BITV 2.0 and WCAG: Germany's Web Accessibility Ordinance Explained

In short: WCAG is the technical accessibility standard. BITV 2.0 is an ordinance that refers to it and makes it binding for federal public bodies. For private providers of certain consumer products and services, the BFSG has applied since 28 June 2025. For BITV 2.0, WCAG 2.1 Level AA is currently the relevant benchmark; WCAG 2.2 has been a W3C Recommendation since 5 October 2023.

WCAG and BITV 2.0 are linked but different:

• WCAG describes how accessibility is achieved technically.
• BITV 2.0, together with the Disability Equality Act (BGG), defines which federal public bodies must comply, which additional duties apply and how compliance is monitored.

This article covers:

• How BITV 2.0 differs from WCAG
• Who is affected and who may fall under the BFSG instead
• How compliance is checked and which practical steps help

For TYPO3 websites, also read our article TYPO3 accessibility. For practical implementation, we have put together a guide with checklist.

Status: October 2026. General information, not legal advice.

BITV 2.0 (Barrierefreie-Informationstechnik-Verordnung of 12 September 2011, last amended on 24 October 2023) is the legally binding German ordinance on digital accessibility for federal public bodies. It defines which websites, mobile apps and electronically supported administrative processes the requirements apply to (section 2 BITV 2.0).

Technically, section 3 BITV 2.0 presumes that the requirements are met if the offerings conform to harmonised standards cited in the EU Official Journal. Currently this is EN 301 549 in version V3.2.1 (Implementing Decision (EU) 2021/1339) and therefore WCAG 2.1 Level AA. The technical requirements come from WCAG; BITV 2.0 makes them binding for the bodies concerned. The accessibility statement and the option to give feedback follow from section 12b of the BGG.

The ordinance is based on the Disability Equality Act (BGG) and applies to federal public bodies. States and municipalities have their own laws, which are based on the same EU Directive (EU) 2016/2102.

For private companies, the Barrierefreiheitsstärkungsgesetz (BFSG) has applied since 28 June 2025. It covers certain products and services for consumers, for example in e-commerce, consumer banking services and elements of passenger transport services. Whether your offering falls under it should be checked in the individual case.

Status: October 2026. General information, not legal advice.

BITV 2.0 is legally binding, but its scope is clearly limited.

Federal public bodies

BITV 2.0 applies to federal public bodies within the meaning of section 12 BGG, that is, federal authorities and other bodies exercising public authority at federal level. For state and municipal authorities, universities and other state institutions, the respective state law applies. It is based on the same Directive (EU) 2016/2102 and often follows the BITV.

The requirements cover websites, mobile apps and electronically supported administrative processes (section 2 BITV 2.0).

Organisations performing public tasks may also be covered.

Under section 12 BGG, this also includes institutions established to perform non-commercial tasks in the general interest that are mainly financed by the Federation or are subject to federal management or supervision. Their legal role and responsibilities determine whether accessibility obligations apply.

Private companies are affected through the BFSG.

BITV 2.0 is addressed to public bodies. For private providers of certain consumer-facing products and services, for example in e-commerce or banking services, the Barrierefreiheitsstärkungsgesetz (BFSG) has applied since 28 June 2025.

Obligations depend on legal status, the scope of services offered and the sector. Have this clarified early, before planning technical or organisational measures.

The WCAG (Web Content Accessibility Guidelines) are the globally recognised technical standard for accessible digital offerings. They specify accessibility requirements for websites, apps and digital content for people with disabilities.

The World Wide Web Consortium (W3C) develops the WCAG. The standard is the technical foundation of many accessibility rules worldwide, including in Germany.

For BITV 2.0, WCAG 2.1 is currently the relevant version, because the version of EN 301 549 cited so far in the EU Official Journal (V3.2.1) refers to it. The W3C published WCAG 2.2 as a Recommendation on 5 October 2023; it adds nine success criteria and removes 4.1.1 Parsing. EN 301 549 V4.1.1, which incorporates WCAG 2.2, was published in September 2026 according to Deque and Davis Wright Tremaine (adopted on 24 August 2026). At the end of October 2026, according to Barrierewerk and Deque, it had not yet been cited in the EU Official Journal. The WCAG are built around four principles ("POUR"):

• Perceivable: Nothing should stop users from seeing, hearing or receiving content in an alternative form
• Operable: The interface should be usable by keyboard and with assistive technology
• Understandable: Information and operation should be simple and predictable
• Robust: Content should work across browsers, devices and assistive technologies

There are three conformance levels:

• Level A: Minimum accessibility requirements
• Level AA: The level cited by BITV 2.0 and EN 301 549
• Level AAA: Highest level, generally not required by law

For federal public bodies in Germany, WCAG 2.1 Level AA is currently the relevant technical benchmark.

This level includes many user groups while staying practical. It is cited by BITV 2.0 and related rules through EN 301 549.

For federal public bodies, compliance with BITV 2.0 is monitored and documented. Monitoring is based on Directive (EU) 2016/2102, which requires member states to monitor and report on the accessibility of public-sector websites and apps. At federal level, the BGG provides for a federal monitoring body for the accessibility of information technology (section 13(3) BGG, section 5 BITV 2.0).

How checks are typically carried out

• Automated testing: finds technical problems such as missing alternative texts, contrast errors or faulty HTML structure.
• Manual testing: evaluates keyboard navigation, focus handling, forms and logical content order, where automation is not reliable.
• User testing: involving people with disabilities shows barriers that occur in practice.

Evaluation basis

Checks refer to WCAG 2.1 Level AA through EN 301 549 (V3.2.1). Automated tools alone are not sufficient; documented manual validation is the more reliable way to show conformance.

Monitoring in Germany

Monitoring is carried out at federal and state level using a defined evaluation method. Results are documented. If barriers are found, the body concerned is expected to remedy them. Accessibility is therefore an ongoing task that should be documented.

If a website or app of a federal public body does not meet the requirements, the following can happen:

• User feedback: Anyone can report barriers through the contact option in the accessibility statement; the body must reply within one month at the latest (section 12b BGG).
• Arbitration: If the matter is not resolved, an arbitration procedure under section 16 BGG may follow.
• Monitoring and follow-up: The monitoring bodies document results and report on them.
• Public visibility: The accessibility statement must be public and current, so known gaps are visible.
• Trust: Inaccessible services can reduce trust among users.

For private providers covered by the BFSG, market surveillance by the states and fines of up to €100,000 can apply (section 37(2) BFSG). This is general information, not legal advice.

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. Fix the barriers that block access first

Concentrate on problems that stop users from reaching core functions and content:

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

If users cannot access vital content, the requirements are not met.

3. Publish an accessibility statement

Federal public bodies must publish an accessibility statement under section 12b BGG. It contains:

• Parts of the content that are not fully accessible, with reasons and, where applicable, accessible alternatives
• An electronic way to get in touch to report barriers
• A reference to the arbitration procedure under section 16 BGG

Keep the statement up to date.

4. Provide a feedback mechanism

Users should have a simple way to report barriers. Federal public bodies must reply to messages within one month at the latest.

5. Embed accessibility in daily workflows

Accessibility belongs in design, content creation, development and QA. Train staff and document responsibilities so that compliance does not depend on 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.

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

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

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!