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Relevance of the WCAG for your company

Information about WCAG 2.1

WCAG stands for Web Content Accessibility Guidelines and contains guidelines for the accessibility of content on the Internet. WCAG has shaped the standard of internet content accessibility legislation in most countries around the world.

The WCAG were created by the World Wide Web Consortium, known as W3C, to address the accessibility aspect of web pages. The W3C was founded in October 1994 at the MIT Laboratory for Computer Science (MIT/LCS). Founding members include several top scientists, and by the end of 2019, the organization has over 440 members, including leaders from business, nonprofits, universities, and various government agencies.

Originally, W3C focused on standardizing Web protocols so that Web pages and Web tools would be compatible with each other. Each W3C standard is reviewed, tested and analyzed several times before it is approved by the members.

Web accessibility was an early issue addressed by the W3C. The first version of the WCAG was published in 1999. In 2018, a revision took place, resulting in the WCAG 2.1 guideline we know today.

Principles of WCAG

The full WCAG is incredibly long and complex, and includes many different points and requirements for the operator of a website. However, the basic principle of all elaborated points is based on 4 essential principles: perceptible, operable, understandable and robust.
Here are the details:



Perceptual refers to the way users perceive content online through their senses of sight, hearing, and touch. This concerns aspects such as alternative texts for images, the ability to adjust texts in the areas of contrast, color, text size and spacing, font and similar factors that facilitate readability.


Usability is the way someone can use the website. It is especially relevant for people with motor disabilities, weak muscles, injured limbs, visual impairments, etc. An operable website must be fully navigable via keyboard, vision-assisted navigation, and other alternatives to a mouse.


Understandable pages are understandable for everyone. They avoid technical terms or convoluted sentences and do not include complicated instructions.


One of the essential factors of a robust site is that it includes clean HTML and CSS code that conforms to recognized standards, thereby ensuring compatibility with the assistive devices of people with disabilities.

Guidelines as a standard for laws

Accessibility laws

The WCAG is not a law, but many governments have adopted the guidelines as a standard for their accessibility laws. Here is a brief overview of accessibility laws in the European Union:

In 2010, EU officials adopted WCAG 2.0 Level AA as mandatory for all official EU sites and extended this to all public sector web platforms. In 2018, the criteria of WCAG 2.1 were included. The EU also adopted the WCAG as the standard for the new European Accessibility Act (EAA), which will come into force in 2025 as a supplement to the current rules.

Ignoring WCAG poses legal risks, as it is the backbone of accessibility legislation in most countries around the world and is considered the most reliable and effective set of accessibility standards in the world.

Who does the law affect?

According to the BGG, all federal public agencies are required to make the following areas accessible in the digital domain:

Websites (including intranets and extranets), apps, and electronic administrative processes (cf. Section 12a (1) BGG).

The obligation for barrier-free design also refers to further content that is integrated into the web pages such as PDF files, videos and graphics.

The overall scope of the barrier-free design is based on the possible technical standards. For federal authorities, these result from the Barrier-Free Information Technology Ordinance 2.0 (BITV 2.0). The updated BITV 2.0 refers to the harmonized standards published in the Official Journal of the European Union. This is currently EN 301 549 V.2.1.2 (2018-08), which in turn refers to WCAG. The requirement to make websites accessible according to the “state of the art” means that what is technically possible must be done. For example, the state of the art is likely to be ISO 14289-1:2012-07 for the accessible design of PDF files (PDF/UA standard), although this standard is not part of EN 301 549 V.2.1.2 (2018-08).

Also, an accessibility statement must be integrated into the web presence. This must state which parts or content of the website or app have not (yet) been designed to be completely accessible and why. If available, a reference to accessible content alternatives shall be provided. The statement must be accessible from the home page and every page of a website. In the case of mobile applications, publication in the place where the application can be downloaded or on the website of the public body concerned is sufficient.

On the website or in the app, the possibility must be given to provide feedback in order to report (in particular) existing barriers to the website operator. The latter must respond to the feedback within one month. The feedback mechanism shall be integrated into the website/app in addition to the accessibility statement. For websites, the feedback mechanism – as well as the accessibility statement – should be accessible from every page of a website; for apps, integration in the navigation is sufficient.

Since the opportunity to provide feedback is an interactive process, a higher level of accessibility must be achieved for it (cf. Section 3 (4)). This should correspond to level AAA of the Web Content Accessibility Guidelines (WCAG) 2.1. Background: The standard EN 301 549 V2.1.2 (2018-08), which is currently mandatory for accessible design, refers to the success criteria of level AA of WCAG 2.1 for accessible design of the web, but only lists the success criteria of level AAA in the annex for informational purposes, i.e. without obligation.

Who does the law affect beyond municipalities?

The EU Directive has drawn the circle of obligated public bodies significantly larger than the previously applicable Disability Equality Act (BGG). According to the EU Directive, all those entities that are obliged to comply with EU public procurement rules are also obliged to ensure accessibility of websites and mobile applications. For federal public bodies, the federal legislature has implemented this in Section 12 sentence 1 numbers 2 and 3 BGG.

Project sponsors and other funding recipients are therefore required to provide digital accessibility if they fall under Section 12 sentence 1 numbers 2 or 3 BGG. One of the requirements specified therein is funding of more than 50 percent by the Federal Government (cf. Section 12, Sentence 1, Numbers 2 and 3, each letter a)). Grants – whether institutional or project-based – represent funding from the federal government.

Accessibility for digital products and services

Information about EAA/EN301549

The European Accessibility Act (EAA) is a regulation adopted by the EU in April 2019 that mandates accessibility for digital products and services.

EN 301549 is a document created by the European Telecommunications Standards Institute (ETSI). EN 301549 defines official web accessibility standards.

When did EAA and EN 301549 come into force?

Web accessibility regulation has been a lengthy process that began in the 2000s. Since then, EU authorities have taken into account the needs of citizens with disabilities in their policy decisions.

The important milestones on the way to web accessibility were the following:

In 2006, there was the Riga Declaration, which set full Internet accessibility as a goal for the coming years.

In 2010, the European Disability Strategy was adopted to harmonize accessibility requirements for areas of life for disabled citizens in all EU Member States.

In 2015 the first version of EN 301549 was published by ETSI, in this document the accessibility standards for the private sector were defined.

In 2016, the Web Accessibility Directive required all public services to make their websites and associated mobile apps accessible to users with disabilities.

The latest version of EN 301549 was published in 2018 based on the Web Content Accessibility Guidelines (WCAG) of the World Wide Web Consortium (W3C). These defined accessibility standards became law when the EAA was passed in 2019.

The EAA gives private entities five years to comply with accessibility requirements. These five years end on June 28, 2025.

What are the requirements of the EAA?

The EAA does not define country-specific accessibility standards or compliance requirements, but as usual leaves the detailed elaboration under the sovereignty of individual member countries. However, the EAA defines usability requirements that align with WCAG 2.1. such as that no website or digital service should be limited to a single mode of interaction. For example, audio content must also be accessible via captions and written text must also be accessible via a screen reader.

Who must follow the EAA?

The EAA is not designed as a blanket law that affects everyone. Products and services covered by the new law include, for example:

  • Computers and operating systems
  • Telephone services and related equipment
  • Audiovisual media services, such as television broadcasts and related consumer devices
  • Services related to air, bus, rail and other passenger transportation
  • Banking services
  • eBooks
  • eCommerce

Although the regulation was originally aimed at public and government groups, it indirectly affects private companies as well. Companies that provide services to government agencies in Europe must ensure that their accessibility standards meet the requirements of the law. The EAA goes on to require that all online business services be accessible to people with disabilities.

The EU directive defines transition periods and additional requirements: Accordingly, newly launched websites had to be offered barrier-free by September 2019, already existing ones have to be barrier-free by September 2020. Mobile applications have an extended deadline of June 2021. In addition, the operator of the website must publish an accessibility statement and offer a feedback option for users.

Law on Equality for People with Disabilities

German legislation

The requirements for implementing website accessibility in Germany are set out in the Act on Equal Opportunities for People with Disabilities and the Barrier-Free Information Technology Ordinance.

Authorities of the federal administration are required by the Act on Equal Opportunities for People with Disabilities (BGG) to make their websites barrier-free. With the amendment of the BGG in 2016, regulations for an accessible intranet were added. In July 2018, it was adapted in view of EU Directive 2102. The following important changes have entered into force:

Scope of application extended to federal public bodies (§ 12 BGG)

  • Deletion of the vague “gradual” implementation – the requirements now apply directly
  • Regulation on accessibility of electronically supported administrative processes from 2021 onwards
  • Derogation for the case of disproportionate burden
  • Obligation to prepare an accessibility statement with feedback mechanism
  • Establishment of a federal monitoring agency for accessibility of information technology in the form of a separate, independent department of the German Pension Insurance Knappschaft-Bahn-See (§ 13 BGG)
  • Enforcement proceedings are settled with a conciliation body; since 2016, these have been the Federal Government Commissioner for Matters Relating to Persons with Disabilities

The requirements that apply are defined in the Barrier-Free Information Technology Ordinance (BITV). BITV 2.0 is based on the requirements of EN 301 549, which refers to WCAG.

State laws on barrier-free information technology in accordance with EU Directive 2102

For public bodies of federal states and municipalities, web accessibility is regulated by state laws and state-specific ordinances:

  • Baden-Württemberg: State Disability Equality Act – L-BGG and L-BGG Implementation Ordinance, Monitoring Office for Media Accessibility Baden-Württemberg at the German Pension Insurance Baden-Württemberg.
  • Bavaria: Bavarian Disability Equality Act – BayBGG and Bavarian Barrier-Free Information Technology Ordinance – BayBITV, monitoring body at the State Office for Digitization, Broadband and Surveying.
  • Berlin: Barrier-free ICT Act Berlin – BIKTG Bln, monitoring body at the Senate Administration for the Interior and Sports
  • Brandenburg: Brandenburg Equal Opportunities for Disabled Persons Act – BbgBGG, Brandenburg Barrier-Free Information Technology Ordinance – BbgBITV, Monitoring Body at the State Office for Social Affairs and Supply
  • Bremen: Bremen Equal Opportunities for Disabled Persons Act – BremBGG, monitoring body is the Central Office for Barrier-Free Information Technology
  • Hamburg: Hamburg Act on Equality for Disabled Persons – HmbGGbM, Hamburg Barrier-Free Information Technology Ordinance – HmbBITVO, Monitoring Office at the Office for IT and Digitalization (ITD) of the Senate Chancellery.
  • Hesse: Hessian Disability Equality Act – HessBGG, Hessian Ordinance on Barrier-Free Information Technology – BITV HE 2019, Monitoring Body for Barrier-Free IT at the Gießen Regional Council.
  • Mecklenburg-Western Pomerania: State Disability Equality Act – LBGG M-V, Barrier-free Website Ordinance Mecklenburg-Western Pomerania – BWebVO M-V, Monitoring Agency Ministry of Social Affairs, Integration and Equality
  • Lower Saxony: Lower Saxony Disability Equality Act -NBGG, monitoring body at the Ministry of Social Affairs, Health and Equality.
  • North Rhine-Westphalia: Disability Equality Act of North Rhine-Westphalia – BGG NRW and Barrier-Free Information Technology Ordinance of North Rhine-Westphalia – BITVNRW, Monitoring Body at the Ministry of Labor, Health and Social Affairs of the State of North Rhine-Westphalia.
  • Rhineland-Palatinate: State Law on Equality for Disabled Persons – LGGBehM, Barrier-Free Information Technology Ordinance Rhineland-Palatinate – BITV RP
  • Saarland: Saarland Equal Opportunities for Disabled Persons Act – SBGG, Saarland Equal Opportunities for Disabled Persons Ordinance – SBGVO
  • Saxony: Saxon Inclusion Act and Barrier-Free Websites Act, Monitoring Body at the German Center for Barrier-Free Reading (read dzb)
  • Saxony-Anhalt: Saxony-Anhalt Equal Opportunities for Persons with Disabilities Act – BGG LSA, Saxony-Anhalt State Office for Accessibility at the Saxony-Anhalt Accident Insurance Fund.
  • Schleswig-Holstein: Act on the Equality of Persons with Disabilities in Schleswig-Holstein (Landesbehindertengleichstellungsgesetz – LBGG), State Ordinance on Barrier-Free Access to Websites and Mobile Applications of Public Authorities – BFWebV SH
  • Thuringia: Thuringia Act on Accessibility to the Websites and Mobile Applications of Public Authorities – ThürBarrWebG, Central Monitoring Office for Digital Accessibility at the Thuringian Ministry of Finance.

DIGIaccess fulfills the requirements