In December 2016, EU Directive 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies was published in the Official Journal of the European Union.
This topic remains relevant today, with another major milestone approaching in September.
The goal is clear: people with disabilities must not be disadvantaged in accessing essential public information.
Because legal texts are not always easy to understand, we’ve summarized the key points for you. This will help you determine whether your website, app, intranet, or extranet falls under this regulation:
Who Is Required to Act?
Öffentliche Stellen: Staatliche Stellen, Gebietskörperschaften, Verbände mehrerer Gebietskörperschaften, Einrichtungen des öffentlichen Rechts
Public sector bodies, including:
- Government authorities
- Regional or local authorities
- Associations of such authorities
- Public law institutions
Also included are organizations entrusted by the state with public functions, such as:
- Special-purpose associations (e.g., street cleaning or waste/water management authorities)
- Statutory health insurers and medical associations
- Universities, colleges, and universities of applied sciences
- Social security institutions
- Regional associations
- Chambers of commerce and industry, chambers of crafts, bar associations, medical chambers, trade associations, and guilds
- Public banks, state asset management offices, financial services
- Schools and kindergartens (only in relation to online administrative functions such as digital form processing or electronic recordkeeping – including documents, videos, audio files)
- Public transportation services
- Foundations
Explicitly Excluded Are:
- Public broadcasters
- Audio and video livestreams
- NGOs that do not provide essential services to the public
- School or kindergarten websites, unless they offer online administrative functions
- Historic cultural archives
- Old websites and apps used only for archiving, without updates
- Non-accessible features that have accessible alternatives — while not ideal, are allowed in exceptional cases
What Must Be Done?
Public digital offerings must be made accessible, including:
- Web-based platforms (including intranets and extranets)
- Native mobile applications (apps)
- Office file formats (e.g., Word documents, PDFs)
Content Must Be:
Perceivable
- Provide text alternatives for non-text content
- Provide captions and alternatives for audio and video content
- Ensure content is adaptable and compatible with assistive technologies
- Use sufficient contrast
Operable
- Ensure all functions can be accessed via keyboard
- Give users enough time to read and use content
- Avoid content that could trigger seizures
- Help users navigate and locate content
Understandable
- Ensure text is readable and clear
- Ensure content appears and functions predictably
- Help users avoid and correct errors
Robust
- Maximize compatibility with current and future technologies
The Following Must Be Provided in German Sign Language and Easy Language:
- Summary of key website content
- Navigation instructions
- Explanation of key elements in the accessibility statement
- Reference to other content in German Sign Language and Easy Language available on the site
- See official guidelines for sign language and Easy Language here (in german).
We’re happy to discuss technical implementation details with you.
Additional Requirements for Websites:
- Accessibility Statement
- Specify which parts of the site/app are not yet fully accessible and why
- Indicate whether the assessment was internal or external
- If applicable, provide links to accessible alternatives
- The statement must be available from every page; for apps, it must be published where the app is downloaded or on the public body’s website
- Must be updated annually or after significant changes to the website or app
- Feedback Mechanism
- A function must be integrated into the website/app allowing users to report accessibility barriers (response required within 1 month)
- Must be accessible from every page; in apps, integration into navigation is sufficient
- Reference to the BGG Arbitration
Compliance Deadlines
- 23. September 2019: Neue Intranets und Extranets müssen barrierefrei sein
- Ältere Websites erst, wenn sie grundlegend überarbeitet werden
- June 23, 2021: Native (non-web-based) mobile apps
- September 23, 2020: Websites launched before September 23, 2018
- Also applies to pre-recorded audio and video (not livestreams)
- September 23, 2019:
- Websites, office documents, and PDFs published after September 23, 2018
- Also includes existing office documents/PDFs that are part of active administrative procedures (e.g., forms for business registration, insurance applications)
- September 23, 2019:
- New intranets and extranets must be accessible
- Older systems only if substantially revised
Are You Affected or Interested in Accessibility as a Service?
If you're impacted by these regulations—or simply want to make your digital offerings more accessible—take a look at our successful example with Paritätischer Wohlfahrtsverband Niedersachsen e.V.
Our experts at DRIVE are happy to support you and your organization.
Get in touch: pole-position@drive.eu. Together, we can reach any goal.
