BFSG, BITV and WCAG: what is the difference?

Start by classifying what you offer

A company website, an online shop and a municipal service portal can use similar technology and still be subject to different rules. So start with the operator, the target audience and the service offered. The question “Which standard do we use?” comes afterwards.

Create a short project sheet for this: who offers what, who is it aimed at, in which countries is it provided and which digital steps are part of it? This sheet stops requirements from another project being adopted without checking.

BFSG: specific products and services

The Barrierefreiheitsstärkungsgesetz (Accessibility Strengthening Act) has applied to the offerings it covers since 28 June 2025. These include services in electronic commerce. A purely informational website is not covered simply because it belongs to a company. There is an exemption for services provided by microenterprises; it does not automatically extend to their products.

Microenterprises employ fewer than ten people and have an annual turnover or annual balance sheet total of no more than €2 million. For affiliated companies or mixed offerings, open classification questions should be clarified with expert advice.

BITV: choosing the right public-sector framework

The federal BITV 2.0 is part of the legal framework of the Behindertengleichstellungsgesetz (Disability Equality Act) for federal public bodies. For the federal states (Länder) and municipalities, the relevant state rules are decisive. They may be modelled on the federal rules, but they do not match them on every point.

So don't adopt a federal template for the statement, or requirements on easy read (Leichte Sprache), without checking the relevant state rules. A technical checklist and a legally appropriate publication template are two different deliverables.

WCAG: making technical requirements understandable

The W3C's Web Content Accessibility Guidelines describe success criteria for web content. They distinguish between levels A, AA and AAA. For a conformance claim at level AA, the applicable A and AA criteria must be met; requirements for complete pages and processes apply as well.

The technical guideline is not itself a German law. Which version and which additional requirements apply to your project depends on the relevant legal or contractual framework. A target such as WCAG 2.2 AA should therefore be documented with a specific testing basis.

BFSG information is not a public model statement

Under § 14 BFSG, service providers that are covered must make information available in accordance with Annex 3. Among other things, this describes the service and how it meets the requirements. It must be distinguished from the accessibility statement of public bodies. The description of remaining barriers provided for there cannot be carried over to private BFSG offerings as a general permission for non-conformance.

How to record the decision so others can follow it

1. 1Document the operator, the offering, the consumer relevance and the target markets.
2. 2Check the applicable law and any exemptions for exactly this offering.
3. 3Note the technical standard, version, target level and any additional requirements.
4. 4Plan automated and manual tests of complete user journeys.
5. 5Choose the right form of information or statement and assign expert sign-off and updates.