The BITV explained in simple terms – Barrierefreie-Informationstechnik-Verordnung
The updated Barrierefreie-Informationstechnik-Verordnung (BITV) 2.0 came into force on May 25, 2019. It implements EU Directive 2016/2102, which requires that websites and mobile applications of federal and state public bodies be designed to be accessible.
Moreover, the BITV has been around since 2002. It was revised for the first time in 2011 and renamed to version 2.0. The final changes were made in May 2019. What is new, for example, is that it no longer provides its own standard, but refers to the standards published in the Official Journal of the EU – in short, to the Web Content Accessibility Guidelines (WCAG) 2.0. The BITV 2.0 concerns all IT solutions of the public federal administration, i in other words websites, web applications, mobile apps and even graphical user interfaces.
As an agency for accessible websites we offer you here an overview of:
These are the areas of application and objectives of BITV 2.0
The major goal of the regulation: To ensure the accessibility of all digital services provided by public entities – in line with the UN Convention on the Rights of Persons with Disabilities. The aim is to promote the inclusion of people with learning difficulties, limited proficiency in German, and mental and physical disabilities.
This means: Websites, intranets, mobile apps and administrative procedures must be usable for everyone. Whether it’s electronic file management or other digital services – everything should be accessible. Public entities include public authorities as well as state bodies and other federal/state institutions operating in the public sector, such as museums or libraries.
As of 2019, BITV 2.0 has extended the requirements to include digital applications used internally by government agencies, meaning that the distinction between publicly accessible and non-publicly accessible applications no longer applies. This means that both internet and intranet content as well as mobile apps that are not intended for the public must now also be designed to be accessible.
On the BFSG – Accessibility requirements for certain private companies
What previously only applied to public institutions is now also mandatory for private companies as a result of the Barrierefreiheitsstärkungsgesetz (BFSG): Effective June 28, 2025, certain companies will also be required by law to make their online presence accessible. Germany is thereby implementing the EU Directive of the European Accessibility Act (EAA). These guidelines are also based on the WCAG.
Although the BITV and the BFSG are essentially the same in terms of their objectives, the BITV 2.0 contains 38 additional criteria that are to be found in the BFSG. This means that the requirements for companies are somewhat less demanding than for state institutions.
Our experience is reflected in the successful implementation of numerous customer projects: whether it’s content in easy read on government websites or the implementation of elements such as accessible website navigation. Do not hesitate to contact us if you need assistance with the implementation of an accessible website.
Requirements for an accessible website in accordance with BITV 2.0 and the current level of technology
In accordance with § 3 of BITV 2.0, the IT offerings of public entities must meet the requirements of WCAG conformance level AA (level A included). In summary, this results in four requirements and the following measures:
Requirement | Measures for compliance |
1) Perceivable | – Improve the legibility of text: Use of clear and simple language, good contrasts and font sizes that are easy to read for all users. – Alternative text for images: Use of descriptive text for visual content that is accessible to screen readers. |
2) Operable | – Alternative control functions: Implementation of alternatives to mouse functions for navigation, such as keyboard operation. – Clear navigation structure: Clear headlines and page titles as well as labeling of all functions like pop-up windows or any additional information available. |
3) Understandable | – Use of understandable language: Formulate the information in a clear and understandable way. – Structured content: Structure content logically to facilitate orientation, e.g., with clear headings and paragraphs. |
4) Robust | – Compatibility with assistive technologies: Ensure that digital content is compatible with screen readers and other assistive devices. – Compliance with standards: Use of harmonized norms and standards to ensure technical robustness and stability. |
But that is not everything. If a website fulfills the four requirements mentioned, the BITV 2.0 merely presumes that the website in question is accessible. In order to actually guarantee accessibility, it must meet current technical standards. In Germany, the current technical standard is defined by two so-called DIN-ISO standards:
The DIN EN ISO 9241 provides guidelines for the ergonomic design for interactions between people and systems in order to make usage comfortable, efficient and user-friendly. It covers topics such as user-friendliness, displays, input devices and workplace ergonomics.
The DIN EN ISO 14289 establishes the way in which PDFs must be designed to make them accessible to people with disabilities, e.g., who use screen readers.
Highest possible degree of accessibility, German sign language and easy read
The conformance level AA of the WCAG 2.1 is no longer sufficient for key landing pages such as the homepage, forms and authentication, identification as well as payment processing. In these cases, the BITV requires conformance level AAA (including level A and AA).
The following information must also be provided explicitly on the homepage in German sign language and in easy read:
- The main contents of the website must be made clear
- The navigation of the website must be explained
- The accessibility statement
- Links to other web content in easy read and German sign language, which supplement the topic/also provide information about it
Accessibility statement
Another requirement for public entities under BITV 2.0 is the drafting and publication of an accessibility statement. This must be accessible on the website as well as in the app store.
The following must be ensured when creating and uploading the declaration:
1) Placement of the statement:
- The declaration must be easily accessible from the homepage and every other page of a website. For mobile apps, it must be placed where the app can be downloaded or on the website of the relevant public body.
2) Content requirements:
- Accessibility assessment: The declaration must make it clear whether the website or app meets the accessibility requirements. It must include details of how accessibility was checked, e.g., through an internal assessment or an external review.
- Non-accessible content: Areas lacking accessibility must be listed in the declaration. It should be stated why they are not accessible and, if possible, alternative solutions or formats should be provided.
3) Feedback mechanism:
- A contact mechanism for users should be integrated to enable them to report accessibility issues or ask questions regarding accessibility. This mechanism, as well as the explanation, should be easily accessible on every page of the website.
4) Annual updates:
- The accessibility statement must be updated annually or whenever a significant change is made to the website or app.
5) Mentioning the review:
- The statement must indicate who assessed the accessibility, e.g., whether it is an internal review or an external assessment.
6) Reference to arbitration body
- The statement should contain information on the arbitration body to which users can turn if they are dissatisfied with the accessibility of the website or app.
The detailed content and specifications can be found on the official website for accessibility and service consolidation of the federal government: Accessibility portal
Conclusion
In summary, a website of a public entity must fulfill the four requirements of WCAG conformance level AA (including level A) as per BITV 2.0. In order to ensure the accessibility of the website, the DIN ISO standards 9241 and 14289 must also be adhered to.
The homepage or other main landing pages, authentication, identification and payment processing on the website must be considered separately. Conformance level AAA (including A and AA) is applicable for these. In addition, the core elements of the website must be made accessible in German sign language and easy read.
Would you like to make your website accessible? As an agency for accessible websites, we are happy to assist you. Contact us for non-binding inquiries using the form below. We would be happy to arrange an appointment for a subsequent discussion – whether by telephone, video call or a face-to-face meeting on site.