Law & standards
Norms & standards at a glance – who refers to whom?
EU directive, BGG, BITV, BFSG, EN 301 549, WCAG, PDF/UA: the tangle unravelled once and for all.
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The web of standards seems impenetrable – but it is a simple chain: laws say WHO has to act, standards say HOW.
The chain for public sector bodies
- EU Directive 2016/2102 – obliges all public sector bodies in the EU to make their websites, apps and file formats accessible.
- Sections 12 et seq. BGG – the German transposition in the Disability Equality Act (Behindertengleichstellungsgesetz) for federal authorities. The federal states and municipalities transpose the directive through their own state laws and ordinances (details for municipalities).
- BITV 2.0 – the ordinance (Barrierefreie-Informationstechnik-Verordnung, Germany's federal ordinance on accessible information technology) that puts the BGG into concrete terms. It does not itself say what to do technically, but refers to …
- EN 301 549 – the European standard for accessible ICT. Chapter 10 deals with documents (“non-web documents”) and, for the content, refers to …
- WCAG – the W3C's Web Content Accessibility Guidelines, conformance level AA. The current EN 301 549 V3.2.1 refers to WCAG 2.1; V4.1.1, published in September 2026, is aligned with WCAG 2.2 (WCAG 2.2 and EN 301 549 for PDFs). For the technical implementation in PDF there is …
- PDF/UA (ISO 14289-1 and -2) – the PDF-specific standard. EN 301 549 does not mandate it, but in testing practice it is the benchmark for the technical side of a PDF; the content-related WCAG points (alt text, reading order, contrast) come on top.
The chain for the private sector
- European Accessibility Act (EU 2019/882) – the EU directive for products and services on the consumer market.
- BFSG – the German Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz), in force since 28 June 2025. It covers e-commerce, banking services, e-books and passenger transport, among others – and can therefore also affect municipal companies, such as savings banks (Sparkassen) or public transport operators (more on the BFSG).
- Technical benchmark: again EN 301 549 → WCAG → PDF/UA.
One sentence for the file note
“Our PDF documents are checked automatically against PDF/UA-1 and WCAG 2.2 (AA), and their content is spot-checked by hand; in doing so, we follow the technical requirements of BITV 2.0 in conjunction with EN 301 549.” – This one sentence answers most questions from elected officials.
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