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Applies toDEAT

BITV 2.0 (German Barrier-free Information Technology Ordinance)

BITV 2.0 governs how German federal bodies make websites, apps and embedded documents accessible.

· Category: Accessibility · Compliance-Kit

TL;DR

The Barrierefreie-Informationstechnik-Verordnung (BITV 2.0) of 12 September 2011, last amended on 24 October 2023, gives effect under § 12a(2) BGG to the accessible design of the information technology of federal public bodies in Germany. It covers websites, mobile applications, electronically supported administrative processes and graphical user interfaces (§ 2(1) BITV 2.0). Integrated documents form part of the website (§ 2a(1) BITV 2.0). Compliance is presumed where the offerings conform to harmonised standards cited in the Official Journal of the EU (§ 3(2) BITV 2.0).

What is BITV 2.0?

BITV 2.0 is the ordinance of the Federal Ministry of Labour and Social Affairs that governs how federal public bodies in Germany make their information technology accessible (introductory formula). § 12a(2) BGG refers to the ordinance issued under § 12d BGG for the details. Under § 12 BGG, federal public bodies are the bodies exercising public authority and certain institutions and associations financed or supervised by the Federation.

  • Scope (§ 2(1)): websites, mobile applications, electronically supported administrative processes including electronic records management, and graphical user interfaces. Intranets and extranets are covered (§ 2a(1)).
  • Documents (§ 2a(1) to (3)): integrated documents, videos and audio files form part of websites, mobile applications and administrative processes.
  • Standards (§ 3): offerings must be perceivable, operable, understandable and robust (para. 1). Conformity with harmonised standards cited in the Official Journal of the EU gives a presumption of compliance (para. 2). Anything not covered by those standards follows the state of the art (para. 3).
  • Sign language and Easy Language (§ 4): under Annex 2, the home page provides explanations in German Sign Language and in Easy Language on the main content, navigation, the accessibility statement and further such content on the site.
  • Accessibility statement (§ 7): accessible and machine-readable, reachable from the home page and every page (para. 1), containing the mandatory content of Section 1 of the Annex to Commission Implementing Decision (EU) 2018/1523 (para. 4), based on an actual assessment (para. 5) and updated annually and on every significant change (para. 6).
  • Monitoring (§ 8(1)): by the monitoring body under § 13(3) BGG, following Commission Implementing Decision (EU) 2018/1524.

Exemptions include archives that neither contain content needed for active administrative procedures nor were updated or revised after 23 September 2019 (§ 2(2) no. 2). BITV 2.0 has no cut-off exemption for older office files. The ordinance does not name WCAG or PDF/UA; for the standards link see EN 301 549.

Germany and Austria compared

Germany

BITV 2.0 applies only to federal public bodies (§§ 12, 12a(1) and 12d BGG). It does not cover public bodies of the Länder or municipalities; their state law is not covered in this entry. A federal body must reply to messages sent via the accessibility statement within one month at the latest (§ 12b(4) BGG). Where accessible design would impose a disproportionate burden, it may exceptionally refrain from it (§ 12a(6) BGG).

Austria

BITV 2.0 does not apply in Austria. Websites and mobile applications of the Federation and federally linked bodies fall under the WZG (§ 2(1) WZG); the Länder implement Directive (EU) 2016/2102 in state laws (FFG, legal framework). Unlike BITV 2.0, the WZG exempts office files published before 23 September 2018 that are not required for ongoing administrative procedures (§ 2(3)(a) WZG). Reports of shortcomings must be answered within two months (§ 4(3) WZG). The WZG also links the presumption of conformity to harmonised standards (§ 3(2) WZG).

Practical example

A federal agency publishes guidance leaflets as PDFs, application forms as Word files and presentation slides from PowerPoint on its website. Under § 2a(1) BITV 2.0 these files form part of the website and must meet the requirements of § 3. This also applies to older files. BITV 2.0 has no cut-off exemption for office files; § 2(2) no. 2 exempts archives only under narrow conditions. The ordinance does not set out the technical details; it refers to harmonised standards and the state of the art (§ 3(2) and (3)). In practice this concerns, for example, a tagged PDF, alternative text and a logical reading order. Content that is not fully accessible, including such documents, must be named in the statement, with reasons (§ 12b(2) no. 1 BGG). For an overview of duties and deadlines, see the guide to accessible PDFs. If you need to rework existing documents, you can have your documents made accessible.

Frequently asked questions

Does BITV 2.0 apply to companies?
No. BITV 2.0 is addressed to public bodies (§ 1(2) BITV 2.0), under the BGG to federal public bodies (§§ 12 and 12a(1) BGG). For commercial providers of websites and mobile applications, § 12a(7) BGG only provides that the Federation works towards target agreements. Duties for companies are covered in the entry on the BFSG.
Do PDFs on federal websites have to be accessible?
Yes. Integrated documents form part of the website (§ 2a(1) BITV 2.0). Exemptions include archives that neither contain content needed for active administrative procedures nor were updated or revised after 23 September 2019 (§ 2(2) no. 2 BITV 2.0) as well as certain reproductions from heritage collections and content of public service broadcasters under federal law (§ 2(2) nos. 1 and 3 BITV 2.0). In addition, under § 12a(5) BGG the duties of Section 2a BGG do not apply to the websites and mobile applications of federal public bodies under § 12 sentence 1 nos. 2 and 3 BGG that offer neither services essential to the public nor services aimed specifically at the needs of persons with disabilities or designed for them. Exceptionally, a body may refrain where accessibility would impose a disproportionate burden (§ 12a(6) BGG). The ordinance does not prescribe a specific format such as PDF/UA.
How quickly must a federal body reply to a report of a barrier?
Within one month at the latest (§ 12b(4) BGG). The feedback mechanism should be directly accessible from every page and easy to use (§ 7(2) BITV 2.0). In Austria, bodies covered by the WZG have two months (§ 4(3) WZG).

See also

Sources

  • Barrierefreie-Informationstechnik-Verordnung (BITV 2.0), last amended by Art. 1 of the Ordinance of 24 October 2023, Eingangsformel, § 1 Abs. 2, § 2 Abs. 1 und Abs. 2 Nr. 1 bis 3, § 2a Abs. 1 bis 3, § 3 Abs. 1 bis 3, § 4, § 7 Abs. 1, 2, 4 bis 6, § 8 Abs. 1, Anlage 2, gesetze-im-internet.de
  • Behindertengleichstellungsgesetz (BGG), § 12, § 12a Abs. 1, 2, 6 und 7, § 12b Abs. 2 Nr. 1 und Abs. 4, § 12d, § 13 Abs. 3, gesetze-im-internet.de
  • Web-Zugänglichkeits-Gesetz (WZG), current version, § 2 Abs. 1 und Abs. 3 lit. a, § 3 Abs. 2, § 4 Abs. 3, ris.bka.gv.at
  • FFG digitalbarrierefrei.at: Legal framework (Rechtlicher Rahmen), Abschnitt „Die 9 Landes-Gesetze setzen die WAD auf Landes-Ebene um“, digitalbarrierefrei.at

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

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.