tegwick
7f135f9e0f
Operator ruling: no external determination in build mode, but keep the set of legal policies for reuse when a work context needs one in place. docs/regulatory/policies/ catalogues thirteen, keyed by activation condition rather than by regime, with a retrieval table so a context pulls a slice: first real user account pulls six of them; a consumer-facing product in Germany pulls those plus accessibility. Two are already active and nobody had noticed — commercial and tax retention, and the e-invoicing receiving obligation that has been live since 2025 with no named owner in the estate. Four written in full; the rest carry their trigger now and get their text when a context approaches, which is the point. RISK-POL-0011 is the argument for the whole catalogue: accessibility cannot be retrofitted cheaply, so a policy retrieved at launch is a rebuild while one read at design time is just a constraint. Co-Authored-By: Claude Opus 5 <noreply@anthropic.com>
60 lines
2.4 KiB
Markdown
60 lines
2.4 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: instant
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clean_streak: 0
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last_checked: "2026-08-20T21:30:00Z"
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next_check: "2026-08-20T21:30:00Z"
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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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