Frequently asked questions about digital
accessibility, the BFSG and audits

Digital accessibility means that websites, apps and documents can be perceived, operated and understood by everyone – regardless of physical or cognitive limitations. It is not just about blind or deaf people, but also about older users, people with temporary impairments or those in challenging circumstances. We deliberately use the term ‘barrier reduction’ rather than ‘100 per cent accessible’, because it is not realistically possible to guarantee complete freedom from barriers.

That depends on your business model and the size of your organisation. Since 28 June 2025, the Accessibility Strengthening Act has required many businesses offering digital products and services to consumers – including e-commerce, banks, passenger transport and numerous service providers – to comply. Micro-enterprises with fewer than ten employees and an annual turnover of less than two million euros are partially exempt in the services sector, but this exemption applies less frequently than many hope. Anyone who is unsure should not make a decision based on gut feeling, but should seek a reliable clarification.

The BFSG is aimed at the private sector, whilst the BITV 2.0 is aimed at public authorities. Whilst the Accessibility Strengthening Act has required companies to comply since 2025, the Accessible Information Technology Regulation has applied to federal authorities, government departments and public institutions for considerably longer. Technically, both are based on the same foundation – the WCAG via the European standard EN 301 549. In practice, many organisations, such as municipal utilities, fall under both sets of regulations.

In the event of non-compliance, you risk receiving formal warnings from competitors and trade associations, as well as complaints from market surveillance authorities. The first formal warnings concerning non-accessible websites are already a reality. Added to this is the reputational risk and the financial loss incurred when a significant proportion of potential customers are unable to use your service. ‘We’ll take care of it at some point’ will no longer be a viable strategy from 2025 onwards.

No. Depending on the study, a purely automated scan covers only about a third of the relevant WCAG criteria. Tools such as axe-core or Lighthouse are a good first filter, but they cannot assess whether alt text makes sense in terms of content or whether a keyboard navigation sequence is logical. To provide robust evidence, a combination of technology, human review and real users of assistive technologies is required – the so-called ‘human-in-the-loop’ approach.

An audit systematically assesses your website, app or documents against standards such as WCAG 2.2. Our process begins with an automated in-depth scan as a starting point, followed by a manual assessment using JAWS, NVDA and VoiceOver, as well as a panel of real users. You will receive a prioritised audit report with specific recommendations for action. Once all issues have been resolved, we will issue the ifdb certificate.

That depends on the scale and complexity of your digital offering – the number of pages to be reviewed, the type of application and the desired scope are the key factors. Rather than a flat fee that may not reflect your actual situation, we start with a free initial analysis and a non-binding consultation, during which we work with you to determine the appropriate scope.

For a medium-sized website with five to ten subpages, two to four weeks from the kick-off to the audit report is a realistic estimate. The subsequent remediation phase depends on how many issues are found and how quickly your team resolves them. Complex enterprise applications are quoted on a individual basis.

The ifdb certificate documents a comprehensive testing process in accordance with WCAG 2.2, combining technical testing, manual evaluation and real users. It serves as proof of due diligence under the BFSG and is therefore one of the most robust documents you can present in the event of an official inspection or a formal warning. Unlike a simple scan report, it is the result of an in-depth human review.

An overlay can improve usability – for example, through font size, contrast or a text-to-speech function – but it does not resolve accessibility issues in the coding. Providers who market an overlay as a ‘one-click solution for full compliance’ are controversial among experts, and such promises have not prevented legal warnings. We use overlays exclusively in good faith: as a declared stopgap whilst the actual refurbishment is underway – never as a substitute.

Yes. The law applies not only to websites and apps, but also to digital documents such as PDFs. The key standard here is PDF/UA, which governs tags, reading order, alternative text and correct table markup. A PDF may look flawless visually, yet still be completely unusable for a screen reader. Public authorities and large corporations with extensive document collections are particularly prone to underestimating this shortcoming.

A website is a living system – every update and every piece of new content can create new barriers. That is precisely why accessibility does not end with the audit. Continuous monitoring automatically checks your website after every change and reports new barriers immediately, ensuring that your achieved compliance status is maintained.

Definitely yes. Even businesses not strictly subject to the BFSG regulations benefit from greater reach, better search engine rankings and improved user-friendliness. The technical principles of accessibility overlap significantly with good SEO, and an accessible website reaches a target audience with strong purchasing power that many competitors continue to exclude to this day. Accessibility is therefore not a cost, but an investment that generates a return.

No. This FAQ provides a technical assessment based on our audit experience, but does not constitute legal advice. For a definitive assessment of your specific legal situation – for example, regarding whether you are affected or concerning contractual details – you should seek professional legal advice.