What goes into the accessibility statement?

If your online shop or digital service falls under the BFSG, you have to provide accessibility information. Sounds simple — but in practice it causes a lot of confusion. Let’s clear it up.

First, the clarification: “statement” or “information”?

Almost everyone speaks of the “accessibility statement”. Legally, for companies that isn’t quite precise. The term accessibility statement (Erklärung zur Barrierefreiheit) originally comes from the German Disability Equality Act (§ 12b BGG) and applies there to public bodies — with an official template.

For private companies, the BFSG instead requires accessibility information (Barrierefreiheitsinformationen) — governed by § 14 BFSG, with the mandatory content in Annex 3. The good news: according to the legislative reasoning, this information largely corresponds to an accessibility statement. So you can roughly follow the familiar concept — but must observe a few specially prescribed points. In everyday use, “accessibility statement” remains an acceptable label; the law doesn’t prescribe a particular heading.

Who actually has to publish it?

Not every website. The obligation hits providers of consumer services that fall within the scope of the BFSG — such as online shops, booking portals or digital banking services. Not covered are:

  • Purely corporate websites without a consumer service (e.g. a mere company presentation)
  • Purely B2B offerings without a consumer link
  • Microenterprises with a service (fewer than 10 employees and no more than €2 million) — but this doesn’t apply to products

Not sure whether you’re included? Our BFSG check gives you a first assessment in three questions, and the BFSG overview explains the scope in detail.

This must go in — the mandatory information

The concrete minimum content is set by Annex 3 to the BFSG. According to Germany’s Federal Accessibility Agency, this includes in particular these points:

  • Explanation of conformance: the basis you rely on — the EN 301 549 standard and therefore the WCAG (Level AA).
  • How the requirements are met: a description of how your service implements the accessibility requirements — e.g. based on harmonised standards.
  • Explanations of the service: descriptions needed to understand how the service can be used accessibly.
  • Remaining barriers: honestly name what is (not yet) accessible — that’s part of a credible statement.
  • Responsible market surveillance authority: the body responsible for you must be stated.
  • Feedback & contact option: a way for users to report barriers or request accessible alternatives.
  • Date & currency: when the information was created or last checked — and update it regularly.

On top come the usual provider and consumer information. And yes: further content is allowed — as long as the statement stays perceivable and understandable.

It’s not just the content — the form matters too

How you provide the information is governed by § 12 of the BFSG Ordinance (BFSGV). Three things are central:

  • Through more than one sense: the two-senses principle — information should be accessible through more than one sensory channel.
  • Readable & understandable for screen readers: the text should be fully readable aloud and use clear, simple language.
  • Placed where it’s easy to find: clearly perceivable — like an imprint, privacy policy or terms.

The honest truth about generators

There are many free “accessibility statement generators”. Handy — but with a catch: most are based on the scheme for public bodies (§ 12b BGG), which only partly fits the BFSG. And many mandatory items are individual in nature and can’t be clicked together from text blocks.

No one but you knows which barriers still exist on your site and how you concretely meet the requirements.

A good generator takes the correct structure and the formal mandatory items off your hands — the substantive content you have to provide for your case. And that’s exactly where the circle closes: to honestly describe what isn’t accessible yet, you first have to know it.

A sequence that actually works

Check first, then declare. Anyone who writes a statement without knowing their own status risks empty phrases. A scan shows you which barriers exist — and delivers exactly the substance that belongs in a credible statement. The practical roadmap is in the guide make your website accessible.

Sources: Federal Accessibility Agency (FAQ on information about services, § 14 BFSG, Annex 3); BFSG Ordinance (BFSGV), § 12; plus publicly available legal commentary. As of June 2026. This article is for general information and is not legal advice — if in doubt, have your statement checked by a qualified professional.