BITV 2.0 and WCAG: Germany’s Web Accessibility Law Explained

What is frequently unclear is the way accessibility is practiced in Germany. BITV 2.0 is not a set of recommendations or guidelines. It is a legal standard that is based on WCAG but implemented through German jurisprudence.

WCAG and BITV 2.0 are interlinked but they are different: 

• WCAG indicates how to obtain accessibility 
• BITV 2.0 indicates who has to follow, what is required, and how compliance is monitored 

This differentiation is crucial for public institutions, companies, and non-profits that work in regulated environments.

The following are the main points of the article: 

• How BITV 2.0 is different from WCAG 
• What the law requires in Germany
• Who is required to comply now and who will be the next to be affected

No theory. Just the facts that are necessary to evaluate compliance and responsibility.

BITV 2.0 (Barrierefreie-Informationstechnik-Verordnung) is the German law governing digital accessibility, which is legally binding. It specifies the requirements for designing websites, mobile apps, and digital documents in such a way that people with disabilities can access them easily.

BITV 2.0 stipulates WCAG 2.1 Level AA as its base standard. The technical specifications are derived from WCAG, but BITV 2.0 legalizes them as obligations under German law. Moreover, it introduces a formal dimension to the law with requirements like accessibility statements and feedback systems.

The regulation is based on the Disability Equality Act (BGG) and is applicable to the public sector only, which includes ministries, local governments, and universities, as well as other public institutions.

However, the rule for private companies has become less strict. 

The Accessibility Reinforcement Act (BFSG) has made the accessibility requirements applicable to many digital services targeting consumers in 2025 and onwards, especially in the banking, e-commerce, and transport sectors.

BITV 2.0 is legally binding in Germany, but its scope is clearly defined.

Public bodies are required to comply.

The compliance of the authorities at federal, state, and local levels is included in this requirement, along with the institutions governed by public law. Ministries, city governments, universities, and public sector institutions are the most common examples. 

The BITV 2.0 regulations should be followed for their websites, mobile apps, and digital documents.

Organisations performing public tasks may also be covered.

An organisation can be considered a performing public task if it acts on behalf of a public body or receives public funding, and its legal role and responsibilities will determine whether or not accessibility obligations apply to it.

Private companies are increasingly affected through related legislation.

The BITV 2.0 still focuses on public institutions, while the Accessibility Reinforcement Act adds that from 2025, private sectors providing services like e-commerce, banking, transport, and digital consumer services will also be covered under the new accessibility requirements.

In Germany, organizations' accessibility obligations vary according to their legal status, the scope of services offered, and the sector in which they operate. It is very important to clarify this at an early stage before considering any technical or organizational measures.

The WCAG (Web Content Accessibility Guidelines) is the globally recognized technical standard for accessible digital services. It specifies the requirements of accessibility for websites, apps, and digital content for people with disabilities.

W3C or the World Wide Web Consortium is the organization behind the development of WCAG, and the standard is considered as the technical groundwork of accessibility laws around the globe, including Germany.

Presently, the most relevant versions are the WCAG 2.0 and WCAG 2.1, which are built around four key principles ("POUR"):

• Perceivable: Nothing should stop users from seeing, hearing, or receiving alternative presentations of the content
• Operable: The interface should be accessible through keyboard and assistive technology
• Understandable: The information and the user interaction should be simple and predictable
• Robust: The content should be equally good and usable on all browsers, devices, and assistive software

There are three conformity levels in the WCAG:

• Level A - Minimum requirements for accessibility
• Level AA - The legally accepted standard in Germany
• Level AAA - Accessibility greatly improved but not required by law

For Germany, WCAG 2.1 Level AA is the practical and legal standard.

It is the level of accessibility that includes the users; at the same time, it does not go further than what is reasonable. This is the level that is cited by BITV 2.0 and associated regulations.

Accessibility compliance under BITV 2.0 is monitored and documented in a formal way. Websites and apps in the public sector are subjected to the reviews of assigned monitoring bodies at the federal and state levels.

This process is based on the EU Directive 2016/2102, which mandates that the accessibility status of public digital services be reported periodically.

How audits are conducted

The compliance verification process consists of a multi-layered method:

• Automated testing: This is the method used to spot technical problems like absence of alternative texts, contrast mistakes, or wrong HTML structure.
• Manual testing: This step is crucial to evaluate keyboard navigation, focus handling, form usability, and logical content order, where automation cannot give reliable results.
• User-based testing: In many cases, the evaluation includes individuals with disabilities to ascertain the usability from a real-life perspective and also to point out the barriers that exist in practice.

What are the criteria for evaluation?

All the checks are performed with respect to the WCAG 2.1 Level AA standard which is the legal standard required by BITV 2.0.

Exclusively using automated tools is not sufficient. Manual validation documented is a necessity to prove compliance.

How Accessibility Is Enforced and Monitored in Germany

Accessibility Compliance under BITV 2.0 is not only based on self-declaration. Monitoring in Germany is ongoing when it comes to compliance.

The public sector's websites and applications go through the monitoring procedures regularly and these procedures are coordinated at both federal and state levels. The reviews are aligned with EU Directive 2016/2102 and are done according to a specified evaluation framework.

Monitoring usually comprises:

• Automated testing as a means of discovering technological flaws
• Manual reviews focusing on evaluating the hierarchy, navigation, and overall experience
• User-based testing where disabled individuals are often engaged

Every single review measures adherence to WCAG 2.1 Level AA, which is the standard required by BITV 2.0. 

The situation gets documented and the report is issued. In case of discovering accessibility issues, these will have to be fixed by the concerned organization in a reasonable period of time.

The outcome of monitoring might also affect the necessity of future audits or the use of formal procedures. Thus, for the public sector, accessibility is not a one-off job but a continuous duty that needs to be recorded and preserved for the long run.

In case your website or application does not fulfill the requirements, the organization has to face the following possible consequences:

• User feedback: Every person can file a complaint through the feedback system - and the organization must reply.
• Legal action: If the matter is not settled, it might go to an arbitration institution or a regulatory authority.
• Public disclosure: The accessibility statement has to be easily accessible to the public and current. Thus, the absence of accessibility is known by everyone - even the monitoring bodies.
• Damage to reputation: The inaccessibility of public institutions implies that certain citizens are not taken into consideration. It is a source of losing trust and reputation for companies.
• User complaints and feedback procedures: Any individual can notify about accessibility hindrances through the compulsion feedback mechanism. Organizations are obliged to reply within the set time intervals.
• Formal review and escalation: If difficulties still exist, the issue can be taken to arbitration or supervisory bodies. These authorities might then start another round of review or enforcement.
• Public visibility of non-compliance: Accessibility statements have to be made public and regularly updated. The users, the monitoring bodies, and the oversight authorities can see the identified accessibility gaps.
• Reputational and trust impact: Accessibility issues for public entities create a public trust deficit and inclusiveness perception. For private companies, the issues could lead to loss of credibility, customer confidence, and legal certainty.

BITV 2.0 compliance is not achieved through a single check. It requires structured testing, clear documentation, and ongoing responsibility.

1. Carry out accessibility testing

Initially, conduct a mixture of automated and manual testing.

• Leverage tools like TYPO3 Accessibility Checker to spot the tech problems.
• Manually validate the results to examine keyboard use, focus order, and usability.
• When possible, involve real users to find out practical hindrances.

Though automated tools assist the process, they still cannot substitute for manual validation.

2. Prioritize fixing the issues preventing access first

Concentrate on the problems that limit users to the core functions and content, like:

• Absence or wrong alternative texts
• Low colour contrast
• Keyboard traps
• Confusing or broken navigation

If the users can't access vital content, the compliance is not met.

3. Make a public accessibility statement

BITV 2.0 calls for a public accessibility statement.

This must indicate the following points clearly:

• Present compliance state
• Barriers known
• Contact and feedback options

The statement has to be updated regularly.

4. Allow user feedback

Feedback mechanism is a must. Users should have a hassle-free way to report barriers.

Not responding or acting on the feedback could result in formal complaints or escalation.

5. Accessibility must be embedded into the daily workflows

Accessibility should be part of:

• Design choices
• Content creation
• Dev and QA

Train personnel and document responsibilities to secure long-term compliance, not just one-time fixes.

WCAG defines the technical accessibility criteria. It explains how digital content must be built so it can be used by people with disabilities. On its own, WCAG is not a law.

BITV 2.0 is the legal framework in Germany that makes WCAG requirements mandatory for defined organisations. It adds formal duties such as accessibility statements, feedback mechanisms, and documented compliance.

What this means for organisations in Germany

• Following WCAG is necessary, but not sufficient, for legal compliance
• BITV 2.0 determines whether compliance is mandatory, how it is assessed, and what happens if gaps exist
• Legal responsibility depends on:
  • Organisational role
  • Sector (public or private)
  • Type of digital service offered

In short, WCAG explains how to build accessible systems. BITV 2.0 defines who must comply and how accessibility is enforced in Germany.

BITV 2.0 and WCAG 2.1 pursue a common goal: to make digital services accessible to everyone.

But this is not just about ticking off a legal checklist. It's about creating digital systems that include and respect all people - regardless of their abilities.

By understanding how BITV builds on WCAG, you can ensure that your implementation goes beyond the legal minimum. The goal is to create digital environments that are functional, inclusive and future-proof.

Accessibility is not an additional task. It is simply good work.

Start with an accessibility audit. Learn more about BITV 2.0 and your responsibilities, and get your team involved. If you don't know where to start, our TYPO3 Agency - NITSAN will be happy to advise you.

For more practical tips and insights around digital accessibility and legal requirements, visit our blog: Accessible Website With TYPO3 Accessibility!