In the German public sector, accessibility for websites and applications has been a legal requirement since 2018. However, it is not always entirely clear what the requirements mean in practice. There is room for interpretation. The Accessibility Working Group of DATABUND e.V., in which mgm is also involved, has now published a handout on the accessibility statement. It summarizes the legal requirements and provides recommendations for practical implementation.
Every software project in the public sector must meet legal requirements for accessibility. The basis for this is the EU Directive 2016/2102, which has been implemented in Germany primarily through the “Behindertengleichstellungsgesetz” (BGG) and the “Barrierefreie-Informationstechnik-Verordnung” (BITV) 2.0. But what exactly does “accessible” mean? Who evaluates accessibility? And what evidence do you need to provide?
These questions repeatedly cause uncertainties in project practice. The accessibility working group of DATABUND e.V., the association of medium-sized IT service providers and software manufacturers for the public sector, has devoted itself to the topic and has developed a handout: “Erläuterung der rechtlichen Anforderungen an die Erklärung zur Barrierefreiheit einschließlich der zugrundeliegenden Bewertung” (-> Download). The document analyzes the legal situation and deduces what a legally secure assessment looks like and how it can be documented. mgm has been a DATABUND member since April 2021.
Self-assessments are also possible
„In the context of software development projects for public administration, the question often arises as to whether accessibility must be confirmed by a certificate. This is not the case“, explains Anna Weißenborn, accessibility expert at mgm, who was involved in creating the handout. „For example, a self-assessment is also possible and makes sense in many cases. The results must be included in the accessibility statement.“
In addition to summarizing the legal situation, the handout provides information on how the accessibility of websites and mobile applications can be assessed. The starting point for this are the standards EN 301 549 and WCAG 2.1. “With the existing catalogs of criteria, it is possible to check the accessibility of a web application very comprehensively. However, not every evaluation step produces a clear result.”, says Anna Weißenborn. “Accessibility is never clearly just ‘fulfilled’ or ‘not fulfilled’ – even according to the formal specifications. There is room for interpretation. That is why we also point out in the handout that everyone involved should come together and find a common ground.”
Accessibility Statement Templates for A12 Projects
The issue of accessibility plays an important role for mgm. Ongoing software projects in the public sector such as Modul-F and Förderfinder have long had to comply with legal requirements. But stricter requirements will soon also apply to business applications in other industries, which are typically very long-lived. From June 28, 2025, new rules for accessible products and services will become mandatory within the EU. The background to this is the European Accessibility Act (EAA), which took effect in June 2019. Almost all companies in the free economy who offer e-commerce services will be affected.
In order to make new applications based on the Enterprise Low Code Platform A12 accessible right from the start, mgm provides all partners with a guide for accessibility in the documentation platform of GetA12. It also contains information and templates for the legally binding accessibility statement.