INDUSTRY · HEALTHCARE & PHARMACEUTICALS · BFSG · EAA · WCAG 2.2

Accessible patient portals –
in the healthcare sector,
access determines care.

In the healthcare sector, a digital barrier is rarely just a inconvenience. Anyone who cannot book an appointment online unable to access a medical report or read the patient information leaflet may, under certain circumstances, denied access to their own healthcare. Health insurance providers, hospitals and pharmaceutical companies bear a responsibility here that goes beyond compliance with the law – as their target audience includes a disproportionately high number of people with disabilities. IFDB GmbH ensures that your healthcare applications are verifiably accessible: audited by actual users of assistive technologies and backed by a legally reliable certificate.

A pharmacist explains the package leaflet for a medicine to a patient – accessible health information in accordance with the BFSG and WCAG 2.2
A doctor discussing treatment options with a seated patient – an accessible patient portal for hospitals and healthcare providers, compliant with WCAG 2.2
A healthcare professional at a clinic’s reception desk talking to a patient – digital accessibility for health insurance funds and healthcare organisations in accordance with the BFSG
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Digital barriers affect the most vulnerable first

  • The healthcare sector is rapidly digitally transforming its communication with patients. The crux: Those who are most in need of these services are the ones who most frequently encounter obstacles. Four areas stand out from our audit experience.
  • An appointment booking that falls through whilst on the way.
    Online booking has become the norm for many medical practices and clinics. If calendar widgets and confirmation steps are not designed to be accessible, urgently needed appointments remain out of reach – with immediate consequences for patient care.
  • Patient portals containing sensitive but inaccessible content.
    Test results, medication plans, laboratory results: this information is highly relevant and is often presented in tabular form. Without a clear semantic structure, it becomes unusable for screen reader users – particularly when it comes to data providing information about one’s own health.
  • Health information in a non-identifiable form.
    Information sheets, treatment guidelines and patient information leaflets in PDF format are part and parcel of everyday practice in the sector. Without accessible documentation, safety-related information remains inaccessible to some patients.
  • Complex applications without consistent keyboard navigation.
    From symptom-checker apps to hospital admission procedures: the more complex the application, the easier it is for keyboard pitfalls to arise that undermine assistive technologies.
A doctor in a white coat with a stethoscope is holding a tablet – inaccessible patient portals and digital appointment booking as an accessibility issue for clinics and healthcare providers according to BFSG and WCAG 2.2
BETWEEN THE BFSG, THE DUTY OF CARE AND PATIENT SAFETY

What requirements the healthcare sector must fulfill

Porträtfoto von Lukas Maximilian Langer, Gründer und Leiter Audit & Zertifizierung der IFDB GmbH
Lukas Maximilian Langer

Founder | Head of Audit & Certification

The legal landscape in the healthcare sector is complex. Customer-facing digital services – such as the online offerings of private clinics, pharmaceutical companies or digital healthcare providers – have been subject to the Accessibility Strengthening Act since 28 June 2025. The guidelines are WCAG 2.2 and EN 301 549.

Statutory health insurance funds and publicly funded institutions are also regularly subject to BITV 2.0, as they operate as institutions under state law. In practice, this means that many stakeholders must keep track of both sets of regulations at the same time.

Beyond compliance alone, there is another factor at play in the healthcare sector: the duty of care towards those who are particularly vulnerable. Anyone who provides health information carries a greater responsibility to ensure that it actually reaches its intended audience. Patient information that is inaccessible is therefore not only a violation of compliance requirements, but also potentially a risk to patient safety – with corresponding implications for liability and reputation.

OUR APPROACH FOR HEALTHCARE SECTOR

Four building blocks for a healthcare system that leaves no one behind

Healthcare applications combine a high degree of sensitivity with complex technology and strict data protection requirements. A reliable solution must meet all these requirements. The following four products are specifically designed to fulfil these needs.

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Access Ready®

carries out an in-depth audit of your patient portals and healthcare applications – using real users of assistive technologies such as JAWS, NVDA and VoiceOver. Critical processes, such as booking appointments and accessing test results, only reveal their weaknesses when put through their paces in a real-world scenario. The outcome is the IFDB certificate, which serves as reliable proof of your due diligence.

Access Doc®

accesses the sector’s safety-related documents: assessment forms, medication records, and patient information leaflets. Access Doc® converts these documents into the PDF/UA standard on a scalable basis – ensuring that health-critical information reaches every patient.

Access Guard®

continuously monitors your digital applications. New services, portal updates, regulatory changes – in the healthcare sector, there is constant change. The monitoring system identifies new barriers immediately and ensures your long-term compliance.

Access Protect®

provides the legal protection required in an environment where liability is a key concern. Subject to a successful audit, we contractually assume liability; should a formal warning be issued, IFDB experts and partner law firms will handle the matter. In an industry where a higher standard of due diligence applies, this offers a vital safeguard.

FROM THE INITIAL ASSESSMENT TO THE CERTIFICATE

Four steps to an accessible patient portal

  • Step 01 – The free assessment
    Access Score® automatically scans your application and, in just a few minutes, identifies where action is most urgently needed – with no obligation and at no cost to your organisation.
  • Step 02 – Checking the sensitive paths
    Our audit team goes through the processes of booking appointments, retrieving test results and navigating the portal manually, alongside users of assistive technologies. This reveals the barriers precisely where patient care is concerned.
  • Step 03 – Resolve and certify
    You will receive a prioritised audit report containing specific recommendations that are ready for implementation. Once all non-conformities have been resolved, the IFDB certificate will be issued – your proof for patients, funding institutions and regulatory authorities.
  • Step 04 – Long-term security.
    With Access Guard®, the level of protection achieved is maintained even as the system is expanded. Access Protect® complements the contractual protection against warnings – an aspect that is particularly important in the healthcare sector, where liability is a significant issue.

The Access Ready® Award – awarded to pioneers of genuine digital inclusion.

FAQ

Frequently asked questions about accessibility in the healthcare sector

In most cases, yes. Private-sector organisations such as pharmaceutical companies, private clinics and digital healthcare providers have been subject to the BFSG since June 2025. Statutory health insurance funds and public institutions are also subject to the BITV 2.0. Often, both sets of regulations apply simultaneously.

Because the target group includes a high number of people with disabilities – and because health-related information is relevant to patient safety. Patient information that is inaccessible is not only a violation of compliance requirements, but can also have a direct impact on patient safety.

Yes. Calendar widgets and multi-step booking processes are technically complex and are rarely implemented in a way that is accessible from the outset. We test these processes with real users to ensure that the appointment is genuinely accessible to everyone.

This tabular content requires a clear semantic structure to ensure that a screen reader can read it out correctly. This is precisely where our in-depth audit comes in, as automated scanners cannot reliably detect such structural flaws.

These security-related documents are also covered by the requirements. Access Doc® converts them to the PDF/UA standard on a scalable basis – from individual information sheets right through to entire document collections.

With the IFDB certificate from the Access Ready® audit. It documents a fully compliant audit process in accordance with WCAG 2.2 and serves as reliable proof of your duty of care – a factor that carries particular weight in the regulated healthcare sector.

With Access Guard®. Continuous monitoring automatically checks every adjustment and immediately reports any new barriers that arise – ensuring that new services also meet the established standard.

Once you have passed the audit, we will contractually assume liability. Should you receive a formal warning regarding a lack of accessibility, IFDB experts and partner law firms will handle the entire process – providing essential support in an liability-sensitive environment.

Health is a fundamental right. Digital accessibility should be too.

An accessible patient portal ensures that healthcare does not stop at the user interface – but reaches everyone who needs it. Let’s determine together where your digital healthcare services stand today.

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Digital health services and their responsibility towards vulnerable user groups

In the healthcare sector, the legal obligation to ensure accessibility goes hand in hand with an enhanced duty of care towards people who are particularly vulnerable. Since June 2025, private-sector organisations have been subject to the Accessibility Strengthening Act, whilst statutory health insurance funds and public bodies are additionally subject to BITV 2.0. The Federal Centre of Expertise on Accessibility provides detailed documentation of the specific requirements resulting from these regulations and how they should be implemented – from technical testing to the accessibility statement.

A free initial analysis will first assess the current status of your digital healthcare services, before a certified in-depth audit examines sensitive processes such as appointment booking and accessing test results in detail. As healthcare applications are constantly evolving, continuous monitoring ensures that the progress made is sustained – so that digital accessibility becomes a reliable feature of your care rather than remaining a snapshot in time.