On 17 July 2026 we ran our deterministic accessibility engine over the homepages of 390 German consumer-facing websites: online shops, banks and insurers, transport and travel operators, telecoms and car makers. Of the 293 sites that could be assessed, the median score was 38 of 100, and 149 sites, 51 percent, graded F. Only 18 sites, 6 percent, had zero detectable violations. The single most common failure is insufficient colour contrast, present on 87 percent of assessed sites.
| Key result | Value |
|---|---|
| Sites targeted | 390 |
| Sites assessed | 293 (97 blocked the scanner or failed to render) |
| Median score (0 to 100) | 38.1 |
| Share graded F (score below 40) | 50.9 % |
| Share graded A (score 90 or above) | 6.5 % |
| Sites with zero automated violations | 18 (6.1 %) |
| Most common failure | Colour contrast: 256 sites, 3,408 instances |
These are automated results, which makes the failure count a floor, not a ceiling: automated testing detects only a subset of the WCAG requirements that the German BFSG points to, so a site failing here fails before the harder, manual criteria are even considered.
What we scanned and how
The engine drives axe-core 4.12.1 through a real browser (Playwright 1.60.0) against each site's homepage, computes a 0 to 100 score weighted by violation impact and instance count, and maps it to grades (A from 90, B from 75, C from 60, D from 40, F below). The method is deterministic: no AI, no sampling, the same input produces the same output. The run manifest, including engine versions and the ruleset hash, is part of the published dataset.
Three honesty rules apply throughout. Sites that blocked the scanner (40) or failed to render (57) are reported as not assessed, never counted as clean. Bot walls are never bypassed. And we publish aggregates only: no individual site is named, because a homepage snapshot from one date should not follow a company around as a public verdict.
The five failures that dominate
Five rules account for most of the findings. None of them is exotic; all five have been in WCAG 2.1 AA since 2018 or earlier.
| Failure (axe rule) | Sites affected | Share of assessed | Instances | Impact | WCAG criterion |
|---|---|---|---|---|---|
Colour contrast (color-contrast) | 256 | 87.4 % | 3,408 | serious | 1.4.3 |
Links without a name (link-name) | 101 | 34.5 % | 620 | serious | 2.4.4 |
Images without alt text (image-alt) | 58 | 19.8 % | 283 | critical | 1.1.1 |
Buttons without a name (button-name) | 39 | 13.3 % | 172 | critical | 4.1.2 |
Nested interactive controls (nested-interactive) | 26 | 8.9 % | 98 | serious | 4.1.2 |
Colour contrast is a design-system problem: 3,408 instances across 256 sites means the failing grey-on-white text is usually baked into the theme, not into one page. Links and buttons without an accessible name are worse in practice than their counts suggest, because they leave screen reader users hearing "link" and "button" with no clue what either does. Images without alt text on a shop homepage typically means product images, so the products themselves are invisible to assistive technology.
Banking is the exception, and that is the interesting part
Grouped by sector, the spread is dramatic. We exclude one site whose sector group had no peers.
| Sector | Sites assessed | Median score | Share graded F |
|---|---|---|---|
| Banking and insurance | 46 | 76.3 | 10.9 % |
| Telecom * | 15 | 40.0 | 46.7 % |
| Transport and travel | 48 | 36.4 | 54.2 % |
| E-commerce | 175 | 30.8 | 60.0 % |
| Automotive * | 8 | 30.3 | 62.5 % |
The starred rows are small samples: read telecom and automotive as indicative only.
Banks and insurers score more than twice the e-commerce median, and their F share is under a fifth of the shops'. We did not expect a gap this wide. The plausible explanation is regulatory exposure: financial services have lived with accessibility-adjacent obligations, supervisory scrutiny and formal complaint channels for years, while most consumer e-commerce first met a hard legal accessibility requirement when the European Accessibility Act and its German transposition arrived. The sector that has been regulated longest is the sector that scores best. E-commerce, the sector the BFSG most visibly targets, scores worst.
What this means under the BFSG
The BFSG (Barrierefreiheitsstärkungsgesetz), Germany's transposition of the European Accessibility Act, has applied since 28 June 2025. E-commerce is explicitly in scope (§ 1 Abs. 3 Nr. 5 BFSG), and § 12 Nr. 3 BFSGV requires websites and apps to be perceivable, operable, understandable and robust, the same four principles the WCAG criteria above implement. Enforcement sits with the joint market surveillance authority of the Länder (MLBF) in Magdeburg. The procedure is graduated, investigation first, then a formal request to fix defects by a deadline, and only then fines: § 37 BFSG sets a maximum of 100,000 euro for a non-compliant product or service (source: gesetze-im-internet.de/bfsg, § 37). Micro-enterprises providing services are exempt (§ 3 Abs. 3 BFSG).
Against that backdrop, the numbers above describe a market where, one year into the obligation, the median covered homepage still fails automated checks that catch only the easiest defects. Colour contrast, link names and alt text are precisely the findings a market surveillance authority, or a competitor's lawyer, can verify with free tooling in minutes.
If your site is in the failing half, the fixes are unusually cheap for a compliance obligation: contrast is a stylesheet change, link and button names are markup, alt text is content work. Our six-step guide to becoming audit-ready sets out the order we recommend, and a free scan shows in minutes where a specific site stands on exactly the checks used in this benchmark.
What this data does not say
Automated results are an upper bound on conformance, not proof of it. axe-core evaluates the machine-checkable subset of WCAG 2.1 AA; keyboard traps, focus order, form error handling and cognitive load need human testing, so a site that passes every automated check can still fail a manual audit. We scanned homepages only, on one date, so a checkout flow may be better or worse than the front door. And a score of 100 here means "nothing automated found", not "accessible".
The reverse reading is the defensible one: a site that fails these checks demonstrably fails WCAG 2.1 AA, because every rule in the tables above maps to a specific criterion.
The dataset
The full aggregate dataset behind this article, population counts, score distribution, grade shares, sector statistics, rule frequencies and the run manifest with engine versions and ruleset hash, is published as open data: accessibility benchmark dataset, Germany, July 2026. Cite it freely with attribution to Inkluso. Per-site results are not published; the aggregates are the story.
We plan to repeat this benchmark for the Czech and Polish markets, where the EAA transpositions (zákon č. 424/2023 Sb. and the ustawa of 26 April 2024) raise the same questions, and to re-run the German scan to track whether enforcement moves the numbers.
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