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Accessibility for Public Procurement: Auditing and Implementing BITV 2.0 and EN 301 549

Public bodies are obligated under BITV 2.0 and the state regulations to digital accessibility at level AA — including an accessibility statement, feedback mechanism and enforcement procedure. In procurement under the GWB, accessibility criteria belong in the technical specification. For contracting authorities and bidders, we assess against Table A.1 of EN 301 549, remediate the barriers and support ongoing compliance.

BITV 2.0 & EN 301 549 AA BITV assessment from €2,980 net Own accessibility statement published

In short and in plain language

This page is for public bodies. Firms that bid for public contracts also find help here.

Public bodies must make their websites accessible. Accessible means that all people can use the site. This includes people with disabilities.

They also need an accessibility statement. And a way for people to report barriers. In a tender, these needs belong in the job text.

We test sites and forms against the BITV. These are rules for public bodies. They go further than the WCAG. The WCAG are rules for accessible websites. We also test PDFs. We fix the problems, write the statement and check again later.

Do you have questions? Write to us or give us a call.

Key figures

Table A.1

of EN 301 549 V3.2.1 as the benchmark

§ 121 GWB

Accessibility in the technical specification

EN 301 549

conformance level AA

PDF/UA

Documents per ISO 14289

BITV assessment per EN 301 549 for public bodies

from €2,980 fixed price net
  • Table A.1 of EN 301 549 V3.2.1, level AA
  • Up to 11 views in the desktop and smartphone layout
  • Report with the result per test step and view, plus a findings list
  • Accessibility statement for €390, ongoing monitoring from €49 a month

Fixed price for up to 11 views; each additional view €190, re-test after remediation €590. Prices as of October 2026, all prices net plus VAT. For websites for which no evidence under BITV is required, there is the WCAG 2.2 AA audit from €2,480 (up to 30 pages); it covers the WCAG criteria, i.e. chapter 9 of EN 301 549. Larger portals and specialist procedures are calculated by the number of views — the binding fixed quote follows a short review. We assess our own website against WCAG 2.2 AA ourselves; status and known limitations are set out in our accessibility statement.

Public bodies face particular scrutiny regarding digital accessibility. While the BFSG primarily addresses the private sector, authorities, municipalities and public institutions must meet the stricter requirements of EU Directive 2016/2102, implemented in Germany through BITV 2.0 (Accessible Information Technology Regulation). This requires conformance with EN 301 549 at level AA, a regularly updated accessibility statement and a functioning feedback mechanism. In procurement under the GWB, Section 121(2) GWB applies as well: anyone procuring services intended for use by natural persons takes into account, in the technical specification, the accessibility criteria for people with disabilities or design for all users, except in duly justified cases. We support contracting authorities and bidders with the BITV assessment against Table A.1 of EN 301 549 and with implementation — with transparent fixed prices from €2,980 net for the assessment as a basis for budget planning and bid calculation.

BITV 2.0 duties over time

Public bodies · deadlines
BITV 2.0 duties over time
EU Directive 2016/2102 · assessed against EN 301 549, Table A.1
23 Sep 2019
New websites
Sites published on or after 23 Sep 2018 must meet level AA
23 Sep 2020
All websites
Existing sites must meet EN 301 549 as well
23 Jun 2021
Mobile applications
Public-body apps brought under the accessibility duty
ongoing · yearly
Statement and feedback
Accessibility statement, feedback mechanism and annual update
BenchmarkTable A.1V3.2.1
ConformanceEN 301 549level AA
Statement from€390net
BITV assessment fixed pricefrom €2,980
ProcurementSection 121(2) GWB
Deadlines of EU Directive 2016/2102 for public bodies, audit benchmark and fixed-price anchors at a glance. Example view.

BITV 2.0 vs. BFSG: What Applies to Public Bodies

BITV 2.0 and the BFSG pursue the same goal but implement different legal frameworks. BITV 2.0 is based on EU Directive 2016/2102 on the accessibility of websites and mobile applications of public sector bodies. It applies to federal authorities, and the German states have issued corresponding state regulations that also obligate municipalities, districts and public institutions. The technical reference standard is EN 301 549: the version V3.2.1 cited in the Official Journal of the EU substantively builds on WCAG 2.1 AA, the version V4.1.1 published in September 2026 on WCAG 2.2 (as of October 2026).

Compared to the BFSG, BITV 2.0 has additional requirements: a publicly accessible accessibility statement, a feedback mechanism through which users can report barriers, and an enforcement procedure, at federal level via the conciliation body under Section 16 BGG. The statement must clearly name the conformance status (fully conformant, partially conformant or not conformant), list known limitations and inform the user about their rights in the enforcement procedure. We create this statement based on our BITV assessment and update it regularly.

BITV 2.0 demands more than the BFSG

The additional duties of public bodies

EU Directive 2016/2102 and its implementation in BITV 2.0 require authorities, municipalities and public institutions to provide components not foreseen in the private-sector BFSG. These components must be published and permanently maintained.

  • Published accessibility statement with conformance status
  • Functioning feedback mechanism for barrier reports
  • Reference to the enforcement and conciliation procedure
  • At least annual update against EN 301 549
Additional BITV 2.0 dutiesbeyond the BFSG
Published accessibility statement with conformance status
Working feedback mechanism for barrier reports
Reference to the enforcement and conciliation procedure
At least annual update per EN 301 549

Typical Challenges in the Public Sector

PDF Documents and Forms

Statutes, notices, application forms and announcements as PDF must be tagged and structured (PDF/UA). Many older documents exist as scanned images and are completely inaccessible to screen readers.

Complex Portal Structures

Citizen portals with hundreds of pages, deep menu structures, embedded specialist applications and form systems. Accessibility must be ensured across all levels, not just the homepage.

Interactive Maps and Geodata

City maps, development plans and GIS applications pose special challenges. Map content must be available as text alternatives, markers must be reachable by keyboard and zoom functions must be accessible.

Council Meetings and Livestreams

Video broadcasts of council meetings and public events must be captioned. For recordings, a searchable transcript is also useful.

Online Appointment Booking

Citizens' office appointment scheduling via online portals must be accessible: calendar widgets with keyboard operation, time slot selection with correct ARIA markup, confirmation page with clear summary.

Authentication and E-Government

Login procedures with eID, identity cards or service accounts must be accessible to all citizens. CAPTCHAs, two-factor authentication and identification processes must not present insurmountable barriers.

PDF Accessibility: A Typical Legacy Issue in the Public Sector

PDF documents are ubiquitous in the public sector: statutes, regulations, forms, notices, budgets and minutes. Many of these documents are not accessible. Scanned documents without text recognition are completely inaccessible to screen readers. PDFs exported from word processors or layout programs frequently lack correct tag structure, so screen readers cannot interpret reading order, headings and tables. Our PDF remediation starts from €4.90 per page plus a minimum fee of €149 per document.

We support the creation of accessible PDF/UA documents: correct tag structure for headings, paragraphs, lists and tables, alt texts for embedded graphics, a reading order following the logical document flow, and bookmarks for navigation in longer documents. For forms, we create accessible PDF form fields with labels and tab order. And for ongoing document production, we train your staff in creating accessible office documents that export correctly to PDF.

From scanned PDF to structured PDF/UA

We make your documents machine-readable

Statutes, notices and forms reach screen readers only with correct tag structure. We remediate existing documents by priority and train your editorial team for ongoing production.

  • Tag structure for headings, lists and tables
  • Logical reading order and bookmarks
  • Alt texts for embedded graphics
  • Accessible form fields with labels and tab order
Scanned PDFno UA
Pixel image without text layer
No tag tree, no reading order
Alt texts completely missing
Form fields without labels
Screen reader outputno text
UA
PDF/UA · ISO 14289accessible
Tagged headings H1 to H3
Logical reading order and bookmarks
Alt texts for coats of arms and graphics
Form fields with label and tab order
Screen reader outputin reading order

Public bodies must publish an accessibility statement that goes beyond a standard disclaimer. The statement must specify the conformance status (fully conformant, partially conformant or not conformant), based on testing against EN 301 549. It must name known limitations and explain why they cannot be resolved. It must provide a feedback mechanism through which users can report barriers. And it must reference the enforcement procedure, at federal level the conciliation procedure under Section 16 BGG. We create the statement as a fixed price of €390 net.

We create the accessibility statement based on the assessment results and align it with the mandatory content under Section 7 BITV 2.0 or the applicable state law. The statement is updated annually and after every significant change to the website. The feedback mechanism is implemented as an accessible contact form that routes reports to the responsible unit in your organization.

Digital touchpoints between authority and citizen

Citizen portal and specialist procedures

We audit deep menu structures and embedded applications across all levels, not just on the homepage.

Forms and notices

Application forms, notices and announcements are audited against PDF/UA and WCAG for form elements, error messages and help texts.

Login and e-government

We audit authentication with eID and service accounts for insurmountable CAPTCHA or two-factor barriers.

Our Approach in Procurement Projects

We align our proposal with the technical specification in the respective tender documents. Together, we define the audit scope: main pages, forms, PDF documents, embedded applications and mobile views. The fixed-price range is set before the project begins.

Cost Framework for Procurement Projects

Transparent fixed-price anchors for budget planning and bid calculation. Larger portals, specialist procedures and document inventories are calculated after review — you receive the binding fixed quote before the project starts. All prices net.

BITV Assessment

For public bodies: assessment against Table A.1 of EN 301 549 V3.2.1, level AA, up to 11 views in the desktop and smartphone layout.

from €2,980 one-time net
  • WCAG criteria from chapter 9 and requirements beyond them
  • Keyboard and screen reader output
  • Result per test step and view against Table A.1
  • Prioritized findings by severity
  • Additional view €190, re-test €590
Request BITV Assessment
Complete package

Audit + Remediation

Audit, barrier remediation and accessibility statement from a single source.

from €4,900 one-time net
  • WCAG 2.2 AA audit before remediation
  • Fixing technical barriers in the CMS code
  • PDF remediation per PDF/UA from €4.90 per page
  • Accessibility statement (€390 net) included; a status under BITV 2.0 additionally requires the BITV assessment
  • Editorial training for accessible content
Request Complete Package

BITV Maintenance

So that conformance stays in view after the project.

from €49 per month net
  • Quarterly spot checks of new content
  • Annual re-audit on request, commissioned separately
  • Measurement data as the basis for the statement (updates €149 each)
  • Support with feedback and enforcement procedures
  • Easy-to-read translation as add-on from €119 per standard page
Request Maintenance

All prices net plus VAT; prices for the BITV assessment as of October 2026. The complete package includes the WCAG 2.2 AA audit, which covers the WCAG criteria, i.e. chapter 9 of EN 301 549. For websites for which no evidence under BITV is required, the WCAG 2.2 AA audit is also available on its own from €2,480 (up to 30 pages). For larger portals and specialist procedures we prepare a fixed quote after a short review. Details on the assessment on the BITV assessment page, on all services on the services page.

Accessibility in Public Tenders

Public institutions are subject to EU Directive 2016/2102, whose deadlines have applied in stages since 2019, and, at federal level, to BITV 2.0 as revised to implement it, which goes beyond the private-sector BFSG standard. Requirements encompass not only EN 301 549 but also explanations in easy-to-read language and German Sign Language on the homepage and a published accessibility statement with feedback mechanism. In procurement under the GWB, Section 121(2) GWB requires the technical specification to take into account the accessibility criteria for people with disabilities or design for all users when the service is intended for use by natural persons. For contracting authorities, this means formulating testable requirements, for example with reference to EN 301 549. For bidders, it means the website or application offered must meet these requirements, with evidence in the bid depending on the tender documents. We support both sides with the BITV assessment against Table A.1 of EN 301 549 and a report with the result per test step and view.

Particularly complex are the requirements for PDF documents and forms in the public sector. Forms for applications, notices and citizen communication must be just as accessible as the website itself. We audit and optimize not only the web presence but also embedded PDF documents according to the PDF/UA standard and web-based forms according to WCAG requirements for form elements, error messages and help texts. This holistic approach aims to make all digital touchpoints between authority and citizens accessible.

Sustainable Accessibility Through Process Integration

One-time audits and remediations are not sufficient to permanently secure a public website's accessibility. New content, updated forms and design changes can introduce new barriers at any time. Therefore, we integrate accessibility into your institution's editorial processes: we train your editors in creating accessible content, create guidelines for correct use of heading structures, alt texts and link texts, and set up automated checks that test new content for basic accessibility criteria before publication. Complemented by regular manual re-audits, this creates a system that helps keep conformance in place over time. We offer this ongoing support from €49 net per month.

Economic Benefits of Accessible Public Web Presences

Accessibility in the public sector is not only a legal obligation but improves service quality for all citizens. Clearly structured web presences with semantic HTML, understandable navigation and accessible forms can reduce inquiries to citizen hotlines and service desks when citizens find and use the information and services they need online on their own. Just over 7.8 million people in Germany were living with a severe disability at the end of 2025 (Federal Statistical Office), many of whom depend on accessible digital administration.

For public institutions, we additionally offer creation and maintenance of the accessibility statement per BITV 2.0, setup of the required feedback mechanism for users and support with inquiries from monitoring authorities.

We additionally support public institutions in evaluating accessible CMS solutions and technical platforms. The choice of content management system directly impacts long-term accessibility: systems with strong semantic base structure and integrated accessibility features reduce maintenance effort and minimize the risk of new content introducing barriers.

Accessibility for your procurement project

Procurement, standards and documents

For contracting authorities and suppliers, the article on accessibility in public procurement is the most practical entry point: it shows how EN 301 549 can be formulated as an award criterion and evidenced. The chain of standards behind it is explained in the article on the EU standard EN 301 549. Because public bodies circulate especially many documents, the article on accessible PDFs complements the PDF accessibility service page; comprehensible content is additionally created through easy-to-read language, and the sector classification is available under accessibility by industry.

Key Points for Public Procurement

  • BITV 2.0 demands more than the BFSG: accessibility statement with status declaration, feedback mechanism, enforcement procedure and annual update
  • In procurement under the GWB, accessibility criteria belong in the technical specification (Section 121(2) GWB) — we assess against Table A.1 of EN 301 549
  • BITV assessment as a fixed price from €2,980 net (up to 11 views in the desktop and smartphone layout); for websites without a BITV requirement the WCAG 2.2 AA audit from €2,480 net (up to 30 pages), complete package of audit and remediation from €4,900 net
  • PDF notices, statutes and forms are tagged per PDF/UA (ISO 14289) — from €4.90 per page plus a minimum fee of €149 per document
  • Ongoing BITV maintenance from €49 net per month helps keep conformance in place after changes

Frequently Asked Questions on BITV 2.0 and Public Procurement

How the website of a rehabilitation clinic could look

The draft shows structure and handling: departments to switch through, the path from medical report to arrival, a weekly plan and stated details on step-free access. The clinic in it is invented.

Draft
Rehabilitation clinic

Rehab clinic with application path and verifiable details

A draft for a rehabilitation clinic: three departments can be switched through, and the path from the medical report through the application to the funding body up to the arrival day is set out in four steps. A week in the house is shown as a daily plan, alongside rooms, visiting hours and support for relatives. The accessibility section states door widths, lift dimensions and call systems instead of a blanket assurance.

DepartmentsApplication pathWeekly planVerifiable measurements

Illustrative layout drafts. The businesses shown are fictitious; these are not client projects.

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