Accessibility in software: Understanding public sector requirements

> Key Takeaway: Starting June 2025, the Accessibility Strengthening Act (BFSG) also requires the public sector to provide fully accessible digital offerings.

For software, this means: WCAG 2.1 AA compliance, screen reader compatibility, keyboard navigation, and documented accessibility statements as mandatory acceptance criteria.

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*February 2026 *

In an increasingly digitized world, barrier-free access to information and services is not only a matter of social responsibility but also a legal necessity. In particular, the public sector is obliged to make its digital offers, including the Software used, accessible to all citizens.

But what does accessibility mean in the context of public sector software? This article gives a comprehensive overview.

Basic Laws: The BITV 2.0 as a Scale

Short: The central legal basis for digital accessibility in the German federal administration is the Barrierefree Information Technology Regulation (BITV 2.

The central legal basis for digital accessibility in the German federal administration is the Barrierefree Information Technology Regulation (BITV 2.0). This regulation specifies the requirements of the Disabled Compensation Act (BGG) and provides clear standards for the design of information technology.

The aim is to ensure comprehensive and in principle unrestricted accessibility for people with disabilities.

BITV 2.0 applies to all public authorities of the federal government and includes websites, mobile applications, electronically supported administrative processes and graphical program surfaces. This is the key guide for the development and procurement of public sector software.

The core requirements of BITV 2.0

The regulation places a number of key requirements on accessibility, which are based on international standards. Developers and IT managers must take these points into account when designing and implementing software solutions:

• Conformity with EN 301 549: BITV 2.0 refers to the harmonised European standard EN 301 549. This standard sets out detailed technical requirements for the accessibility of ICT products and services. Compliance with this standard creates the assumption of conformity with legal requirements.
• Contact of the state of the art: Beyond EN 301 549, the software must comply with the current state of the art. This means that proven and modern technological solutions must be used to achieve the best possible accessibility. These include, for example, the standards of the DIN EN ISO 9241 series for the ergonomics of the human system interaction.
• The highest possible level of accessibility: For particularly important areas such as central navigation and entry pages or interactive processes (e.g. online forms), BITV 2.0 calls for the highest possible level of accessibility. In practice, this often means fulfilling the demanding success criteria of the AAA level of the Web Content Accessibility Guidelines (WCAG).
• **Deployment of information in light language and denomination

References and further reading

Short: The following independent references complement the topics in this article:

The following independent references complement the topics in this article:

• Bitkom – German digital industry association
• German Federal Office for Information Security (BSI)
• European Commission – Digital strategy
• MDN Web Docs (Mozilla)
• W3C – World Wide Web Consortium

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