IT Governance and Compliance

    Digital accessibility

    By Redaktion techport.ai, IT-Beratung · Last updated on

    The German Accessibility Act has applied since 28 June 2025. It implements a European directive and obliges companies to offer certain products and services to consumers in an accessible form. In scope are, among others, online shops, booking journeys, customer portals and apps through which consumers conclude contracts.

    For many mid-sized companies this was not a topic for a long time, because they did not see themselves as affected. The decisive question, however, is not the industry but whether you provide a service in electronic commerce to consumers.

    How you notice it

    • There is no statement on whether your website or shop falls under the act.
    • The website was built years ago and has been maintained in content but not technically.
    • Forms cannot be operated without a mouse, error messages are marked only by colour.
    • When a complaint about barriers arrives, there is no procedure for handling it.

    Why this happens

    Accessibility was long regarded as a requirement for public bodies. Its extension to private providers came with a transition period that felt far away, and then met websites that had grown technically. On top of that, accessibility cannot be seen: a page can look modern and be unusable for people working with a keyboard or a screen reader. Without an assessment, nobody operating the page with a mouse notices.

    How we go about it

    1. Clarify whether you are in scope. We check whether your offerings fall under the act and whether an exemption applies, for example for micro-enterprises providing services. The result is documented with reasoning even where it is negative.
    2. Assess rather than assume. We have the affected offerings assessed against the governing requirements, with automated tools for breadth and manual testing for what tools cannot detect, particularly keyboard operation, focus handling and comprehensibility.
    3. Fix and prioritise. We fix in the order of effect: first the paths through which contracts are concluded, meaning search, basket, forms, sign-in and payment, then the rest.
    4. Anchor it permanently. We add accessibility to the requirements for new content and systems, train the people who maintain content, and set up the feedback procedure the act provides for.

    What you gain

    • Legal certainty instead of an open question with a fine risk.
    • Offerings usable by more people, including older customers.
    • Better usability and findability for everyone else too.

    From our projects

    The bulk of findings in a first assessment can be fixed with manageable effort: missing labels on form fields, insufficient contrast, error messages marked only by colour, and controls unreachable by keyboard. What is laborious is usually a small number of areas, frequently embedded third party components such as booking journeys, map services or payment dialogues that you do not control yourself. We therefore clarify early which parts come from third parties and add the requirement to the contracts with those providers.

    Good to know

    The German Accessibility Act has applied since 28 June 2025. It covers manufacturers, distributors and importers of certain products and providers of services to consumers, including electronic commerce explicitly. For services there is an exemption for micro-enterprises with fewer than ten employees and no more than two million euros in annual turnover. That exemption does not apply to products. The requirements follow the European standard EN 301 549, which essentially refers to the Web Content Accessibility Guidelines. Market surveillance sits with a central body of the federal states, breaches can be fined, and consumer associations can pursue infringements.

    Häufige Fragen

    Does the act also apply to our purely informational company website?

    For a website that only provides information and through which no consumer contracts are concluded, it generally does not. As soon as an order, a booking, a contract conclusion or a customer account for consumers is possible, electronic commerce is affected. The distinction in the individual case belongs reviewed legally and documented.

    Is an automated test enough?

    No. Automated tools find a portion of the problems, typically contrast, missing alternative text and structural errors. Keyboard operability, sensible order, understandable error messages and usability with assistive technology can only be checked manually. A combination of both is the usual route, complemented by testing with people who actually use assistive technology.

    Let us talk about Digital accessibility

    In a thirty minute first call we work out where your biggest lever sits and whether we are the right people for it.

    Further reading

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