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The Accessibility Strengthening Act places new requirements on associations regarding the digital accessibility of their websites. Many responsible parties wonder whether and to what extent the law applies to their association and how practical implementation can succeed.
This page provides an easy-to-understand overview of the structure of the Accessibility Strengthening Act for associations, explains the most important success criteria and highlights typical pitfalls. This gives you, as an association decision-maker, guidance and practical know-how to address your website’s accessibility in a targeted way.
The Accessibility Strengthening Act (BFSG) is a key set of rules that makes digital accessibility legally binding in Germany. For associations, this means meeting certain requirements for the accessibility of their websites. The structure of the BFSG is clearly organised: it contains general principles, specific requirements for digital products and services, and special provisions for certain organisations, which may also include associations.
For associations, the most relevant sections are those relating to digital services and the provision of information. These include, in particular, the requirements for accessible website design (Sections 3–5 BFSG) and the requirements for monitoring and enforcement (Sections 14–16 BFSG). Compared with other legal bases such as the Act on Equal Opportunities for Persons with Disabilities (BGG) or BITV 2.0, the BFSG is specifically geared towards implementing European requirements and forms an independent legal layer. In the legal hierarchy, the BFSG is regarded as a special law in the area of digital accessibility, applied in addition to existing regulations.
| Legal level | Relevance for associations |
|---|---|
| Accessibility Strengthening Act (BFSG) | Regulates digital accessibility; key provisions for association websites |
| BITV 2.0 / BGG | Supplementary requirements, mainly relevant for public-law organisations |
| European Directive (EU 2019/882) | Basis for the BFSG; sets minimum standards for digital accessibility |
In the association context, the Accessibility Strengthening Act aims to enable digital participation for everyone. At its core is the idea that no one should be excluded from access to an association’s information and services due to disabilities or limitations. Inclusion and equal participation thus become self-evident basic principles that also extend to digital communication.
For associations, this means that digital accessibility is not only a technical obligation but also an expression of social responsibility. While general accessibility goals are often broadly defined, the BFSG places particular emphasis on practical implementation for non-profit organisations. This primarily affects the design of websites and digital services so that people with different needs can actively participate in association life.
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For association websites, the Accessibility Strengthening Act sets specific success criteria based on the international WCAG 2.1 AA standards. These criteria relate, among other things, to the perceivability, operability, understandability and robustness of digital content. For assessment purposes, the key question is whether all essential functions and information are accessible to people with different impairments.
Compliance is measured by whether the individual success criteria have been implemented on the website. In the association context, this means that, for example, alternative text for images, a clear navigation structure and sufficient contrast are mandatory. Unlike other types of websites, association sites often place greater emphasis on volunteer structures and limited resources, which is taken into account in the assessment.
| Success criterion | Assessment for association websites |
|---|---|
| Alternative text for images | All relevant images must have descriptive text |
| Contrast and readability | Text and background must provide sufficient colour contrast |
| Navigation structure | Clear, easy-to-follow menu navigation for all user groups |
| Operability without a mouse | All functions must also be accessible via keyboard |
Accessibility testing of association websites under the BFSG takes place in several steps. First, associations can carry out a self-assessment to check compliance with the legal requirements internally. In addition, an external audit can be conducted by specialised service providers or experts. Supervisory authorities may also carry out random checks (monitoring) to verify implementation of the requirements.
For all testing procedures, careful documentation of results and measures is required. Associations should keep evidence of tests carried out, corrections made and, where applicable, external reports. Typical testing methods in the association context include checklists, automated tests, user feedback and the preparation of test reports, which should be updated regularly.
| Testing method | Features and benefits for associations |
|---|---|
| Self-assessment | Cost-effective, flexible, ideal for an initial assessment and regular review |
| External audit | Independent assessment, high level of expertise, suitable for complex websites and evidence obligations |
| Monitoring by authorities | Random checks, focus on compliance with the statutory minimum requirements |
| User feedback | Practical addition, direct indications of barriers from the target group |
A step-by-step approach is recommended for the practical implementation of digital accessibility in associations. First, those responsible should conduct an inventory of their own website to identify existing barriers. Subsequently, technical measures such as optimizing contrasts, retrofitting alternative texts, and improving keyboard accessibility are implemented. Organizationally, it makes sense to define responsibilities and schedule regular reviews to ensure long-term compliance with the requirements.
The prioritization of measures is based on the greatest benefit for users and the effort required for implementation. Initial steps such as revising central navigation areas, providing easy-to-understand content, and using accessible templates for new pages are particularly effective. Even with limited resources, visible improvements can be achieved through pragmatic solutions such as using automated testing tools or gathering feedback from the association’s community.
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The Accessibility Strengthening Act (BFSG) does not affect all associations equally. The decisive factor is whether an association acts as a service provider for the general public and operates a website or mobile application that goes beyond purely internal association life. Associations that are economically active or make services publicly accessible generally fall within the scope of the BFSG. In contrast, exceptions or simplifications often apply to purely volunteer-led or very small associations that do not pursue economic interests.
An important distinction also exists regarding micro-enterprises and public bodies: while micro-enterprises with fewer than ten employees and low annual turnover are exempt from the requirements under certain conditions, stricter specifications usually apply to public-law associations and federations. Special regulations particularly affect associations whose offers are intended exclusively for members or whose resources are very limited.
| Type of association | Applicability of the BFSG / Exceptions |
|---|---|
| Economically active association with a public website | BFSG generally applies, implementation of accessibility required |
| Volunteer-led, non-economic association | Often exceptions or simplifications, depending on the public offering |
| Micro-association (fewer than 10 employees, low turnover) | May fall under exemption rules, detailed review required |
| Public-law association/federation | Stricter requirements, accessibility usually mandatory |
In practice, many associations face specific challenges when implementing digital accessibility. Technical difficulties often arise from outdated websites, a lack of accessible templates, or missing know-how in dealing with web standards. Organizationally, there is often a lack of clear responsibilities, and volunteer structures make continuous content maintenance difficult. Financial bottlenecks can also delay or prevent the implementation of necessary adjustments.
A common mistake is the misinterpretation of legal requirements, such as when individual measures are considered sufficient even though a holistic approach is necessary. In practice, it is often seen that alternative texts for images are missing, forms cannot be operated with the keyboard, or important information is provided exclusively as a PDF. Failing to regularly collect user feedback can also lead to existing barriers remaining undiscovered.
In the association context, numerous interfaces arise between the Accessibility Strengthening Act and other legal requirements. Overlaps with BITV 2.0, which primarily applies to public bodies, and the General Data Protection Regulation (GDPR), which sets requirements for handling personal data on association websites, are particularly relevant. Association law can also influence the design of digital offerings, for example, regarding responsibility for content or member involvement.
WCAG 2.1 AA forms the technical basis for most accessibility requirements and is used in both the BFSG and other standards. It is therefore important for associations to know the respective areas of application and to coordinate the requirements meaningfully. A clear overview of the most important interfaces helps to avoid duplication of work and to fulfill legal requirements efficiently.
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The accessibility statement is a central element for association websites under the BFSG. It serves to transparently explain the extent to which an association’s digital presence is accessible and what measures have been taken for improvement. For associations, this results in both content and formal requirements: the statement must be easy to find, understandable, and up-to-date. It should name the most important barriers, offer contact options for feedback, and document a clear status of accessibility.
The importance of the accessibility statement goes beyond the mere duty to inform. It is proof of the association’s efforts and builds trust with users. When creating it, it is recommended to regularly check the status of implementation and update the statement accordingly. Templates and assistance can significantly reduce the effort for associations.
| Requirement | Implementation for association websites |
|---|---|
| Easy findability | Placement in the main menu or footer, clearly labeled |
| Content transparency | Specification of achieved and still open accessibility goals, explanation of exceptions |
| Contact option | Provision of an email address or an online form for feedback |
| Regular updates | At least annual review and adjustment of the information |
The Accessibility Strengthening Act applies in particular to associations that provide services or information to the general public, regardless of their size. Commercially active, non-profit and public-law associations are typically affected. Special cases include associations with mixed models, for example where both internal and public services exist. An individual assessment is also advisable for association cooperations or umbrella organisations, as different rules may apply.
The Accessibility Strengthening Act requires associations to make their digital services accessible to everyone. The legal requirements particularly affect associations that present themselves to the public through their websites or digital services. This involves taking technical, organisational and legal requirements into account and implementing them in a targeted manner.
Key aspects include aligning with the WCAG 2.1 AA success criteria, preparing a transparent accessibility statement, and regularly reviewing and documenting the measures. Even with limited resources, associations can make significant progress by prioritising, using proven practical tools, and involving external support.
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Small associations can meet the requirements of the Accessibility Strengthening Act by prioritising key measures and using available resources in a targeted way. Automated testing tools, free checklists and user-friendly templates provide quick support. For more complex tasks, involving external experts or exchanging experience with other associations is recommended.
Small associations can meet the requirements of the Accessibility Strengthening Act by prioritising key measures and using available resources in a targeted way. Automated testing tools, free checklists and user-friendly templates provide quick support. For more complex tasks, involving external experts or exchanging experience with other associations is recommended.
For most associations, the key deadline is 28 June 2025: by this date, websites and digital services must meet the requirements of the Accessibility Strengthening Act. Transitional periods may vary depending on the association’s structure and the type of services offered. Public-law and commercially active associations are generally affected immediately, while exceptions or longer transitional periods may be possible for small or purely volunteer-run associations.
Associations can raise members’ awareness of digital accessibility by providing targeted information about the benefits and legal requirements. Training sessions, workshops and involving affected individuals promote understanding. References to monitoring procedures and the option to file complaints highlight the relevance of the topic in day-to-day association work.
If an association does not implement the Accessibility Strengthening Act, complaints or reports from affected individuals and monitoring by authorities may follow. This can lead to requests for remediation. To prevent this, open internal communication, targeted training and active member involvement are recommended to embed accessibility in everyday association work.
