Who is required to publish an accessibility statement?

All companies that fall within the scope of the Barrierefreiheitsstärkungsgesetz have been required to publish an accessibility statement since 28 June 2025. The BFSG applies to private sector companies with more than ten employees or annual turnover exceeding two million euros, provided they offer digital products or services falling within the substantive scope. Micro-enterprises (fewer than ten employees and less than two million euros in turnover) are exempt. More on BFSG requirements.

Can I use a template for the accessibility statement?

Templates exist and can serve as a structural starting point, but they must be populated with your website's actual conformance status. A generated standard statement with no reference to a genuine review is legally worthless. If you need to demonstrate in an enforcement procedure how you determined the conformance status, an unsupported self-assessment will not be accepted. We prepare your individual statement on the basis of a documented WCAG 2.2 audit.

How often must the statement be updated?

The statement must be updated whenever the conformance status changes — for example after remediation of known barriers, after adding new areas or features and after a website relaunch. Even without material changes we recommend an annual review to ensure all information remains accurate. At minimum the date of the last review must appear in the statement.

What happens if we do not publish an accessibility statement?

The absence of an accessibility statement may be treated as a violation of the BFSG. Market surveillance authorities can verify whether a statement is in place upon receiving a complaint and, if absent, initiate appropriate measures. The fine for violations of the BFSG can be up to 100,000 euros (Source: BFSG §31). Beyond the legal risk, a missing statement also raises a reputational issue when users with disabilities encounter barriers and find no feedback channel.

How long does preparing the accessibility statement take?

The statement itself can be drafted within a few hours once the audit data are available. The time-determining factor is the preceding WCAG 2.2 audit: depending on the scope of the website this takes two to five weeks. If you already have a current audit report, we can prepare the statement on that basis. If no audit is available, we begin with the review before drafting the statement.

Does the statement also need to be published in English?

The BFSG requires the accessibility statement to be published in the language in which the digital product is provided. For German-language websites a German statement is sufficient. If your website is also offered in English, we recommend an English version to give English-speaking users access to the feedback mechanism and information about known limitations. We prepare a fully consistent English version on request.

Accessibility Statement under BFSG §14: legally sound, complete, up to date

The accessibility statement is a statutory obligation under the Barrierefreiheitsstärkungsgesetz. It documents the actual conformance status of your website, openly states known limitations and provides a binding feedback channel. We create your statement on the basis of a thorough WCAG 2.2 audit and keep it current over time.

Commission statement All services

BFSG §14 compliant WCAG 2.2 AA foundation Feedback mechanism included

conformance levels documentable

§14

BFSG mandatory paragraph

months maximum update interval

50+

statements prepared (project experience)

Since 28 June 2025, companies with more than ten employees or an annual turnover exceeding two million euros have been required to make their digital products and services accessible (Source: Barrierefreiheitsstärkungsgesetz 2021). Those subject to this obligation must additionally publish an accessibility statement pursuant to BFSG §14. This statement is not a blanket clearance but a binding document that honestly records where your website is conformant — and where known barriers remain. We create this statement on the basis of a thorough WCAG 2.2 audit and take care of wording, structure and legal completeness.

What is an accessibility statement and why is it mandatory?

The accessibility statement is a publicly available document that operators of digital products must publish once they fall within the scope of the Barrierefreiheitsstärkungsgesetz. The BFSG transposes European Directive 2019/882 (European Accessibility Act) into German law. For websites, online shops and mobile applications of companies in the private sector, the obligation applies from 28 June 2025 (Source: BFSG 2021, §1 para. 2). Public bodies were already subject to this obligation considerably earlier under EU Directive 2016/2102.

The statement must contain, pursuant to BFSG §14, at least the following: the current conformance status (fully conformant, partially conformant or non-conformant), a list of content or areas not accessibly available, the reasons for these limitations together with a timeline for remediation, and a feedback mechanism through which users can report accessibility problems. The enforcement procedure must also be described: users must be informed of the authority to which they can turn if the operator does not respond to a complaint. The absence of a statement, or a statement that is incomplete in substance, may be treated as a violation of the BFSG and result in fines.

Caution: placeholder statements are not sufficient

Many websites publish generated boilerplate texts with no reference to the actual conformance status. Such a statement is legally worthless and can, in the event of a complaint, achieve the opposite effect. Only a statement based on a genuine audit that documents the actual state satisfies the requirements of the BFSG and protects against enforcement action.

The three conformance levels in detail

The BFSG distinguishes three possible conformance levels to be stated in the accessibility statement. The choice of level is not a matter of optics but must reflect the actual audit findings. An incorrect classification constitutes a misleading statement.

Fully conformant

All 78 WCAG 2.2 AA success criteria are met. No known barriers. This level requires a complete, documented audit and regular re-testing, since new content or features may affect conformance. Only few websites reach this status without prior accessible development.

Partially conformant

The majority of requirements are met; individual barriers remain. This level is realistic for most websites after an initial remediation cycle. Known limitations must be precisely named, justified and accompanied by a concrete remediation timeline.

Non-conformant

Substantial parts of the website are not accessibly available. This level does not automatically entail legal consequences if a credible action plan with realistic timelines is presented simultaneously. It does, however, require that the statement honestly and completely documents the existing deficiencies.

Our process for creating your accessibility statement

Schritt 1

WCAG 2.2 audit as the foundation

A reliable accessibility statement presupposes a complete audit. We conduct a WCAG 2.2 AA audit that systematically tests all 78 success criteria — automatically with axe-core and Lighthouse, manually by experienced auditors and using assistive technologies such as NVDA, JAWS and VoiceOver. The result is a comprehensive audit report that serves as the data foundation for the statement.

What a complete statement must contain

The statutory minimum requirements for an accessibility statement are clearly defined. In practice, however, we frequently encounter statements that omit important mandatory elements or whose content does not match the actual conformance status. The following overview shows what a complete statement under BFSG §14 must contain.

Conformance status: fully conformant, partially conformant or non-conformant — with date of last review
Known limitations: precise identification of all areas or content not accessibly available
Justification of limitations: why does the barrier exist? Technical, legal or financial reasons are permissible
Remediation plan: concrete dates or timeframes by which each limitation will be remediated
Feedback mechanism: functioning contact channel with reference to the response period (20 working days)
Enforcement procedure: identification of the competent market surveillance authority with complete contact details
Update date: date of the most recent revision of the statement
Assessment method: indication of whether the statement is based on self-assessment or an external audit

Demarcation: what the statement does not replace

An accessibility statement is a statutorily required transparency document — it is not a substitute for actually achieving accessibility. Many operators hope to use a statement to circumvent the substantive requirements: a website reported exclusively as "non-conformant" without a credible action plan will not be rated as compliant by market surveillance authorities. The statement documents the path to accessibility — it is not a goal in itself.

Equally important: the statement applies only to the digital offerings it expressly covers. Operators of multiple websites, online shops, mobile apps or software products may require either a joint or separate statements for each product, depending on the configuration. We advise you on maintaining oversight and closing legal gaps — even where your portfolio includes multiple online shops or corporate websites.

Self-assessment versus external audit

The BFSG permits both self-assessment and an external audit as the basis for the statement. In both cases the statement must indicate the basis on which the conformance status was determined. An external review by an independent expert is more robust and reduces the risk of inadvertently concealing known deficiencies. Particularly for companies that genuinely want to be BFSG-compliant, a professional audit is the safer foundation.

Accounting for specific content types in the statement

The BFSG and WCAG recognize legitimate exceptions: content provided exclusively for internal purposes, certain time-critical archival content predating a cut-off date, third-party map content and live broadcasts without the possibility of subtitling may under certain circumstances be named as justified exceptions in the statement. These exceptions must, however, be explicitly justified and time-limited insofar as this is technically feasible.

A frequently overlooked area is PDF documents and other file formats: downloadable PDFs, forms, technical documentation or price lists must also be accessible if provided via the website. Exceptions apply only to documents published exclusively before 28 June 2025 that have remained unchanged since then. Operators who regularly publish new documents must also ensure their accessibility and document it in the statement.

Setting up a legally compliant feedback mechanism

The feedback mechanism is one of the most frequently neglected components of the accessibility statement. The BFSG requires a low-threshold channel through which users can report accessibility problems. This channel must itself be accessibly available — a feedback form that screen reader users cannot operate does not serve its purpose. When preparing your statement, we test the accessibility of the feedback channel and remediate any barriers found.

Dedicated email address

A dedicated email address for accessibility feedback (e.g. accessibility@your-domain.com) signals seriousness and facilitates internal handling. The address must be correctly linked in the statement and marked up as a mailto link so screen readers identify it as an email link.

Accessible contact form

A dedicated accessibility contact form can enable more structured feedback. The form itself must be fully WCAG 2.2 AA conformant: correct labels, comprehensible error messages, keyboard navigation and screen reader compatibility. We test and optimize your existing feedback channel.

Observe response deadline

Operators must respond to feedback submitted via the feedback mechanism within 20 working days. This deadline applies both to acknowledging receipt and to providing a substantive response. We recommend establishing a clear internal process for handling incoming accessibility requests.

Keeping the statement current over time

An accessibility statement is not a one-time document but must reflect the current state of your website. When new features are introduced, existing barriers remediated or new content published, the conformance status changes. We recommend incorporating the statement into the following events: full update with every WCAG audit and after major website revisions, updating remediation dates as known barriers are resolved, adding new known limitations when newly identified accessibility issues emerge in parts of the website. The maximum interval between revisions is twelve months.

Our BFSG monitoring can help continuously track your conformance status. Automated scans detect new technical barriers in changed or new content; regular manual spot-checks uncover context-dependent issues. This monitoring forms the basis for keeping the statement current with minimal effort and being able to present robust data at any time during a regulatory review. We also recommend our complementary services: screen reader testing and easy language can be part of a comprehensive accessibility concept.