tegwick
5a7e4ac2d4
RISK-REG-0001: eight-year voucher period (BEG IV) confirmed against secondary sources and §147 AO. RISK-POL-0009/0002: positions unchanged; new restore evidence noted as partial. RISK-POL-0012: receiving duty still unowned; issuing phase-in dates added, flagged for confirmation. RISK-POL-0011: stays dormant. Co-Authored-By: Claude Opus 5 <noreply@anthropic.com> Assistant: claude-code Assistant-Model: opus Assistant-Process: 6903@bnt-lap001 Assistant-Session: 8319e8a8-ffa6-4eb3-b8bf-b29945628f89
69 lines
2.8 KiB
Markdown
69 lines
2.8 KiB
Markdown
---
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id: RISK-POL-0011
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type: legal-policy
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title: "Accessibility of digital services"
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regime: "BFSG (European Accessibility Act, Directive 2019/882), EN 301 549 / WCAG"
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status: dormant
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activates_when: "a consumer-facing digital service or product is offered in Germany — e-commerce, banking, e-books, ticketing, or a consumer app"
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owner: risk-nexus
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written: "2026-08-20"
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cadence: 1h
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clean_streak: 1
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last_checked: "2026-09-22T06:26:29Z"
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next_check: "2026-09-22T07:26:29Z"
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checked_by: "worsch"
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---
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# RISK-POL-0011 — accessibility
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**Dormant, and the most likely of the dormant set to activate.** The estate has
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a consumer domain and design work in it; the day any of that is offered to
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consumers in Germany, this applies in full and without a grace period for new
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services.
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## Why it is written before it is needed
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Accessibility cannot be retrofitted cheaply. It constrains component choice,
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colour, focus handling, form semantics and content structure — decisions taken
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early and expensively reversed. A policy retrieved at launch is a rebuild; a
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policy read at design time is a constraint like any other.
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That is the whole argument for this catalogue existing, and this is the entry
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that demonstrates it.
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## What it requires, in outline
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- Conformance to the harmonised standard (EN 301 549, which carries WCAG at
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level AA) for the service's interface, and for its documentation and support.
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- An **accessibility statement**, published, saying what conforms and what does
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not.
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- Accessibility considered in the product's own conformity assessment, with
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records kept.
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Micro-enterprises providing services are outside scope, which is a real
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exemption and also a fragile one to build on — it disappears with headcount or
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turnover, and the product does not become accessible by growing.
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## What it requires of systems
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Design-time, not launch-time: semantic markup, keyboard operability, contrast
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and focus visibility, form labelling and error identification, no
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information-by-colour-alone, captions and alternatives for media. Plus a way to
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**test** these that runs before release rather than at it.
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## Evidence that would show this is met
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A conformance assessment against EN 301 549; a published accessibility
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statement; automated and manual test results in the release path.
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Nothing here binds any repo today. `whynot-design` and the consumer-domain
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repos are where it will land, and naming the owner is theirs, not the
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register's.
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**2026-09-22 review.** The policy stays dormant. No consumer-facing digital
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service offered in Germany is on record. The micro-enterprise exemption for
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services is still the fragile basis described above.
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## Reviews
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- **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.
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