---
id: RISK-POL-0011
type: legal-policy
title: "Accessibility of digital services"
regime: "BFSG (European Accessibility Act, Directive 2019/882), EN 301 549 / WCAG"
status: dormant
activates_when: "a consumer-facing digital service or product is offered in Germany — e-commerce, banking, e-books, ticketing, or a consumer app"
owner: risk-nexus
written: "2026-08-20"
cadence: 1h
clean_streak: 1
last_checked: "2026-09-22T06:26:29Z"
next_check: "2026-09-22T07:26:29Z"
checked_by: "worsch"
---

# RISK-POL-0011 — accessibility

**Dormant, and the most likely of the dormant set to activate.** The estate has
a consumer domain and design work in it; the day any of that is offered to
consumers in Germany, this applies in full and without a grace period for new
services.

## Why it is written before it is needed

Accessibility cannot be retrofitted cheaply. It constrains component choice,
colour, focus handling, form semantics and content structure — decisions taken
early and expensively reversed. A policy retrieved at launch is a rebuild; a
policy read at design time is a constraint like any other.

That is the whole argument for this catalogue existing, and this is the entry
that demonstrates it.

## What it requires, in outline

- Conformance to the harmonised standard (EN 301 549, which carries WCAG at
  level AA) for the service's interface, and for its documentation and support.
- An **accessibility statement**, published, saying what conforms and what does
  not.
- Accessibility considered in the product's own conformity assessment, with
  records kept.

Micro-enterprises providing services are outside scope, which is a real
exemption and also a fragile one to build on — it disappears with headcount or
turnover, and the product does not become accessible by growing.

## What it requires of systems

Design-time, not launch-time: semantic markup, keyboard operability, contrast
and focus visibility, form labelling and error identification, no
information-by-colour-alone, captions and alternatives for media. Plus a way to
**test** these that runs before release rather than at it.

## Evidence that would show this is met

A conformance assessment against EN 301 549; a published accessibility
statement; automated and manual test results in the release path.

Nothing here binds any repo today. `whynot-design` and the consumer-domain
repos are where it will land, and naming the owner is theirs, not the
register's.

**2026-09-22 review.** The policy stays dormant. No consumer-facing digital
service offered in Germany is on record. The micro-enterprise exemption for
services is still the fragile basis described above.

## Reviews

- **2026-09-22** — clean check: Dormant: no consumer-facing service on record. Cadence instant → 1h (1 clean in a row); next check 2026-09-22 07:26Z.