tegwick 5a7e4ac2d4 Review the overdue regulatory records

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

2026-09-22 08:26:43 +02:00

2.8 KiB

Raw Blame History

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

2.8 KiB Raw Blame History