What is an Abmahnung, and why is it relevant now
An Abmahnung is an existing civil law instrument in Germany: a written warning from a competitor, a consumer organisation or a trade association, requesting that a violation be stopped and often claiming the costs incurred. It has existed for some time, among other things in cases of advertising and privacy violations. Since the European accessibility directive became enforceable in all member states, the absence of digital accessibility now falls under what such a letter can raise, because the underlying standard is now anchored in German law.
For businesses selling to German consumers, this is a different type of risk than oversight by a government agency. An Abmahnung does not come from a supervisory authority but from a private party, and the reason is often visible: a checkout process that does not work with a screen reader, missing alternative text, or a missing accessibility statement.
What concretely changes this year
Before 28 June 2025, digital accessibility in Germany was primarily a matter for the public sector and specific sectoral rules. With the direct effect of the directive, the technical standard now also applies to a broader group of private providers, such as webshops with a checkout process and services with an account environment. For the first time, this creates a clear legal basis on which an Abmahnung can rely: not a vague expectation, but a concrete standard that has been transposed into national law.
Whether and how often this instrument is actually used against whom cannot be predicted in advance and varies greatly by sector and visibility of the violation. What is certain, however, is that the legal basis has existed since this year where it was previously absent. Those who wish to check whether a webshop, app or business site with a login environment falls under the directive can do so using the free scope check.
What an Abmahnung is not
An Abmahnung is not a government decision and not a ruling by a supervisory authority. It is a request from a private party, often accompanied by a deadline and a proposal for a declaration that the violation will cease. The fact that an Abmahnung has been sent does not automatically mean that a court would reach the same conclusion, and the correct response depends on the precise content and German procedural law. This is something for a lawyer to assess, not something an automated scan or this article makes a ruling on.
It is also important to understand that an Abmahnung is separate from the route through the official supervisory authority. Both can exist side by side, and both concern the same underlying standard, but the approach and steps to be taken differ. Those who want to know more about how supervision and reporting routes differ by country will find more information in the knowledge base by situation.
What you can do about it in practice
The most obvious way to reduce the risk of an Abmahnung is the same as for supervision: know where your site or app currently stands in relation to the standard, and be able to demonstrate it. A visible, up-to-date accessibility statement and demonstrable self-assessment are not only a legal requirement, they also remove some of the grounds on which a warning letter can be based.
An automated scan, including ours, tests part of the requirements and that is stated in every report we deliver; what cannot be tested automatically remains manual work. Overlay widgets that claim to comply with the law do not, and we therefore do not sell them. For those who want to know what a full assessment, a prioritised action list and country-specific information entail in detail, that is clearly laid out on the pricing page and what is included.
Do you have specific questions about how this applies to your situation, for example because you supply to multiple countries at the same time? Then check out the frequently asked questions about country-specific differences, or first go through the free scope check at no obligation to see whether the directive and the associated risks apply to your business.