Knowledge & requirements for digital accessibility

Legal requirements and best practices

Challenges and status quo

Digital accessibility is more than just a legal requirement—it is a strategic success factor. It enables everyone, regardless of limitations, to access digital services. At the same time, it meets legal requirements such as the Accessibility Enhancement Act (BFSG) and BITV 2.0.

Public authorities: No website or mobile application is currently fully accessible (source: Second report by the Federal Republic of Germany to the EU).

Business: Many commercial websites and apps have significant barriers (source: Third test report 2025 on online shops).

Common problems:

Insufficient contrast.
Missing or unsuitable alternative text for images.
Cannot be operated using a keyboard.
Forms that are not accessible.
Missing labels for links and buttons.
Lack of support for screen readers.

Laws and guidelines for accessible administration in Germany

Public bodies such as government agencies and authorities have been subject to digital accessibility requirements for years. These are based on the Barrier-Free Information Technology Ordinance (BITV) in accordance with the UN Convention on the Rights of Persons with Disabilities and the Disability Equality Act (BGG). Compliance with the ordinance is monitored by the Federal Monitoring Agency for Barrier-Free Information Technology.

BITV 2.0 covers requirements for intranet and extranet offerings, apps, electronic administrative procedures, websites, and file formats for office applications (e.g., PDF documents). The BITV criteria are based on the Web Content Accessibility Guidelines (WCAG 2.1). These guidelines follow the principles of perceptibility, usability, comprehensibility, and robustness. The second version of the BITV refers in § 3 “Applicable Standards” to the applicable European standard EN 301 549 and its requirements.

The following requirements also apply to the generally accessible administration of the federal government:

Easy language and sign language

Public authorities must provide explanations in plain language and German sign language on their homepages.
Content includes navigation instructions, essential information, and an accessibility statement.

Accessibility statement

Websites and mobile applications must contain a statement explaining which content is not accessible.
A feedback mechanism and a reference to the arbitration body are available.

Accessible PDF documents

PDF documents can be used and read with assistive technologies such as screen readers.

Interactive offerings

Central navigation and entry offerings as well as interactive functions such as forms, authentication, and payment processes are accessible.

The Accessibility Enhancement Act (BFSG) for companies

The Accessibility Enhancement Act (BFSG) transposes EU Directive 2019/882 (European Accessibility Act) into German law and affects numerous industries and areas of application. The aim is to enable all people, regardless of individual limitations, to have equal access to digital services. Since June 28, 2025, the BFSG has required companies to make their services and products accessible to consumers.

Which services are affected by the BFSG?

E-Commerce

Online shops offering goods or services such as fashion, electronics, food, or travel bookings.
Digital marketplaces where multiple vendors sell their products.
Mobile shopping apps that support the purchasing process.
Digital offerings that are individually tailored to conclude a contract with consumers, such as online appointment bookings or subscriptions.

Banking and financial services

Credit agreements, services related to securities and investment activities

Deposit management, cash management, foreign exchange transactions, and others
Services associated with one's own payment account (e.g., opening, maintaining, and closing an account, as well as payment transactions)
Data carriers and documents related to the contract (e.g., a PDF file)
Online banking portals and mobile banking apps
Payment services (e.g., cashless payment services, e-money, identification and authentication methods, electronic signatures, security features)

Transportation and mobility services

Digital booking platforms for public transportation, such as trains, buses, ships, or airplanes in interregional passenger transport
Digital information and timetables (real-time travel information, traffic disruptions, connections, onward travel)
Digital ticketing systems
Interactive self-service terminals (ticket terminals, information terminals)

Telecommunications services (TC services)

Internet access services
Messenger and VoIP services
Telephony (landline and mobile)
TC services with voice communication
TC services with video

Media and entertainment

E-books
Software designed for e-books

Which physical products (hardware) are affected by the BFSG?

Universal calculator for consumers

Desktop computers
Notebooks
Smartphones
Tablets

Self-service terminals for BFSG services

Payment terminals
Cash machines
Ticket machines
Check-in machines
Interactive information terminals

Interactive devices for accessing audiovisual media services

Televisions with internet access (smart TVs)
Game consoles
Media adapters, media receivers, set-top boxes and HDMI sticks

Interactive devices for telecommunications services

Routers, modems
Smartphones and interactive mobile phones
Certain smartwatches
E-book readers

Are there any exceptions to the BFSG?

Under certain circumstances, economic operators are not covered by the BFSG. Micro-enterprises that offer services are not subject to the new accessibility regulations. However, if they offer physical products that fall under the BFSG, they are not exempt.

Micro-enterprises are defined as companies with fewer than ten employees and a maximum annual turnover or annual balance sheet total of €2 million.

When is something considered accessible?

A digital product or service is considered accessible if it meets the requirements of EN 301 549. This harmonized European standard defines the technical requirements for accessibility for digital services and products. These include websites, mobile applications, software, hardware, and electronic documents. It serves as the basis for practical implementation and technical standards. BITV 2.0 and BFSG reference the technical standard.

EN 301 549 is based on the Web Content Accessibility Guidelines (WCAG) 2.1 and the four principles:

- 1. Perceptibility: Content is accessible to all senses, for example through alternative text, subtitles, or sufficient contrast.
- 2. Operability: All functions can be used with different input methods, such as a keyboard and screen reader.
- 3. Understandability: Content and navigation are clear and intuitive.
- 4. Robustness: Content is compatible with different technologies and assistive devices.

The WCAG are a kind of internationally recognized “building code” for the internet. They provide guidelines for the design of websites so that they are accessible to people with disabilities.

EN 301 549 extends these principles with specific requirements that are mandatory for digital accessibility in Europe.

In summary:

WCAG 2.1 are the international guidelines that define the principles of accessibility.
EN 301 549 translates these guidelines into technical requirements for Europe.
The BFSG obliges private companies to implement EN 301 549.
BITV 2.0 regulates accessibility for public authorities and supplements EN 301 549 with specific requirements.

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