An accessible application process determines whether qualified people with disabilities can apply to your company at all – or whether they are already being held back by the job advert. Many companies underestimate this. They invest in employer branding, but unwittingly erect digital barriers within their own application process. Yet the target group is large and the skills shortage is very real. In this guide, I’ll draw on my practical audit experience to show you which legal obligations actually apply – and which don’t – where the specific stumbling blocks lie, from the job advert through to the application form and the applicant tracking system, and what underestimated risk of discrimination is currently emerging as a result of AI. Finally, I’ll reveal the simplest step that almost everyone overlooks.
What does an accessible job application mean?
An accessible application process means that the entire journey to joining your organisation can be completed without the need for assistance from others. This begins with the job advert and extends through the careers page and the application form right through to the interview. At no stage of this process should a visual, hearing, motor or perceptual impairment result in exclusion.
It is important to look at the bigger picture. After all, a process is only as accessible as its weakest link. A perfect careers page is of little use if the form behind it cannot be filled in using a keyboard. And even the best job advert is wasted if it is posted on a social media platform as a simple image without alternative text.
Far more people are affected than one might think. Around 87 million people with disabilities live in the EU. Many of them are well-educated and in the prime of their working lives. You can only reach these skilled workers through a process that is transparent from start to finish. In addition, there are people with temporary disabilities, for example following an injury, as well as older applicants – they, too, benefit directly.
The four barriers in the application process
Recruitment challenges can be categorised into four types. Each type affects a different group – and requires a different solution.
Visual barriers affect blind and visually impaired applicants. They are hindered by images without alternative text, font sizes that are too small, and reliance on colour coding alone. Auditory barriers affect deaf people, for example in the case of an explanatory video without subtitles. Motor barriers affect people who cannot use a mouse – they require full keyboard control. And cognitive barriers arise from overloaded forms, technical jargon and strict time limits.
It is important to note that these barriers often compound. An older applicant, for example, may have poorer eyesight and type more slowly. That is why making piecemeal changes in just one area won’t help. Rather, the entire process must work for all four groups. Only when each of these four hurdles has been addressed will your application process truly be inclusive.
Does the BFSG apply to careers pages?
There is a great deal of confusion on this point, which is why we are setting the record straight: for most employers, it is not the BFSG that is the decisive factor, but the General Equal Treatment Act (AGG). This is because the AGG applies to every employer – regardless of company size and without exception. If a barrier makes it more difficult for a person to apply for a job because of their disability, this may constitute discrimination under Section 7 of the AGG. This may give rise to claims for compensation under Section 15 of the AGG of up to three months’ salary.
The BFSG, however, only applies under certain conditions. It applies to career pages where they form part of a website that offers services to consumers via electronic commerce. A purely B2B careers microsite is not necessarily covered by the Act. However, please note: as soon as applicants register in an applicant tracking system, this may constitute a consumer contract – and that triggers the obligation under the BFSG, even if registration is free of charge. You can read more about the Act in the BFSG guide for businesses.
Public sector employers are subject to their own set of standards in any case. For years now, their websites have been required to comply with BITV 2.0, and this includes their careers pages. I explain the principles laid down by BITV in the guide to BITV as the basis for accessible websites. The following overview sets out the most important legal principles.
| Legal foundation | Applies to | Core |
|---|---|---|
| AGG | all employers, with no threshold | Prohibition of discrimination, compensation under §15 |
| BFSG | Consumer/e-commerce relevance, ATS registration | WCAG-compliant digital services |
| BGG / BITV 2.0 | public sector employers | Accessible websites, including careers pages |
| Social Code Book IX | Employers with 20 or more employees | Employment obligation, equalisation levy |
The talent pool you’re missing out on
Accessibility in recruitment is not a cost factor, but a means of accessing skilled workers. After all, there are around 7.8 million people with severe disabilities living in Germany. Many of them are highly qualified and looking for work. Anyone who excludes them is voluntarily reducing their pool of applicants – and this, of all times, at a time of skills shortages.
Added to this is a significant financial incentive. Under Section 154 of SGB IX, employers with at least 20 posts must fill five per cent of these with people with severe disabilities. Those who fail to meet this quota must pay a compensation levy under Section 160 of SGB IX. Furthermore, employers are obliged to assess the suitability of applicants with severe disabilities (Section 164 of SGB IX). An accessible recruitment process is therefore also a way of reducing this levy, rather than simply paying it. It is important to note that you must first reach candidates with severe disabilities before you can recruit them.
The third benefit is employer branding. A process that is inclusive of everyone signals a positive attitude and modernity. This enhances your image amongst all applicants, not just those with disabilities. Added to this is staff retention. After all, anyone who has experienced an employer that considers everyone’s needs is more likely to stay and recommend them to others. I discuss the overall economic benefits in detail in the guide to the economic advantages of digital accessibility.
The job advert: make it accessible and inviting
The first barrier is often found right in the wording of the job advert. You should therefore use clear, simple language and avoid creating unnecessary obstacles. For example, do not require a driving licence if the role does not absolutely need one. Requirements like this exclude people without serving any useful purpose.
Also, pay attention to the format. A job advert posted as a standalone image on social media is invisible to blind people if the alternative text is missing. Any attached PDF must be tagged and accessible to screen readers. And a clear, honest statement that you expressly welcome applications from people with disabilities noticeably lowers the barrier to applying. A common and sensible addition is a statement confirming that, where candidates are equally qualified, those with severe disabilities will be given preferential consideration. I explain how to create accessible PDFs from the outset in ‘Creating accessible PDFs’.
Caution is also advised when using coded language. Phrases such as ‘high resilience’ or ‘stress-resistant’ can put some applicants off, even though they often have no real technical meaning. It is better to describe the tasks involved in concrete terms. That way, it is the candidate’s actual suitability that counts, not a vague cliché.
It is also helpful to adopt a gender-neutral and age-inclusive tone. A job advert that explicitly states ‘m/f/d’ and avoids phrases such as ‘young, dynamic team’ will appeal to a wider audience. This is because such phrasing can inadvertently come across as exclusionary. By contrast, specifying concrete duties and setting fair requirements will attract precisely the candidates you are looking for.
Accessible careers page: WCAG as the benchmark
The careers page itself complies with the WCAG guidelines from a technical perspective. It must be fully operable using a keyboard (2.1.1 Keyboard), and the focus must remain clearly visible (2.4.7 Focus Visible). Furthermore, all text must have sufficient contrast against the background (1.4.3 Minimum Contrast). These three points alone make a huge difference.
Scalability is equally important. Users must be able to enlarge the text to 200 per cent without any content being lost (1.4.4 Changing text size). A page that cannot cope with this will immediately lose applicants with visual impairments. Also, bear in mind mobile use. After all, many people now apply for jobs via their smartphones. Clickable elements should be large enough and clearly separated on mobile devices (2.5.8 Minimum Target Size). I go into more detail about the importance of clear contrast ratios in the guide on colours and contrast.
You should also test the page using a screen reader. This is the only way to check whether headings, links and buttons are announced in a way that is easy to understand. What seems obvious when using a mouse can prove to be a dead end when using a screen reader. It is precisely this gap that is filled by a test which ‘listens’ to the page rather than just ‘seeing’ it.
Accessible application forms: the most critical aspect
The form is the most common point at which users abandon the process. That is why every field needs a visible, permanently recognisable label (3.3.2 Labels or instructions). A placeholder that disappears when you start typing is not sufficient. This is because it places a strain on the user’s memory and is often invisible to screen readers.
How errors are handled is also crucial. If an error occurs, it must be clearly identified and linked to the relevant field, with specific instructions on how to correct it (3.3.1 Error detection). You should also populate fields with the appropriate autocomplete values (1.3.5 Recognising the purpose of input) so that the name and address are filled in automatically. And ensure that dynamic changes, such as a successful upload, are reported in an accessible manner (4.1.3 Status messages). I go into more detail on how to design forms to be accessible in general in the guide to accessible forms.
There are two pitfalls I come across particularly often. Firstly, strict time limits, which put applicants under pressure and cause them to abandon the upload process (2.2.1 Adjustable time limit). Secondly, a CAPTCHA that requires users to type out distorted letters, thereby excluding blind applicants (3.3.8 Accessible Authentication). Both of these can easily be mitigated or omitted altogether. As an alternative to a CAPTCHA, you could, for example, offer a simple logic question, or do away with it entirely if invisible spam protection is sufficient.
Don’t forget the applicant tracking system
The biggest shortcoming often lies in the system behind it. This is because a significant part of the application process takes place within the applicant tracking system – when creating a profile, uploading documents and tracking the status. It is precisely this tool that is often a third-party software programme which nobody has checked for accessibility.
Nevertheless, the responsibility remains with you. You cannot hide behind the provider if an applicant is unable to log in. You should therefore ask the provider for proof of accessibility, such as a robust statement or a VPAT. And test the registration and upload process yourself using a keyboard and a screen reader. Also, ensure that the process works seamlessly across all devices. After all, anyone who starts on a smartphone and has to continue on a PC will quickly lose their train of thought.
Then there is the legal aspect. As mentioned, registration in such a system can constitute a consumer contract and thus trigger the BFSG. This means that it is often the ATS level in particular that becomes the actual obligation. Our in-depth ‘Access Ready’ audit examines precisely this chain – comprising the careers page, the form and the system – using real users.
Making the job interview accessible
The interview itself can also present a barrier. You should therefore ask candidates early on, and in a respectful manner, whether they require any adjustments for the interview. This could be an accessible room, a sign language interpreter or simply more time. This way, you demonstrate openness without embarrassing anyone.
Also bear in mind the format. A telephone interview alone excludes deaf people. A video call, on the other hand, requires properly functioning subtitles, as I explain in the guide to video subtitles. Aptitude tests also need to be scrutinised. This is because a test with a strict time limit puts people who read more slowly at a disadvantage, without this having anything to do with their professional aptitude.
Public sector employers actually have a clear obligation in this regard. Under Section 165 of SGB IX, they must invite applicants with severe disabilities to an interview, provided they do not clearly lack the necessary professional qualifications. However, even without this obligation, it is simply sensible not to rule anyone out too hastily.
Accessible recruitment: fair testing and decision-making
Between the interview and the job offer lies the recruitment process, and this too must be accessible. Online assessments, aptitude tests and work samples are now mostly conducted digitally. The same requirements apply as for the careers page: keyboard access, support for screen readers and no rigid time limits. You should also offer reasonable adjustments, such as extra time or a different format, if a test would otherwise measure a disability rather than aptitude.
You should also involve the representative body for people with severe disabilities, if one exists. Employers are required to inform this body of applications from people with severe disabilities (Section 164(1) of SGB IX). The body is entitled to inspect the documents relevant to the decision and to attend the interviews (Section 178(2) of SGB IX). Finally, make a record of why you decided in favour of or against a particular candidate. This is because, in the event of a dispute, Section 22 of the General Equal Treatment Act (AGG) stipulates that even circumstantial evidence of discrimination is sufficient, and you will then have to prove that your selection was objectively justified. A documented selection process is therefore the best safeguard and the cornerstone of a fair, accessible recruitment process.
AI in recruitment: the underestimated risk of discrimination
A new risk is emerging precisely as a result of automated selection. This is because AI that sorts CVs, ranks candidates or evaluates video interviews is classified as a high-risk system under the EU AI Regulation. Following the postponement caused by the so-called Digital Omnibus Package, the full obligations for such systems will come into force from 2 December 2027. Furthermore, emotion recognition in the workplace – such as the analysis of facial expressions or tone of voice during an interview – has been prohibited since 2 February 2025.
For people with disabilities, the risk is very real. Someone who stutters might exceed a time limit during a video interview and be automatically rejected. Anyone who, due to a visual impairment, fails to maintain eye contact with the camera will be flagged out by facial expression analysis. And an unfamiliar accent may be mistakenly interpreted as a lack of commitment. In one test, a system classified 38 per cent of speakers with an accent as showing little commitment – compared with just 12 per cent of those without an accent.
You can protect yourself by establishing clear rules. Never allow an AI system to reject applications automatically on its own; always keep a human in the loop. Be transparent about the use of AI and offer an equivalent, accessible alternative. In practical terms, this means that anyone who is unable to cope with the AI assessment must be able to request a traditional conversation with a human. This is because, under the General Data Protection Regulation, everyone has the right to challenge a purely automated decision. You should also document how your system has been tested. This obligation to provide evidence applies equally to providers and the organisations using the system. Those who handle this properly not only avoid trouble but also gain the trust of applicants. This ensures the selection process remains fair – and legally compliant.
After the offer: Onboarding and the workplace
Accessibility doesn’t end with the signing of the contract. After all, the first day at work brings with it new digital barriers. An employment contract in the form of an untagged PDF is unreadable for a blind employee. And an internal portal that cannot be navigated using a keyboard excludes them from day one.
You should therefore include onboarding in your planning. Ensure that contracts and documents are provided in accessible formats. Also check whether the intranet, learning platform and specialist software are accessible. And clarify at an early stage what technical aids a person needs – these can often be funded through the Inclusion Office. This ensures that a good recruitment decision leads to a good start. After all, those who can contribute from day one become productive more quickly. The welcome pack and initial training materials should therefore also be accessible right from the start.
The most common mistakes in the application process
The same shortcomings recur time and again across numerous audits. These are the seven I see most frequently – and they can all be avoided:
- A job advert posted as an image on social media, with no alternative text at all.
- Vanishing placeholders as the only field labels in the form.
- Mandatory upload without accessible feedback on whether it was successful or failed
- A strict time limit that acts as a cut-off point during uploading.
- A letter-based CAPTCHA that completely excludes blind applicants.
- An unaudited third-party applicant tracking system.
- There is no alternative application route in the event that something goes wrong.
One thing is striking. Almost none of these mistakes are made deliberately. Rather, they stem from the assumption that all applicants have good eyesight, good hearing and a steady hand. It is precisely this assumption that excludes qualified people.
The simplest step that almost everyone forgets
A single step can overcome almost every remaining obstacle. And yet hardly any company implements it consistently.
From real-world experience – the designated ‘emergency exit’: Always provide a simple, alternative way to apply – one that is clearly visible and includes a specific, named contact person, complete with a direct email address and telephone number. Because no matter how good your digital process is, a barrier can always arise, and when it does, a person needs a solution that works straight away. Two things are important here. Firstly, this route must not present any obstacles – in other words, it must not itself be hidden behind an inaccessible form. Secondly, it must not force anyone to disclose their disability in advance or to ask for special treatment. A simple line such as “You can also apply directly by email or telephone to Ms Muster” takes the pressure off. This way, you’ll no longer lose a qualified candidate to a technical detail – whilst at the same time signalling genuine openness.
Would you like to know exactly what digital accessibility entails in your sector? In 30 minutes, we’ll work with you to clarify the requirements and the next steps.
Frequently asked questions about accessible job applications
Does a job application form have to be accessible?
The AGG applies to all employers: if a female applicant is unable to complete your form due to her disability, this may constitute discrimination and give rise to claims for compensation. Public sector employers are also bound by the BITV 2.0. And if your applicant tracking system requires registration, the BFSG may also apply. The WCAG serve as the technical benchmark. An accessible application form is therefore effectively indispensable.
Am I allowed to ask about a disability during the recruitment process?
You should avoid asking a mandatory question about a disability, as this could be taken as evidence of discrimination in the event of a dispute. However, a voluntary offer is not a problem; for example: ‘Do you require any support or adjustments for this interview?’ This allows you to find out what someone needs without them having to disclose their disability. Applicants may also voluntarily declare a severe disability in order to exercise their rights under SGB IX.
What does inclusive recruitment involve?
The whole process: an accessible job advert, an accessible careers page, an application form and an applicant tracking system that work with a keyboard and screen reader; an interview with reasonable adjustments offered; fair assessments; and an accessible onboarding process. In addition, there is always an alternative application route with a designated point of contact.
How to make your application truly accessible
The process begins with the measurable shortcomings and ends with the actual application experience. The free Access Score provides a quick overview of the careers page and application form in a matter of minutes. It highlights the measurable issues: insufficient contrast, lack of keyboard navigation, and click targets that are too small.
However, the real truth only becomes apparent in practice. Can a blind person complete the application form? Does a deaf applicant understand the video interview? Can someone with tremors find the right buttons? No scanner can measure that. Our in-depth ‘Access Ready’ audit tests the entire process with real users and issues a legally compliant certificate.
| Approach | Checks | Real users | Legally valid certificate |
|---|---|---|---|
| Free scanner | Only measurable data on the page | no | no |
| A gut feeling | individual samples | no | no |
| Access Ready (ifdb) | Advert, page, form, ATS | yes | yes |
The difference lies in the support we provide. Other providers simply send you an automated report and leave you to get on with the results. We, on the other hand, support you every step of the way – from the assessment, through the specific measures, right through to providing evidence. This turns a legal risk into a recruitment strategy that reaches more talent. And it transforms ‘let’s hope it works out’ into a proven ‘absolutely anyone can apply to us’.
