Digital Accessibility Knowledge Centre – did you know?

Through our Digital Accessibility Knowledge Centre, we help you to deepen your understanding of the requirements and implications of digital accessibility and the Accessibility Enhancement Act (BFSG), so that you can better assess the legal and practical aspects.

This information is important for everyone within organisations who is responsible for ensuring legal compliance and improving accessible access to services and products. This includes, in particular, senior management, the legal department, product development and management, the IT department, compliance officers, quality management and marketing.

It primarily applies to digital services intended for consumers and provided by businesses of a certain size. Not all commercial websites are automatically covered by the BFSG. Here are the key points:

The following are affected:

Online shops and e-commerce platforms
Banks and financial service providers (e.g. online banking)
Telecommunications providers
E-book platforms and streaming services
Ticketing systems for travel and events
Hotel booking portals

The following are not affected:

Small businesses (fewer than 10 employees and an annual turnover of less than €2 million)
Personal websites and blogs (which are not operated commercially)
Websites of micro-enterprises, provided they do not offer essential services

What does this mean for website operators?

From 28 June 2025, affected websites must be designed to be accessible. This means:

Alternative text for images
Keyboard accessibility
Clear structures and contrasts
Plain language and clear navigation

The relevance and importance of smartphones and apps

Apps are applications on smartphones.
Compared to computers, they offer:
Greater mobility
Greater user-friendliness and more intuitive use
Greater accessibility and therefore a wider user base
Around 68.5 million smartphone users in Germany (source: statista.com)
Apps for almost every area of life, e.g.
banking apps
Shopping apps
Waste management apps
An integral part of everyday life

The case for accessibility and the benefits of smartphones and apps for people with disabilities

9.3 per cent of people in Germany have a severe disability.
18.9 per cent of people in Germany are over 65 (source: statista.com), of whom 73 per cent use smartphones (source: bitkom.org).
Temporary impairments caused by, for example, illness or an accident

Benefits of accessibility for people with disabilities

Speech recognition and voice control
Apps for various needs (e.g. for recognising objects)
Autocomplete and word completion
Zoom
Built-in screen readers
Haptic feedback and vibration alerts
Video calls

Benefits of accessibility

Usability and accessibility for everyone
Reach a wider range of user groups
An improved user experience for everyone
Supports search engine optimisation (SEO)

Legal requirements

Government departments and public bodies

Under EU Directive 2016/2102, public authorities are obliged to ensure that mobile applications are accessible to all citizens. In Germany, this directive is implemented through the Law on Equal Opportunities for People with Disabilities (BGG) and the Accessible Information Technology Ordinance (BITV).
Mobile applications are tested for accessibility in accordance with the global standards EN 301 549 and WCAG.

Businesses

From 2025, the Digital Accessibility Enhancement Act (BFSG) will make digital accessibility mandatory for companies as well. This legislation is based on EU Directive 2019/882 and includes mobile applications. Businesses must test and adapt their apps and websites accordingly.

Greater clarity for everyone

The terms ‘plain language’ and ‘simple language’ are often used interchangeably, although they refer to two different concepts.

Whilst plain language is aimed at a general audience, easy-to-read language focuses on people with cognitive impairments or so-called intellectual disabilities. People with learning difficulties, as they refer to themselves, are not only involved in drawing up guidelines for easy-to-read language, but should also be included as reviewers to assess the comprehensibility of texts written in easy-to-read language.

Both simple language and easy-to-read language make it easier for people who, for various reasons, have limited reading comprehension skills in German to understand texts. This benefits, for example, people whose first language is not German, deaf people and people living with dementia. Easy-to-understand language contributes to social participation by encouraging people to access information independently and make self-determined decisions.

Around 6.2 million German-speaking adults aged between 18 and 64 have difficulty reading and writing letters, words or sentences. That is 12.1 per cent of the relevant total population (source: Leo 2018 – Living with Low Literacy). By using simple language and plain language, you can help these people to understand the texts on your website.

Easy-to-read language	Simple language
Easy-to-read language follows clearly defined rules (e.g. putting important content first, using short sentences and explanatory images).	Plain language is modelled on spoken language.
Easy-to-read language should be checked for comprehensibility by members of the target group (target group testing).	Simple language has a higher linguistic level than plain language.
Plain language is a requirement of the Accessible Information Technology Regulation (BITV 2.0).	Plain language can be used in the context of complying with the Act on Strengthening Accessibility (BFSG) to make information available in an understandable way.
Target group: People with cognitive impairments or learning difficulties	Target group: People with low literacy levels, i.e. those with difficulties in reading and writing
Standard for plain language: DIN SPEC 33429 Recommendations for German Plain Language	Standards for plain language: DIN ISO 24495-1:2024-03 Plain Language – Part 1: Principles and guidelines (ISO 24495-1:2023) and DIN 8581-1 Plain Language – Application for German – Part 1: Language-specific specifications

Another term you may come across in the context of easy-to-understand language is ‘citizen-friendly administrative language’. This simplified version of the German language refers to communication between public authorities and citizens. When it comes to explaining legal matters, the term ‘citizen-friendly legal and administrative language’ is sometimes used.

Excerpt: Plain Language and Simple Language

UN Convention on the Rights of Persons with Disabilities

The Convention aims to ensure the full and equal participation of people with disabilities in all areas of life. This means that people with disabilities should have the same rights and opportunities as everyone else. This also applies to equal access to digital services.

Directive (EU) 2016/2102 of the European Parliament and of the Council

This Directive is intended to ensure that all citizens, regardless of their abilities, have access to important information and services provided online by public sector bodies. This applies to both mobile applications and websites. The Directive was implemented in Germany through the Disability Equality Act (BGG) and the Accessible Information Technology Regulation (BITV 2.0).

Directive (EU) 2019/882 of the European Parliament and of the Council

The Directive is an important step towards improving accessibility in the EU and helps to strengthen the participation of people with disabilities in social and economic life. The aim is to improve the accessibility of products and services at European level. This Directive is implemented in Germany through the Accessibility Enhancement Act (BFSG).

Disability Equality Act (BGG)

The BGG aims to eliminate discrimination against people with disabilities in Germany and to promote their equal participation in social life. It contains requirements regarding accessibility in public spaces and obliges public bodies to comply with the BITV 2.0.

BITV (Accessible Information Technology Regulation) 2.0

The BITV 2.0 plays a central role in making digital content in Germany accessible to people with disabilities. It is based on EU Directive 2016/2102 on the accessibility of websites and mobile applications of public sector bodies. It serves as the basis for the accessibility requirements for websites and apps operated by public sector bodies.

Accessibility Enhancement Act (BFSG)

The BFSG extends the accessibility requirements to the private sector. It transposes the EAA (European Accessibility Act) into national law and, for the first time, also requires private companies to ensure the accessibility of their products and services. This applies in particular to digital services, with a view to promoting the participation of people with disabilities in economic and social life.

Web Content Accessibility Guidelines (WCAG)

The WCAG are international guidelines that set out standards for the accessibility of web content. They were published by the World Wide Web Consortium (W3C) and comprise four principles: ‘Perceivable’, ‘Operable’, ‘Understandable’ and ‘Robust’. Within these principles, there are 13 guidelines and 78 success criteria, which are categorised into three levels of conformance: A (Single A), AA (Double A) and AAA (Triple A). These criteria also form the basis for testing in accordance with EN 301 549.

EN 301 549

This European Standard sets out the requirements for the accessibility of information and communication technologies (ICT). It is based on the WCAG and covers a wide range of products and services, including software, hardware, mobile applications and electronic documents. The standard is an essential component of accessibility requirements. It thus serves as the basis for the Accessibility Enhancement Act (BFSG) and the BITV 2.0.