For public bodies, the BGG, the BITV 2.0, and, technically, EN 301 549 apply — not the Accessibility Strengthening Act (BFSG). The first and most common misconception concerns precisely this legal basis. The BFSG has applied since June 28, 2025, and because much has been written about it, it is also cited in public authorities. However, it is linked to economic operators and to products and services in consumer transactions and is not the basis for the accessibility of websites and applications of public bodies. A different, older chain applies to public administration.
It starts with Directive (EU) 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies. It requires an accessibility statement, a feedback and enforcement procedure, and regular monitoring with reporting to the European Commission. In Germany, it has been implemented in the BGG and in the BITV 2.0.
Two provisions of the BGG are decisive for day-to-day work. Section 12a BGG requires websites and mobile applications to be designed to be accessible — expressly including the services intended for employees, i.e., the intranet — and accessibility to be taken into account as early as planning, development, tendering, and procurement. Section 12b BGG requires the accessibility statement, together with an easy-to-find contact option through which barriers can be reported, and a response within one month.
The BITV 2.0 fills this out technically: Section 2 determines the scope, Section 2a expressly extends it, via the definitions, to intranet and extranet services and to non-web-based graphical user interfaces — electronically supported administrative processes are already named in Section 12a BGG itself; Section 3 names the standards to be applied, with the four basic principles perceivable, operable, understandable, and robust; Section 4 governs the provision of information in German Sign Language and in Easy Language; Section 7 describes the content, format, and update cycle of the accessibility statement; Sections 8 and 9 govern monitoring and reporting.
Technically authoritative for federal public bodies is EN 301 549 in version V3.2.1 from March 2021, harmonized by Implementing Decision (EU) 2021/1339. A newer harmonized version was not apparent as of the editorial date. For the states and municipalities, the respective state equal opportunities acts and state ordinances apply; each federal state maintains its own monitoring body.
At federal level, the checks are carried out by the Federal Monitoring Body for the Accessibility of Information Technology. It tests websites and applications technically and editorially, advises, publishes guidelines, and prepares the reports to the European Commission; the second German monitoring report for the period 2022 to 2024 was submitted to the Commission in March 2025, and the short version was published in October 2025.
The route for affected persons is tiered. First, the report goes through the feedback mechanism of the body concerned. If there is no response, affected persons can turn to the enforcement bodies of the federal government and the states. Under Section 16 BGG, there is also a conciliation procedure with the Federal Government Commissioner, which is free of charge for the parties involved. Recognized associations can bring an action under Section 15 BGG for a declaration that a violation has occurred — before an action against a public body, however, the conciliation procedure must be completed.
What is missing from this set of instruments is remarkable: a fine provision. The wording of the BGG and BITV 2.0 contains no fine provision for public bodies; this is a research finding as of the editorial date of August 6, 2026, and not an officially confirmed interpretation. It would be the key difference from the BFSG, which provides for sanctions for economic operators. Anyone in public administration who relies on fine risks as an argument is therefore probably missing the point — enforcement takes place via feedback, conciliation, action by associations, and the public report.
Not expressly. The BGG and BITV 2.0 contain no training or continuing professional development requirement, and the Bundesfachstelle Barrierefreiheit also presents its offerings as voluntary.
The need nevertheless arises, just elsewhere: from the implementation obligation itself. Section 12a BGG requires accessibility to be taken into account in planning, development, tendering, and procurement, and in doing so expressly also covers the intranet and electronically supported administrative processes. Anyone who creates documents, posts forms, maintains content editorially, or procures services cannot fulfill this obligation without specialist knowledge. The European level is more explicit: Article 7 (4) of Directive (EU) 2016/2102 obliges the member states to promote and facilitate training programs on the accessibility of websites and mobile applications for relevant stakeholders and for the staff of public bodies — expressly with a view to creating, managing, and updating content. Under international law, this is flanked by Article 9 (2) lit. c of the UN Convention on the Rights of Persons with Disabilities, according to which the states parties provide training for all stakeholders on accessibility issues — this is an obligation of the states, not an individually enforceable right to training.
For practice, this means: the question is not whether training is prescribed, but how else the body intends to prove that it is fulfilling its implementation obligation. How such proof must be structured is described in Proving mandatory training.
For the most part, accessibility is not created in the IT project but in day-to-day casework. The Bundesfachstelle Barrierefreiheit expressly points out that accessibility is most effective when it is taken into account right from the creation stage instead of being established afterwards.
Chapter 10 of EN 301 549 is authoritative. The practical requirements: work with style templates instead of manual formatting so that a logical heading structure is created; provide alternative texts for images that carry information; mark up tables as tables and do not recreate them with tabs; specify the document language; comply with the PDF/UA standard for publications. A document that is only run through testing software at the end can, as a rule, no longer be repaired in a meaningful way.
The Bundesfachstelle names concrete points for this: verbalize visual content, send presentations in an accessible format in advance, offer sign language interpretation and live captions, choose screen-reader-compatible tools, name a technical contact person before and during the event, keep chat and alternative contact channels open, and provide software instructions in advance, also in Easy Language.
Section 11 BGG is worded as a should provision: public authorities should communicate with people with intellectual or mental disabilities in simple and understandable language, and on request they should explain administrative decisions, general administrative orders, public-law contracts, and forms in Easy Language if an explanation in simple language is not sufficient. The only mandatory element is that the public authority bears the costs for this. Section 4 BITV 2.0 additionally requires information in German Sign Language and in Easy Language on the home page.
It is not a one-off document. Under Section 7 BITV 2.0, it must be provided in an accessible and machine-readable format, be reachable from every page, be updated annually, and be revised after significant changes; it must disclose which content is not accessible, why, and which alternatives exist. This includes a directly accessible feedback mechanism. In practice, this rarely fails because of technology and often because of responsibilities: a named person is needed who receives reports and meets the one-month deadline of Section 12b BGG.
Training for everyone to the same extent rarely hits the mark. It makes more sense to divide it according to what the respective role actually decides.
This division is an organizational recommendation and not a statutory requirement — the BGG and BITV 2.0 say nothing about it. It merely follows the logic of Section 12a BGG, which requires accessibility at the points where decisions are made.
Two things help more than an annual event. First, the connection to existing procedures: anyone who introduces the e-file or provides online services decides on accessibility there — the basics are covered in What is the e-file? and What is the OZG?. Second, short, recurring formats instead of a one-off block, because the relevant steps are role-specific and must be practiced in the flow of work; the possibilities and limits of such units are assessed in Microlearning. The same logic applies to other cross-cutting topics in public administration, such as Security awareness in public authorities.
In terms of scale: the Federal Statistical Office reported around 7.8 million people with an officially recognized severe disability at the end of 2025, which corresponds to 9.4 percent of the population; 79 percent of them were 55 years of age or older. Accessibility is therefore not a marginal requirement but a question of access for a considerable proportion of those who use administrative services.
Two procedures are open as of the editorial date and should be checked before planning training. An Act amending the BGG was adopted by the cabinet on February 11, 2026, debated in first reading in the Bundestag on May 7, 2026, and, after the public hearing of June 22, 2026, was still under committee deliberation. This draft directly affects the obligations described here: among other things, it intervenes in Sections 8, 11, 12a, and 12b BGG and provides for a separate provision on Easy Language and German Sign Language. Anyone defining training content now should check the status of the procedure before every update.
Two further developments should be monitored but do not have a direct effect on public bodies. For the BFSG, an amendment to the associated ordinance was promulgated on July 15, 2026; its regulatory content could not be evaluated from the official text. And at European level, there is a draft of EN 301 549 in version V4.1.0, which is aligned with WCAG 2.2. Until it is cited in the Official Journal, version V3.2.1 remains authoritative.
It is not the basis for websites and mobile applications of public bodies; it is linked to economic operators, so that legal persons under public law may nevertheless be covered in individual cases as providers of certain services. For the set of obligations described here, the BGG together with the BITV 2.0 applies at federal level, and for the states and municipalities, the respective state equal opportunities acts with their ordinances. The two regulatory regimes run in parallel and should not be mixed up.
For federal public bodies, version V3.2.1 from March 2021 is authoritative, harmonized by Implementing Decision (EU) 2021/1339. A newer harmonized version was not apparent as of the editorial date of this article. What is always authoritative is the version published in the Official Journal of the European Union, not the latest technical version of the standard in each case.
The wording of the BGG and BITV 2.0 contains no fine provision for public bodies; an official confirmation of this reading is not available as of the editorial date. Enforcement takes place in stages via the feedback mechanism of the body concerned, the enforcement bodies of the federal government and the states, the free conciliation procedure under Section 16 BGG, and the action by associations under Section 15 BGG, which must be preceded by conciliation.
Yes. Section 12a BGG expressly also covers services intended for employees, i.e., in particular the intranet, and in addition names electronically supported administrative processes. The BITV 2.0 additionally extends its scope to intranet and extranet services and to non-web-based graphical user interfaces. Accessibility is therefore also a question of workplace equipment.
Under Section 7 BITV 2.0, annually and additionally after every significant change to the service. It must be provided in an accessible and machine-readable form, be reachable from every page or from the app navigation, and disclose which content is not accessible, why that is the case, and which alternatives exist.
The BGG and BITV 2.0 contain no express training obligation. The need arises indirectly from Section 12a BGG, which requires accessibility as early as the planning, development, tendering, and procurement stages — which cannot be implemented without the corresponding knowledge in casework.
All sources retrieved on 6 Aug 2026 unless otherwise stated in the entry. For provisions on gesetze-im-internet.de, the legal status of 6 Aug 2026 applies; retrieval there was not technically possible.
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