Does Section 4 BITV 2.0 apply to company websites as well?

As a rule, no. The regulation addresses federal public bodies; its statutory basis in Section 12a BGG speaks expressly of federal public bodies (German Federal Ministry of Justice). Private sector companies are therefore typically not subject to this home page duty. Anyone building a sign language offering voluntarily is still well advised to follow Annex 2, because it spells out concrete production requirements in German regulatory law. State authorities and municipalities follow their respective state regulation, which largely mirrors the federal text.

Is a single welcome video in sign language enough?

Experience says no. Section 4 BITV 2.0 names four explanations: information on the core content, guidance on navigation, an explanation of the core content of the accessibility statement, and pointers to further material available in sign language (German Federal Ministry of Justice). A welcome film usually covers only the first of them. The common approach is a small series of short films that together fill all four items and are reachable through a shared overview page.

Does every subpage have to be translated into German Sign Language?

By the wording, no. The regulation speaks of core content and ties the duty to the home page (German Federal Ministry of Justice). The scope is therefore a selection decision that should be documented: which content counts as essential, and why. Large sites often extend the mandatory films with further high-demand topics such as application routes or opening hours. That extension is voluntary and can be planned in stages.

Does a sign language video replace captions?

As a rule not, because the two serve different needs. WCAG success criterion 1.2.2 requires captions at Level A for prerecorded audio content in synchronised media (W3C); sign language interpretation sits separately in 1.2.6 at Level AAA (W3C). People who lost their hearing later in life often use written language rather than sign language. A film therefore typically carries captions, a transcript and, where the picture holds information of its own, an audio description or full-text alternative.

Are avatars or automatically generated signing animations permitted?

That can only be judged case by case. Annex 2 Part 1 requires that facial expression and mouth pattern are clearly visible and that background, clothing and hands of the performer stand in contrast to one another (German Federal Ministry of Justice). The wording is framed around a performing person. In practice work is therefore predominantly done with interpreters, and an automated solution needs a robust review with deaf test users before it can carry the mandatory part.

How often does a sign language video have to be updated?

The regulation names no interval. In practice the content decides: films describing remits or navigation age with every change to the menu structure. Coupling this to the editorial process has proven itself - whoever touches navigation or the accessibility statement reviews the matching film - plus an annual pass over the whole stock. Ongoing monitoring reports deviations earlier than a periodic audit finds them.

Sign Language on the Web: Embedding DGS Videos Right

A public authority website shows a video on its home page. It features an interpreter against a grey background, runs for 90 seconds and is titled Welcome. That covers part of what Section 4 BITV 2.0 (German Federal Ministry of Justice) requires - three further points remain open. German Sign Language is not a transliteration of the body text but a language of its own with its own grammar (German Association of the Deaf). Anyone embedding it makes technical decisions that Annex 2 of the regulation has already mapped out: resolution, frame rate, labelling, downloadable file. This article walks the chain from content selection through to sign-off.

Key takeaways

Section 4 BITV 2.0 names four explanations that must appear on a public body's home page in German Sign Language and in Easy Language (German Federal Ministry of Justice). A plain welcome video covers one of them.
Annex 2 Part 1 makes seven production requirements binding, among them a minimum resolution of 320 x 240 pixels and a minimum frame rate of 25 frames per second (German Federal Ministry of Justice). Those values belong in the brief, not in the rework.
WCAG places sign language interpretation at Level AAA (W3C). Anyone auditing to Level AA alone will not find the BITV 2.0 sign language duty reflected in the resulting report.
Captions and audio description remain success criteria in their own right and are not replaced by a sign language video (W3C). A video typically carries both tracks alongside each other.
The player is part of the audit scope: keyboard operation, visible focus, toggleable captions and an expandable transcript decide whether the video can be reached at all.

What Section 4 BITV 2.0 actually requires

The duty sits in a single sentence with four numbered items: on the home page of a public body's website, the following explanations must be provided in German Sign Language and in Easy Language in accordance with Annex 2 (German Federal Ministry of Justice). The sentence then names information on the core content, guidance on navigation, an explanation of the core content of the accessibility statement, and pointers to further material available in those two forms on the same site. Four points, then, not one. In audit practice this is where the most common gap sits: a site shows a general welcome video while navigation, the accessibility statement and the pointer to further sign language material remain unfilled.

The regulation addresses federal public bodies. The basis sits in Section 12a BGG: federal public bodies shall design their websites and mobile applications, including intranet offerings intended for staff, to be accessible (German Federal Ministry of Justice). For electronically supported administrative procedures the same section names 23 June 2021 (German Federal Ministry of Justice) as the latest date. The federal states run their own regulations, which largely mirror the federal text; anyone working for a state authority or a municipality consults the state version in addition. Private sector companies are not addressed by Section 4 BITV 2.0 - there a sign language offering grows out of reach and customer proximity, not out of this regulation. How far the duty extends behind the login is covered in the article on the accessible intranet.

Information on the core content of the site
Guidance on navigation, that is, on how to operate the site
An explanation of the core content of the accessibility statement
Pointers to further material available on the same site in German Sign Language and in Easy Language

Easy Language sits in the same sentence

Section 4 BITV 2.0 requires the four explanations in German Sign Language and in Easy Language (German Federal Ministry of Justice). Both offerings usually grow out of the same project because they need the same content selection: what is essential and what is trimming. Annex 2 Part 2 sets its own requirements for the text version, among them short sentences and a font size of at least 1.2 em (German Federal Ministry of Justice). How we build the text offering is described on the page about Easy Language.

Core content: the selection step before the camera

The regulation prescribes no running time and no number of videos. It prescribes a selection concept: core content. That moves the first piece of work out of the studio and into the editorial team. Anyone maintaining an authority site with 400 subpages cannot have everything interpreted, and by the wording is not expected to. Experience suggests that a set of four to six short films carries the mandatory part: what this body does, what it is responsible for, how to find your way around, how to reach a person, what the accessibility statement says, and what further material exists in sign language. That selection belongs in writing, because it may have to be justified.

The second reason for the selection step is linguistic. Sign languages have a comprehensive vocabulary and a grammar of their own that follows fundamentally different rules from the grammar of spoken languages (German Association of the Deaf). A film is therefore not a word-for-word rendering of the body text but a transfer that resets order, emphasis and examples. German Sign Language has been recognised in Germany as a fully fledged language since 2002 (German Association of the Deaf); in law, Section 6 subsection 1 BGG states this expressly (German Federal Ministry of Justice). Anyone taking that status seriously plans a script together with interpreters rather than a voice-over added afterwards.

What belongs in

Remit, service overview, how the navigation works, the contact route, the core of the accessibility statement and the pointer to further sign language content.

What stays out

Day-to-day news, form details and legal texts in full. They date quickly and tie up budget that the mandatory content carries better.

Who decides with you

Editorial team, disability officer and interpreters. A feedback loop with deaf test users surfaces comprehension gaps early.

On the scale of it: according to the German Association of the Deaf, around 80,000 (German Association of the Deaf) deaf people live in Germany; drawing on figures from the German Association of the Hard of Hearing, the same guide also names roughly 140,000 (German Association of the Deaf) hard of hearing people with a degree of disability above 70 per cent who depend on sign language interpreters. Worldwide the World Federation of the Deaf counts more than 70 million (United Nations) deaf people who between them use more than 300 different sign languages. That diversity matters in practice: German Sign Language is not international (German Association of the Deaf), it has dialects, and a film from another language area does not stand in for it.

Annex 2 Part 1: the seven production requirements

While Section 4 says what is shown, Annex 2 Part 1 says how it has to look. Seven numbered items, each briefly worded, each verifiable. They cover light and body of the performer, the background, the contrast between background, clothing and hands, labelling with the sign language logo, the resolution, the frame rate and the provision of a downloadable file. The order is telling: first the legibility of the signing space, only then the technology. Whoever writes the brief is well advised to carry the seven items verbatim into the production order, because otherwise the studio reads them as recommendations.

Two values are hard numbers and therefore the simplest check points in the whole provision: the resolution is at least 320 x 240 pixels (German Federal Ministry of Justice) and the frame rate is at least 25 frames per second (German Federal Ministry of Justice). Both are floors, not targets. In practice a present-day production sits well above them, because facial expression and mouth pattern blur at small player sizes. More important than the raw resolution is what size the picture occupies in the finished layout: a sign language window delivered 120 pixels wide on a phone meets the number and misses the point.

Requirement from Annex 2 Part 1	Wording in brief	What it means in production
Item 1 - light and body	Avoid shadows, facial expression and mouth pattern clearly visible	Soft frontal light, no hard side light, framing to the hip rather than full body.
Item 2 - background	Static, no black, no white	A plain mid-tone surface, no moving studio graphic, no office backdrop with people walking through.
Item 3 - contrast	Background, clothing and hands in contrast	Dark, plain clothing without patterns; jewellery and watches removed, as they disturb the signing space.
Item 4 - labelling	Video carries the German Sign Language logo	Logo in the player or the preview, colour-matched to the design, with a meaningful alternative text.
Item 5 - resolution	At least 320 x 240 pixels	A floor; check the delivered display size in the layout separately.
Item 6 - frame rate	At least 25 frames per second	A floor; review motion blur on fast signing during the edit.
Item 7 - downloadable file	File for download with size and running time	Direct link next to the player, file size and duration in the text, not only in the file name.

The download item is the one most often missed

Item 7 requires that the sign language film is additionally available as a file for download and that details of the file size and the running time are available (German Federal Ministry of Justice). Both are regularly absent in audits, because modern players stream files instead of offering them. A visible link following the pattern MP4, 38 MB, 2:14 minutes satisfies the item and at the same time helps people on a narrow connection who would rather download once than buffer three times.

The player decides whether the video arrives

A compliantly produced film is of little use if its surroundings do not release it. The player is an operating surface with buttons, a progress slider and a menu - and therefore an audit object of its own. Section 3 subsection 4 BITV 2.0 sets a raised bar for it: for central navigation and entry offerings as well as offerings that enable user interaction, the highest possible degree of accessibility shall be sought (German Federal Ministry of Justice). The home page with the sign language entry point falls squarely into that category. In practice this means keyboard operation without traps, visible focus on every control, labelled buttons and a progress slider that moves with the arrow keys.

The entry point itself deserves the same attention as the video. A sign language offering reachable only through an icon in the footer hardly satisfies the wording of the home page duty. What works is a visible entry point in the upper page area, marked with the sign language logo and given a text label that works without the image. An overview page listing every sign language film with title, duration and download link has proven itself - which also satisfies the fourth item of Section 4, the pointer to further material, at no extra cost. Building the entry point and the player belongs in accessible web development rather than in video production.

dgs-entry-point.html

<figure class="dgs-film">
  <video controls preload="metadata"
         poster="/media/dgs-welcome.jpg"
         aria-describedby="dgs-note">
    <source src="/media/dgs-welcome.mp4" type="video/mp4" />
    <!-- Captions stay a separate, toggleable track -->
    <track kind="captions" src="/media/dgs-welcome.vtt"
           srclang="de" label="Deutsch" default />
  </video>
  <figcaption id="dgs-note">
    Explanation in German Sign Language.
    <!-- Annex 2 Part 1 item 7: size and running time visible -->
    <a href="/media/dgs-welcome.mp4" download>
      Download the film (MP4, 38 MB, 2:14 minutes)
    </a>
  </figcaption>
</figure>

<details>
  <summary>Expand transcript</summary>
  <div lang="de"><!-- Full text of the film --></div>
</details>

Two things stand out in the markup. First, the caption carries the download link including file size and running time - it is the place where item 7 of the annex becomes visible. Second, the transcript sits in an expandable element rather than in a separate file: moving the full text to a second page loses part of the readership along the click path. A detail that often has to be added later is the language marking. The full text is German text and carries lang="de"; the video itself is sign language. A dedicated language tag for sign language in the HTML attribute is uncommon in practice, which is why the marking runs through logo, title and description - exactly as item 4 of the annex intends.

Captions and transcript remain separate duties

A widespread short circuit runs: if the film exists in sign language, captions are dispensable. WCAG sees it differently, and for good reason. Success criterion 1.2.2 requires captions at Level A (W3C) for all prerecorded audio content in synchronised media. Success criterion 1.2.5 requires audio description at Level AA (W3C) for all prerecorded video content, and 1.2.4 requires captions for live audio content as well. Those are three distinct needs: people who lost their hearing later in life often use written language rather than sign language; blind people need the description of what happens on screen; people in a noisy environment read along. The tracks do not replace one another, they complement one another.

In practice: a sign language film with spoken audio needs a caption track, a transcript and - where the picture carries information the audio does not - an audio description or a full-text alternative. Conversely, an existing explainer video with captions does not satisfy Section 4 BITV 2.0, because that provision expressly requires German Sign Language. How captions, transcript and audio description mesh cleanly is covered in detail in the article on accessible media.

Embed the caption track as a toggleable WebVTT file rather than burning it into the picture
Offer the transcript as full text on the same page, expandable instead of moved elsewhere
Plan audio description or a full-text alternative where the picture carries information of its own
State title, running time and file size as text for every film
Set the sign language logo as the marking and give it an alternative text
Walk the caption menu and the volume control with keyboard and screen reader

Where WCAG stops and the regulation continues

This is the point that causes the most confusion in audit reports. Sign language interpretation appears in WCAG as success criterion 1.2.6 and is assigned to Level AAA (W3C). For a conformance claim at Level AA the guideline's conformance requirements state that the web page satisfies all the Level A and Level AA success criteria, or that a Level AA conforming alternate version is provided (W3C) - Level AAA stays outside. A tool or an audit checking the page against Level AA therefore reports no failure when no sign language video is present. The duty stands regardless, because it comes not from the guideline but from Section 4 BITV 2.0 (German Federal Ministry of Justice).

For practice this implies a clear split in the audit brief. The technical audit against the harmonised standard covers player, captions, focus and structure; the review of the sign language and Easy Language offerings runs alongside it as a comparison with the wording of the regulation. Anyone merging both into one report should state the origin of each requirement, otherwise a regulatory finding is misread as a Level AAA recommendation and drops to the bottom of the priority list. Which standard sits behind the presumption of conformity is explained in the article on EN 301 549; how findings are then put in order is shown in the article from audit report to remediation plan.

German Sign Language is recognised as a language in its own right.

Section 6 subsection 1 of the German Disability Equality Act (BGG), translated

Audit, document and keep current

Signing off a sign language offering has two halves. The first is a text check against the wording of the regulation: are all four items from Section 4 filled, does every film carry the logo, is there a download link with size and duration for each film, do resolution and frame rate sit above the floors. That half can be worked through in a table and needs no special tooling. The second half is an operational check: the keyboard path from the top of the page to the play button, the focus order inside the player, the behaviour of the caption menu, the screen reader output, the rendering in high contrast mode and on narrow screens. Both halves belong in the same report, but in separate sections.

The third part is easily forgotten: currency. A sign language film describes remits and navigation. If the menu structure changes, the film ages quietly without any tool raising a flag. Experience favours a fixed rule: whoever touches the navigation or the accessibility statement reviews the matching film in the same operation. A recurring annual date catches the rest. For sites that change often, ongoing accessibility monitoring is worth having, reporting deviations before they surface in the next audit. Content shown on hover or focus around the player - short notes on the film length, for instance - follows rules of its own, covered in the article on accessible tooltips.

Procurement: the requirements belong in the specification

Where the production is tendered, the specification decides the outcome. The seven items from Annex 2 Part 1, the four contents from Section 4 and the player requirements belong in it verbatim, together with acceptance criteria and rights clearance for the interpreters. What to observe formally is set out in the article on accessibility in public tenders. For expert support on public sector projects we maintain the page Public Sector.

One last point for context: the International Day of Sign Languages goes back to resolution A/RES/72/161 (United Nations), co-sponsored by 97 member states and adopted by consensus on 19 December 2017. For your own website that is no legal basis, but it is a usable date: 23 September works as an annual checkpoint to review the stock of sign language films, replace outdated statements and test the entry point. Carrying that along in the WCAG audit assembles the evidence for the next review without a separate run. For the technical side of entry point, player and transcript our accessible web development applies, and for the text version Easy Language.

This article is based on data from: the German Accessible Information Technology Regulation (BITV 2.0), Sections 3 and 4 and Annex 2, together with the German Disability Equality Act (BGG), Sections 6 and 12a, both in the version published on gesetze-im-internet.de by the Federal Ministry of Justice; W3C Web Content Accessibility Guidelines (WCAG) 2.2, Recommendation of 12 December 2024; German Association of the Deaf, guides on deafness and German Sign Language; United Nations, International Day of Sign Languages with resolution A/RES/72/161.