Accessibility Statement under BFSG §14: legally sound, complete, up to date
The accessibility statement is a statutory obligation under the Barrierefreiheitsstärkungsgesetz. We prepare it at a fixed price of €390 net on the basis of a genuine WCAG 2.2 audit — with all mandatory disclosures, a feedback mechanism and the enforcement procedure.
Accessibility statement at a fixed price
- Technical short check as assessment basis included
- All eight mandatory disclosures under BFSG §14
- Feedback mechanism and enforcement procedure drafted
If the statement is missing or incomplete in substance, fines of up to €100,000 apply (BFSG §37). This site itself meets WCAG 2.2 AA — our own accessibility is solid evidence of our work.
WCAG 2.2
conformance target level AA
§14
BFSG mandatory paragraph
8
mandatory disclosures per statement
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 prepare it at a fixed price 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
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.
Placeholder text or a legally sound statement?
The difference decides your legal certainty
A statement produced with a generator reads as complete but is vulnerable without an assessment basis: it asserts a conformance status that nobody has evidenced and conceals existing barriers. That is exactly what can be used against you in the event of a complaint. Our statement is based on a documented WCAG 2.2 audit — every stated status is verifiable, and every known limitation is backed by a criterion and a remediation date.
- Conformance status on an audit basis instead of a blanket claim
- Known limitations openly named, with a timeline
- Feedback channel tested for accessibility
Our process for creating your accessibility statement
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.
Classification and prioritization of findings
Based on the audit, we classify all findings by severity, WCAG criterion and remediation effort. This classification determines which barriers are documented under the conformance status in the statement, which can be remediated promptly and which require more in-depth rework. Only with this classification is a precise, substantively correct statement possible.
Formulating the conformance status
We formulate the conformance status based on the audit results: fully conformant, partially conformant or non-conformant. For partially conformant and non-conformant websites, we precisely formulate the known limitations: affected area, WCAG success criterion, impact on users, justification and planned remediation date. These statements must be traceable and plausible.
Integration of the feedback mechanism
The feedback mechanism is a legally mandatory component of the statement. We integrate a functioning channel for accessibility feedback: a dedicated contact form, an email address or a combination of both channels. Importantly, the operator must respond to feedback within 20 working days. We advise on efficiently handling incoming requests.
Description of the enforcement procedure
Users must be informed in the statement of the authority to which they can turn if their concern is not addressed by the operator. In Germany this is the competent market surveillance authority. We ensure the correct authority with complete contact details is named in your statement and the procedure is described clearly.
Publication, linking and ongoing maintenance
The statement must be reachable from every page of the website, typically via a footer link. We advise on technical integration into your CMS — whether WordPress, TYPO3, Shopware Community Edition or a custom system — and create a maintenance plan: the statement must be updated after material changes to the website, and at minimum once annually.
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
Prepare it yourself or have it prepared?
| Aspect | Yourself with a generator | Statement prepared by us |
|---|---|---|
| Assessment basis | No audit, just a text block | Complete WCAG 2.2 audit |
| Legal certainty | Vulnerable if challenged | Evidenced conformance status |
| Known limitations | Mostly omitted | Precisely named, with timeline |
| Feedback mechanism | Rarely tested for accessibility | Tested and accessible |
| Updating | Quickly forgotten | Maintenance plan, max. 12-month interval |
| Cost | €0 — until the first complaint | €390 fixed price net |
Clear prices for your accessibility statement
All prices net. The statement is always based on a technical short check — the full scope is discussed in the free initial consultation.
Statement fixed price
The legally sound statement as a standalone service, including the assessment basis.
- Technical short check as assessment basis
- All eight mandatory disclosures under BFSG §14
- Conformance status with evidenced justification
- Feedback mechanism and enforcement procedure
- German version, English version on request
Statement + annual care
Preparation at the fixed price plus an annual update so the information stays current.
- All services of the fixed-price statement
- Annual review and update
- Adjustment after website changes
- Tracking of remediated limitations
- Robust data basis for regulatory reviews
Included in the WCAG audit
When you commission a complete WCAG 2.2 audit, the statement is included.
- Complete WCAG 2.2 AA audit (up to 30 pages)
- Accessibility statement at no extra charge
- Prioritized findings list for implementation
- Foundation for the remediation
- One point of contact for audit and statement
The accessibility statement is already included in our audit and remediation packages. For the BFSG-compliant new build of entire websites, see accessible web development from €4,900 net.
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
A statement on a robust basis — at a fixed price
We prepare your accessibility statement for €390 net on the basis of a genuine WCAG 2.2 audit, with all mandatory disclosures and an accessibility-tested feedback channel.
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.
What may remain open in the statement
Non-conforming content has to be named — what a defensible justification looks like is shown in the article on disproportionate burden under section 17 BFSG. Third-party components are the most common reason for limitations; see the article on third-party widgets and BFSG duties. What an incorrect or missing statement can lead to is set out in the article on BFSG enforcement and legal risks.
The essentials at a glance
- The accessibility statement has been mandatory since 28 June 2025 under BFSG §14 — we prepare it at a fixed price of €390 net
- The foundation is always a genuine WCAG 2.2 audit, not a generated placeholder text
- All eight mandatory disclosures: conformance status, limitations, justification, remediation plan, feedback, enforcement, date, method
- If the statement is missing, fines of up to €100,000 apply (BFSG §37)
- Annual care from €149 per year; with the WCAG audit from €2,480 the statement is included