Sellers who sell via Shopify, Amazon, eBay or Etsy almost always ask the same question: \u201cWhere do I put the accessibility statement?\u201d It\u2019s 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\u2019re actually describing there. In your own Shopify shop, you\u2019re describing your own service. On a marketplace, however, you\u2019re describing a service whose platform doesn\u2019t even belong to you. This is precisely where the mistake I see most often in marketplace statements occurs. <\/p>\n\n
In this guide, I\u2019ll show you what the BFSG actually requires of sellers on platforms and e-commerce systems. You\u2019ll 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\u2019ve already outlined the general mandatory content in \u2018Accessibility Statement: Mandatory Content, Structure and Common Mistakes\u2019<\/a>. This guide focuses on the specific requirements for platform-based retail, as of October 2026. <\/p>\n\n This obligation is set out in \u00a7 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. <\/p>\n\n Appendix 3 sets out the content. You must provide this information in your terms and conditions or \u2018in any other clearly visible manner\u2019. In addition to the consumer information required under Section 246 of the EGBGB, the following details must be included, where applicable: <\/p>\n\n 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. <\/p>\n\n Practical tip<\/strong>: Part of your explanation usually already exists. The consumer information required under Section 246 of the EGBGB \u2013 that is, who you are, how to contact you and how the contract is concluded \u2013 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). <\/p>\n\n This is where it gets interesting, as this issue has not yet been conclusively settled in law. The H\u00e4ndlerbund 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. <\/p>\n\n 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 \u2013 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. <\/p>\n\n 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\u2019s specifications for their products. <\/p>\n\n 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. <\/p>\n\n 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. <\/p>\n\n 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 \u2018Formal warning due to lack of accessibility<\/a>\u2019. A robust marketplace declaration therefore draws a clear distinction between two levels: <\/p>\n\n eBay itself sets a good example. The explanation for eBay\u2019s 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\u2019t do so for its interface. <\/p>\n\n 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 \u2018Accessible Online Shop: What the BFSG Means for E-commerce\u2019<\/a>. <\/p>\n\n Many Shopify merchants rely on the platform being accessible. It is therefore worth taking a look at Shopify\u2019s 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 \u2018not supported\u2019, but 13 criteria are marked as \u2018partially supported\u2019. 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. <\/p>\n\n 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\u2019s 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\u2019s actual accessibility. I explain why automated scores alone are insufficient in any case in \u2018The Limitations of Automated Accessibility Testing<\/a>\u2019. <\/p>\n\n 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<\/a>. <\/p>\n\n Practical tip<\/strong>: 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. <\/p>\n\n On marketplaces, the answer depends on what the platform offers. The three major platforms take very different approaches in this regard. <\/p>\n\n 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. <\/p>\n\n 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. <\/p>\n\n I\u2019m not aware of a dedicated field for a disclaimer on Etsy either. Commercial sellers include their legal information in the shop policies, and that\u2019s where the disclaimer should go. However, Etsy does offer something that\u2019s 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. <\/p>\n\n 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: <\/p>\n\n 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. <\/p>\n\n Practical tip<\/strong>: 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 \u2018Image\u2019? Anything you can\u2019t hear will also be missing for your customers who use screen readers. <\/p>\n\n Appendix 3 and the separation of responsibilities provide a clear framework. I recommend that retailers adopt these seven building blocks: <\/p>\n\n 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 \u2018Digital Accessibility Deadlines for 2026 and 2027\u2019<\/a>. <\/p>\n\n Ultimately, it is your choice of words that determines whether your statement protects you. Three examples illustrate the difference. <\/p>\n\n Vulnerable<\/strong>: \u201cOur shop is fully accessible.\u201d On a marketplace, you cannot know this for certain, and in your own shop, it is rarely verified. Viable<\/strong>: \u201ceBay provides the search, ordering and payment functions. We have implemented the following measures for our listing content.\u201d <\/p>\n\n Vulnerable<\/strong>: \u201cSome content may not be accessible.\u201d This statement says nothing and merely shows that you are unaware of your own situation. Viable<\/strong>: \u201cSize 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.\u201d <\/p>\n\n Vulnerable<\/strong>: \u201cWe use an accessibility tool that makes our shop accessible to everyone.\u201d A widget does not constitute implementation in the code. Valid<\/strong>: \u201cOur shop was tested against EN 301 549 in September 2026. The results and outstanding issues are listed below.\u201d However, you may only make this statement if the test has actually taken place. <\/p>\n\n Many retailers don\u2019t 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 \u2018largely compliant\u2019, eBay features a copied boilerplate text, and Amazon has nothing at all. However, whoever is carrying out the checks won\u2019t just look at one channel. <\/p>\n\n 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. <\/p>\n\n 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. <\/p>\n\n 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. <\/p>\n\n 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 \u2013 such as e-book readers or computers \u2013 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 \u2018Accessibility as a website requirement: Who is affected?\u2019<\/a>. <\/p>\n\n 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. <\/p>\n\nWhat the BFSG requires of retailers<\/h2>\n\n
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Does this obligation also apply to sellers on Amazon, eBay and Etsy?<\/h2>\n\n
The mistake: You\u2019re explaining someone else\u2019s interface on the marketplace<\/h2>\n\n
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Shopify: Here, you\u2019re in complete control<\/h2>\n\n
eBay, Amazon and Etsy: Where the explanation belongs<\/h2>\n\n
eBay: a dedicated section in your account<\/h3>\n\n
Amazon: no dedicated explanation field<\/h3>\n\n
Etsy: Alternative text \u2013 yes, description box \u2013 no<\/h3>\n\n
What you can do yourself on the marketplace<\/h2>\n\n
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How to structure a marketplace statement<\/h2>\n\n
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Wording that is effective, and wording that leaves one open to criticism<\/h2>\n\n
One company, four channels, one truth<\/h2>\n\n
Micro-enterprises: When the obligation does not apply<\/h2>\n\n
Comparison: Approaches to explaining accessibility<\/h2>\n\n