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Accessibility monitoring body

The monitoring body regularly checks whether websites, apps and documents of public bodies are accessible.

· Category: Accessibility · Compliance-Kit

TL;DR

A monitoring body checks whether the websites and mobile applications of public bodies meet the accessibility requirements and prepares the report to the European Commission. Implementing Decision (EU) 2018/1524 sets the methodology, with in-depth and simplified monitoring (Art. 5). In Germany, the Überwachungsstelle des Bundes für Barrierefreiheit von Informationstechnik is responsible at federal level (§ 13(3) BGG, § 8 BITV 2.0). In Austria, the FFG monitors federal websites and apps (§ 5(1) and (2) WZG).

What is a monitoring body (accessibility monitoring)?

A monitoring body checks for the Member State whether the websites and mobile applications of public bodies meet the accessibility requirements. Its results feed into the report that the Member State submits to the European Commission (Art. 8(1) of Implementing Decision (EU) 2018/1524). The Implementing Decision sets out the monitoring methodology and the arrangements for reporting (Art. 1). The yardstick is the standards and technical specifications under Art. 6 of Directive (EU) 2016/2102 (Art. 4(1) of the Implementing Decision).

  • Two methods: in-depth monitoring verifies compliance with all requirements; simplified monitoring detects non-compliance (Art. 5(a) and (b)). The simplified method uses automated tests to the greatest extent possible (Annex I point 1.3.2).
  • Sample: the number of websites monitored depends on the population of the Member State (Annex I point 2.1.1). Where they exist, the sample covers state, regional and local websites and websites of other bodies governed by public law (Annex I point 2.2.2). Organisations representing persons with disabilities are consulted on the selection (Annex I point 2.2.4).
  • Frequency: after the first monitoring period (for websites 1 January 2020 to 22 December 2021), monitoring takes place every year, from 1 January to 22 December (Art. 3(2) and (5)).
  • Feedback: where deficiencies are found, public bodies receive data within a reasonable period that helps them correct the deficiencies (Art. 7).
  • Report: the Member States submit the report to the Commission in an accessible format and publish it (Art. 8(1), Art. 11).

Germany and Austria compared

Germany

At federal level, the Überwachungsstelle des Bundes für Barrierefreiheit von Informationstechnik (Federal Monitoring Body for Accessibility of Information Technology) is responsible. It is set up within the Bundesfachstelle Barrierefreiheit (§ 13(3) BGG), which is based at the Deutsche Rentenversicherung Knappschaft-Bahn-See (§ 13(1) BGG). Its tasks: periodic monitoring, advising public bodies on test results, evaluating the reports of the supreme federal authorities and the Länder, preparing Germany's report to the Commission and supporting the conciliation body under § 16 BGG (§ 13(3) sentence 2 nos. 1 to 5 BGG).

§ 8 of the BITV 2.0 governs the procedure. The body tests in line with Art. 1 to 7 and Annex I of the Implementing Decision (para. 1). It records the requirements under Art. 6 of Directive (EU) 2016/2102 and the additional requirements under § 12a BGG and the BITV 2.0 separately (para. 2), may carry out ad hoc and repeat tests (para. 3) and consults organisations of persons with disabilities on the selection (para. 4). It drafts the report to the Commission itself (§ 9(1) BITV 2.0). The supreme federal authorities and the Länder report to it every three years, first by 30 June 2021. The Länder report on the results of their own monitoring (§ 12c(1) and (2) BGG).

Austria

For websites and apps of the federal government and federally linked institutions (§ 2(1) WZG), the Austrian Research Promotion Agency (FFG) is responsible as long as no regulation designates another body (§ 5(2) WZG). It monitors on a recurring basis and prepares a report every third year, which it submits to the Commission together with the reports of the Länder. The bodies concerned must cooperate (§ 5(1) item 1 WZG). The FFG also receives complaints and issues recommendations for action where a complaint is justified (§ 5(1) item 2 WZG). It coordinates the tests with the Länder (§ 5(3) WZG). The Länder and municipalities are covered by the state laws. The article Accessibility in municipalities: Austria's state laws gives an overview.

Practical example

In-depth monitoring also covers documents: at least one relevant downloadable document for each type of service and each other main purpose, where available (Annex I point 3.2(e) of Implementing Decision (EU) 2018/1524). The pages with the accessibility statement and the feedback mechanism are tested as well (point 3.2(c)).

A federal ministry might, for example, offer application forms as PDF, information sheets as Word files and presentation slides as PowerPoint. If the website is drawn into the sample for in-depth monitoring, any of these documents may be tested. So list your documents by service and remediate the most important ones first. The monitoring body may also use evaluation reports submitted by the public body itself. Conditions include that it is the latest detailed report and that the evaluation was carried out no more than three years before the monitoring and in line with Annex I points 1.2.1 to 1.2.4 and point 3 (Annex I point 1.2.5). The article How monitoring bodies test accessibility explains how the tests work. If you would rather not process the stock yourself, you can have accessible documents prepared for you.

Frequently asked questions

Does the monitoring body also test PDF and Word documents?
Yes. In-depth monitoring includes at least one relevant downloadable document for each type of service and each other main purpose, where available (Annex I point 3.2(e) of Implementing Decision (EU) 2018/1524). The provision does not name a specific file format.
Who monitors the websites of the Länder and municipalities in Austria?
The WZG only covers websites and apps of the federal government and federally linked institutions (§ 2(1) WZG). The Länder and municipalities are covered by the state laws, which provide for bodies for monitoring and complaints. The FFG includes the reports of the Länder in its report to the Commission (§ 5(1) item 1 WZG) and coordinates the tests with the Länder (§ 5(3) WZG).
How often is monitoring carried out and reported?
Monitoring takes place every year (Art. 3(2) and (5) of Implementing Decision (EU) 2018/1524). In Austria, the FFG prepares a report every third year (§ 5(1) item 1 WZG). In Germany, the supreme federal authorities and the Länder report to the federal monitoring body every three years, first by 30 June 2021 (§ 12c(1) and (2) BGG).

See also

Sources

  • Commission Implementing Decision (EU) 2018/1524: monitoring methodology and reporting, Art. 1, Art. 3 Abs. 2 und 5, Art. 4 Abs. 1, Art. 5, Art. 7, Art. 8 Abs. 1, Art. 11; Anhang I Nr. 1.2.5, Nr. 1.3.2, Nr. 2.1.1, Nr. 2.2.2, Nr. 2.2.4, Nr. 3.2 lit. c und e, eur-lex.europa.eu
  • Behindertengleichstellungsgesetz (BGG), German Disability Equality Act, § 12c Abs. 1 und 2, § 13 Abs. 1 und 3, gesetze-im-internet.de
  • Barrierefreie-Informationstechnik-Verordnung (BITV 2.0), German Barrier-free Information Technology Ordinance, § 8 Abs. 1 bis 4, § 9 Abs. 1, gesetze-im-internet.de
  • Web-Zugänglichkeits-Gesetz (WZG), Austrian Web Accessibility Act, consolidated version, § 2 Abs. 1, § 5 Abs. 1 Z 1 und 2, § 5 Abs. 2 und 3, ris.bka.gv.at

Legal status of the sources checked: 19 October 2026 (RIS, gesetze-im-internet.de, EUR-Lex)

Practitioner note: This article is practice-oriented compliance documentation, not legal advice. We are compliance specialists, not a law firm. For legally binding advice, consult an admitted lawyer.