Accessibility in the public sector
Authorities, public universities and other public bodies are subject to legal accessibility requirements for their websites, apps and digital documents. This page outlines the key rules and explains what they mean for accessible PDFs.
General overview, not legal advice. Whether and how the rules described here apply depends on the individual case.
EU, federal and state level
The basis is Directive (EU) 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies. Germany has transposed it at two levels:
- Federal level: the Behindertengleichstellungsgesetz (BGG) and the Barrierefreie-Informationstechnik-Verordnung (BITV 2.0) apply to federal public bodies.
- States: state and municipal administrations, state universities and other bodies are covered by the laws and regulations of the individual states. These rest on the same European rules but can differ in detail.
At a glance
- EU directive
- (EU) 2016/2102
- Federal level
- BGG and BITV 2.0
- States
- Their own laws and regulations
- Harmonised standard under the EU directive
- EN 301 549 (harmonised standard)
- Application deadlines
- Websites since 2019 or 2020, mobile apps since 2021
Which bodies are covered
Public bodies are mainly the authorities and administrations of the federal government, the states and municipalities. Many institutions that serve the general interest and are mainly publicly funded or supervised are covered too. Which rules apply depends on who runs the body:
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Federal authorities and institutions
For federal authorities and many federal institutions, the BGG and BITV 2.0 form the relevant legal framework.
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State and municipal administrations
The law of the respective federal state applies; the specific requirements vary from state to state.
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Universities
Public universities are generally subject to the law of their federal state. Federal institutions are covered by federal law.
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Other public institutions
For example public-law corporations and institutions. Classification follows the relevant federal or state law.
What is required
Content should be perceivable, operable, understandable and robust. For this, BITV 2.0 refers to harmonised standards. In practice, this means EN 301 549. EN 301 549 in turn incorporates the WCAG success criteria at level AA. Among other things, this covers:
- Websites and mobile apps
- Documents published there, such as PDFs and office files
- At federal level, also intranet content and electronically supported administrative processes
BITV 2.0 also provides for explanations in German Sign Language and in Easy Language (Leichte Sprache).
Exemptions in the directive (selection)
- Certain office files, including PDF documents of this kind, published before 23 September 2018, unless they are needed for active administrative processes
- Third-party content that the body neither funds nor controls
- Archives that are not edited after 23 September 2019
How the federal government and the states have adopted these exemptions can differ in detail.
Accessibility statement and feedback
Public bodies are generally required to provide an accessibility statement (Erklärung zur Barrierefreiheit) for their websites and apps and to keep it up to date. It usually contains:
- the compliance status: fully, partially or not compliant
- the content that is not accessible, and why
- a feedback mechanism through which users can report barriers and request content in an accessible form
- a reference to the conciliation or enforcement procedure
Inaccessible PDFs may be among the limitations listed in such statements. Making documents accessible can reduce that share accordingly.
How accessibility is checked
Compliance with the accessibility requirements is monitored regularly. In addition, users can report barriers and initiate further procedures.
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Regular monitoring
The websites and apps of public bodies are reviewed for accessibility at regular intervals under the legal framework. At federal level, this is the responsibility of the federal monitoring body for the accessibility of information technology; the states have their own structures.
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Feedback and further steps
Users who encounter barriers can first contact the public body through its feedback mechanism. If the issue is not resolved, further procedures may be available depending on the applicable legal framework, such as conciliation or enforcement procedures. At federal level, the conciliation body under the BGG is responsible.
PDFs and office documents
Documents are part of a website’s content when they are offered there for download. For public bodies they are therefore covered in principle, often in large numbers. Typical examples:
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Forms and applications
Forms that are filled in or printed, and the guidance that comes with them.
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Statutes, regulations and notices
For example university examination and study regulations, or official notices from municipalities.
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Reports and brochures
Annual reports, budgets, information brochures and leaflets.
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Teaching and information material
Lecture notes, module handbooks, course catalogues and information for students and staff.
Setting priorities
New documents should be accessible from the start. In the existing collection, it pays to begin with frequently used documents and those needed for administrative procedures.
Frequently asked questions
Does BITV 2.0 apply to our university?
That depends on who runs it. BITV 2.0 applies to federal public bodies. State universities are usually covered by state law, which sets comparable requirements and often refers to BITV 2.0 or EN 301 549.
Do all older PDFs have to become accessible?
Not necessarily. The EU directive exempts office file formats published before 23 September 2018, unless they are needed for active administrative processes. Documents published later are covered in principle. Check how your state law implements this.
How does this differ from the BFSG?
The public-sector rules apply to public bodies. The BFSG concerns businesses that offer certain products and services to consumers. Both build on similar requirements. More on the BFSG page.
Does EqualDoc help with the accessibility statement?
EqualDoc does not write accessibility statements and issues no certificates. Its report shows, for each document, what was remediated and checked and which points remain open. That can help you assess the state of your documents.
Remediate document collections step by step
Try EqualDoc with a document from your institution. EqualDoc remediates PDFs automatically, checks them against PDF/UA and EN 301 549 and lists open points in its report.