BITV 2.0 (Barrierefreie-Informationstechnik-Verordnung 2.0) is a German federal ordinance issued by the Federal Ministry of Labour and Social Affairs in 2011 and amended in 2019 to implement the EU Web Accessibility Directive. It points to EN 301 549 (WCAG 2.1 AA for web content) and applies to federal public bodies; each German state has its own equivalent law. Together with § 12b BGG it requires an accessibility statement (Erklärung zur Barrierefreiheit) and a feedback mechanism.

What is the BFSG, and is it different from BITV 2.0?

Yes. They are two separate, real German laws. BITV 2.0 applies to the public sector. The Barrierefreiheitsstärkungsgesetz (BFSG, the Accessibility Strengthening Act) transposes the European Accessibility Act (EAA) into German law for private-sector products and services placed on the German market. It doesn't require the public-sector style accessibility statement; instead, service providers must publish the Annex 3 information, for example in their terms and conditions.

What must a German accessibility statement (Erklärung zur Barrierefreiheit) include?

Under § 12b BGG and BITV 2.0 the statement gives the conformance status and the content that isn't accessible, offers a feedback mechanism, and links to the conciliation procedure (Schlichtungsverfahren) of the Schlichtungsstelle under § 16 BGG, based at the Federal Government Commissioner for Persons with Disabilities. This applies to public bodies; BFSG service providers publish Annex 3 information instead.

What WCAG level does BITV 2.0 / BFSG require?

Both point to EN 301 549, whose web section corresponds to WCAG 2.1 AA. Meeting WCAG 2.1 AA covers the web-content part; BITV 2.0 adds a few requirements of its own (such as information in German Sign Language and Easy Language on the homepage), and the BFSG has product- and service-specific requirements.

Who does BITV 2.0 apply to, and who does BFSG apply to?

BITV 2.0's scope is federal public bodies; the states have their own equivalent laws. BFSG's scope is private-sector products and services placed on the German market, since it transposes the EU-wide Accessibility Act (which entered enforcement across the EU on June 28, 2025) into German federal law.

Legal · Germany

Germany BITV 2.0 & BFSG

Two separate German laws govern digital accessibility: BITV 2.0 for the public sector, and the BFSG for private-sector products and services. This guide covers both, and the accessibility statement each requires.

Standard: EN 301 549 (WCAG 2.1 AA)BITV 2.0: 2011, amended 2019BFSG: in force since June 28, 2025

Two Separate German Laws

"Germany accessibility law" is not one single statute. BITV 2.0 and the BFSG are two distinct, real laws with different scope.

BITV 2.0 (Barrierefreie-Informationstechnik-Verordnung 2.0)

2011 (amended 2019) · Federal Ministry of Labour and Social Affairs (BMAS)

German federal ordinance implementing the EU Web Accessibility Directive (WAD). Aligns with EN 301 549 / WCAG 2.1 AA. Requires an accessibility statement and feedback mechanism.

EN 301 549 (WCAG 2.1 AA aligned)Federal public bodies (each German state has its own equivalent law)

BFSG (Barrierefreiheitsstärkungsgesetz)

Transposes EAA · German federal law

The Accessibility Strengthening Act transposes the European Accessibility Act (EAA) into German law. Covered products and services (e-commerce, banking, e-books, telecoms and more) must be accessible from June 28, 2025, and service providers must publish the information set out in Annex 3, for example in their terms and conditions. Fines go up to €100,000 (§ 37 BFSG).

EN 301 549 (WCAG 2.1 AA aligned)Private-sector products and services placed on the German market

Erklärung zur Barrierefreiheit

Public bodies must publish this statement under § 12b BGG and BITV 2.0 (BFSG service providers publish Annex 3 information instead). Two of its required elements:

Self-Assessed Conformance Status

A declared statement of how well the site or app conforms to EN 301 549 / WCAG 2.1 AA.

Schlichtungsstelle

The conciliation body under § 16 BGG, based at the Federal Government Commissioner for Persons with Disabilities, which the statement must link to as the route for unresolved complaints.

Germany Compliance Checklist

A practical action list for both German public sector bodies (BITV 2.0) and private-sector organisations in scope of the BFSG.

Publish an "Erklärung zur Barrierefreiheit" (accessibility statement)

Critical

State a self-assessed conformance status in that statement

Critical

Link to the Schlichtungsstelle under § 16 BGG (the conciliation body) as the complaints pathway

Critical

Provide a working feedback mechanism for reporting accessibility barriers

High

Audit web content against EN 301 549 / WCAG 2.1 AA

High

Document a remediation roadmap for any unresolved WCAG failures

Medium

Who Is Covered?

Public Sector: BITV 2.0

Federal public bodies (each German state has its own equivalent law). Issued by the Federal Ministry of Labour and Social Affairs.

Private Sector: BFSG

Products and services placed on the German market, since the BFSG transposes the EU-wide Accessibility Act into German federal law.

Frequently Asked Questions

Legal Disclaimer: This guide is for educational purposes only and does not constitute legal advice. Consult a qualified lawyer (Rechtsanwalt) for compliance advice specific to your organisation.

Check Your Site Against EN 301 549 / WCAG 2.1 AA

Scan your site against the standard both BITV 2.0 and BFSG reference, and generate a Germany Edition VPAT.

Run Free Germany Accessibility Scan View EAA Guide