Accessibility statement: what goes in.

§14(1) BFSG requires service providers to prepare the information set out in Annex 3 and make it available to the public. Annex 3 says where: in the general terms and conditions or in another clearly perceivable way. The information must remain available as long as you offer the service (§14(2)).

• A general description of the service in an accessible format.
• Descriptions and explanations needed to understand how the service is delivered.
• A description of how the service meets the accessibility requirements of the BFSG ordinance.
• The name of the competent market surveillance authority: the joint market surveillance office of the German states for accessibility (MLBF).

The general consumer information duties under Art. 246 EGBGB apply on top. To meet the requirements you may rely on harmonised standards published in the EU Official Journal. None has been cited under the European Accessibility Act yet. In practice, EN 301 549 V3.2.1 is the reference standard for web and apps.

Annex 3 does not require a list of non-accessible parts. That distinguishes the BFSG statement from the statement public bodies publish under BITV 2.0, whose templates are often copied.

Deviations do not disappear that way. If your service does not meet the requirements, you must correct it and inform the market surveillance authority without delay, with details of the deviation and the corrective measures (§14(4)). The statement describes how you meet the requirements. The action plan handles what is still open.

• The statement is missing altogether.
• The BITV template for public bodies was copied, including the list of defects and the wrong legal basis.
• Wrong or no authority named, for example the incorrect abbreviation MSBF.
• "Fully accessible" with no testing behind it.
• The statement exists only as a PDF that is itself not accessible.
• An overlay widget is named as the solution.
• Not updated after a relaunch. §14(3) requires changes to the service, the requirements and the standards to be taken into account.

1. Define scope: which journeys and content fall under the BFSG, such as tariff calculators, application flows, checkout, customer account.
2. Test against EN 301 549 or WCAG 2.1 AA, automated and manual, because tools cover only about a third of the criteria.
3. Fix findings in the code and document the corrections.
4. Write the statement with the mandatory content, publish it accessibly, link it in the footer next to imprint and privacy policy.
5. Review and update it with every relaunch and every significant change.