your service meets the requirements.
| Path | Foundation | Does this cover point (c)? | Risk |
|---|---|---|---|
| Sample text from the internet | no separate examination | No, just general formulas | high when statements are incorrect |
| Adopt the platform’s statement | Audit of the platform operator | for the platform interface only | Your own content is missing |
| Clause in the terms and conditions | usually standard legal wording | rare; details of how it is implemented are often missing | medium |
| Statement based on an audit (ifdb) | Scanning and checking by humans | Yes, with specific findings | minimal, as long as it remains up to date |
How ifdb supports retailers in this regard
A declaration is only as honest as the audit behind it. For your own shop on Shopify or another platform, Access Declare generates the declaration based on a comprehensive scan of your shop and structures it in accordance with BFSG guidelines. If you need robust evidence, we’ll test your shop using Access Ready throughout the actual purchasing journey, using a keyboard and screen readers. Access Guard then monitors your shop on an ongoing basis. This ensures that a theme update or a new app doesn’t introduce new barriers without you realising.
For invoices, instructions and data sheets, there’s Access Doc, which formats PDFs to be accessible and has every result checked by a human. If you sell exclusively on marketplaces, please get in touch. We’ll then work with you to clarify what information needs to be included in your accessibility statement. If you’d like to find out where your own shop stands first, start with the free Access Score.
Not sure exactly what the BFSG means for your business? In 30 minutes, we’ll work with you to clarify which obligations apply and what you should tackle first.
Frequently Asked Questions
As an Amazon seller, do I need an accessibility statement?
Legally, this is a matter of debate, as Amazon provides the interface and the checkout process. Anyone selling on a commercial basis who is not a micro-enterprise should nevertheless provide a statement, for example in the terms and conditions on their seller profile. This should describe your own content and contact details, whilst referring to Amazon for the platform’s functions.
Is it sufficient to refer to the statement from Shopify or eBay?
No. A platform operator’s declaration only covers its own interface, not your product descriptions, images, documents or contact details. If you run your own Shopify shop, you are the operator yourself in any case. Shopify publishes compliance reports for its own products, but does not issue a declaration for your shop.
As a small Etsy shop, do I need to publish a statement?
Not if you’re a micro-enterprise – that is, one with fewer than ten employees and an annual turnover or balance sheet total of no more than two million euros. This exemption applies to the requirements for services. It’s still worth providing alternative text for your photos, as Etsy offers this field and your customers will benefit from it.
