EEA Guideline

How to implement accessibility projects properly – Achieving accessibility by 2025

Illustration: Barrier present: Stairs are blockers - Accessibility Strengthening Act denkwerk

An often-used example of accessibility is the ramp (known as a wheelchair ramp, but of course it also provides an accessible stair alternative for strollers or walkers). Again, the staircase (=barrier) does not disappear, all that is provided is a way to get around the barrier.

Illustration: Barrier gone: the famous ramp clears the way. Accessibility Strengthening Act denkwerk

The same then applies in the area of accessibility according to BITV. Accessibility is de facto an all-encompassing challenge that affects the digital, virtual and real worlds equally and is not purely technical, even in the digital world. A common barrier in digital offerings, for example, is a lack of legibility due to insufficient color contrasts. This is a design task, using the color palette available in corporate design to achieve the best possible readability for everyone. Incidentally, insufficient contrast is one of the most common shortcomings in website accessibility, along with editorial errors – such as empty ALT texts or incorrect links.

  • • Websites

  • • Intranets and extranets

  • • PDF files

  • • Mobile applications (mobile)

This means that public bodies at federal, state and local level have to make their websites accessible at least in accordance with conformance level AA of WCAG 2.1 (Web Content Accessibility Guidelines). Some schools and daycare centers as well as public broadcasters are exempt from the BITV. For the latter, dedicated guidelines on audiovisual media services apply.

BFSG has already come into force

For non-public digital services, the BFSGV has now come into force. The good news is that it will not become mandatory until July 28, 2025, after which all new private e-commerce offerings, operating systems, all electronic and digital banking services (including ATMs), electronic communications, audiovisual media, e-books, and passenger transportation services must be accessible in accordance with the above standard. For already existing services, there is a five-year transition period, but even if the obligation and the threatened penalties don’t take effect immediately, the experiences with the GDPR described at the beginning of this article call for early action. Depending on the current status of the company’s own digital technology and process-related interlinking with any of its barrier-rich and non-digital customer touchpoints or also in an employee context, accessibility can become an extremely challenging task. This is particularly true if a holistic approach is taken (as would be correct in terms of user and customer centricity). The pandemic in particular has shown just how important accessibility is in this context.

"Many organizations underestimate that accessibility is an important business driver."

Domingos de Oliveira Accessibility Consultant at

Regulatory constraint of BITV 2.0

In addition to the regulatory compulsion that comes with the implementation of BITV 2.0, it is often forgotten that with increased and improved accessibility, an often-neglected user group can be better reached with their own digital offering. For around 10% of people, accessibility is indispensable in all areas of daily life. For 40%, it represents a significant improvement and for all, it offers greater convenience and therefore, in the digital context, a significant factor in the user experience. So there are also clear economic arguments for successfully developing this topic for your own product.

How can denkwerk support BFSGV implementation?

Here at denkwerk, many of our client projects have already been made accessible, some of which were under considerably greater regulatory pressure in terms of time. For example, in 2018, a regulation on the accessibility of, among other things, flight booking offers in IBEs (Internet Booking Engines) was issued by the DOT (US Department of Transportation) in the USA, non-compliance with which could result in severe penalties (on a similar scale to the GDPR). Together with the stakeholders and other parties involved, denkwerk prepared the entire English-language websites and booking routes of the then-associated airlines Condor and Thomas Cook Airlines in conformity with WCAG 2.0 AA.

Under similar conditions, this year we worked on the accessibility of the website and booking route for Motel One for their market entry into the USA with their first hotel in New York. In the hospitality sector, the USA is also ahead of the Europeans in terms of digital accessibility because similarly concrete regulations apply in the same way that they do for flight bookings. For this project, denkwerk has established a close cooperation with accessibility consulting agency netz-barrierefrei. The head of the agency, Domingos de Oliveira, is actually blind himself. As an intensive user of assistive technologies, his analyses attain a higher level of quality. This clearly gives our customers an even higher level of security in terms of BFSGV and WCAG conformity.