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Accessibility certificates: what website owners really need

Updated October 14, 2026 · 7 min read

German law does not require a certificate for the accessibility of your website. The Barrierefreiheitsstärkungsgesetz (BFSG), Germany's implementation of the European Accessibility Act, requires that your service meets the requirements and that you inform about it under § 14 and Annex 3. The yardstick is the harmonised standard EN 301 549. Audit reports and seals can help to show this – but they replace neither accessibility itself nor your accessibility statement.

This article is a factual overview, not legal advice.

What the BFSG requires – and what it does not

§ 14 BFSG sets out the duties of service providers. You may only offer a covered service, such as an online shop for consumers, if

  1. it meets the accessibility requirements of the regulation under the BFSG, and
  2. you have prepared the information set out in Annex 3 and made it available to the public in an accessible form.

You must keep this information for as long as you offer the service. The requirements must be met at all times; if your service, the requirements or the standards change, you must take that into account. If you find non-conformities, you take corrective action and inform the market surveillance authority. On a reasoned request, you must give the authority information on how you demonstrate conformity.

§ 14 does not mention a certificate, a third-party test or a conformity assessment procedure for services. The EU declaration of conformity and CE marking exist in the BFSG only for products (§§ 18 and 19, Annex 2), not for services such as a website. Whether you are covered is explained in Who is affected?; all duties are summarised in our BFSG guide.

How conformity is measured: EN 301 549

§ 4 BFSG contains a presumption of conformity: if a service meets harmonised standards whose references are published in the EU Official Journal, it is presumed to meet the requirements – to the extent the standard covers them. For websites and apps, that standard is EN 301 549. The currently harmonised version V3.2.1 adopts the success criteria of WCAG 2.1 levels A and AA for web content. The difference to the newer WCAG 2.2 is explained in WCAG 2.1 vs 2.2.

The key point: the presumption depends on actually meeting the standard, not on a document certifying it. If the German market surveillance body (MLBF) checks your website – based on a complaint or as a spot check under § 28 BFSG – it looks at the website itself.

What about "WCAG certificates"?

WCAG is published by the W3C. The W3C does not certify websites. About the WCAG logos that site owners can use to state conformance, it says explicitly that these logos do not represent review or validation of conformance by W3C and/or WAI. A WCAG conformance claim is also optional: WCAG 2.2 states that conformance claims are not required. And conformance always applies to full pages – it cannot be achieved if part of a page is excluded.

A "WCAG certificate" is therefore always a statement by a private provider about certain pages at a certain time. It can be valuable if the testing is done well – but it is not an official seal of approval.

Audit report, audit, seal: what they deliver

The audit report

An audit report is the result of a test by experts. A good report states:

  • the standard (for example EN 301 549 V3.2.1 or WCAG 2.2 AA),
  • the pages and flows tested, such as the homepage, a product page, the cart and checkout,
  • the date and the method (manual, automated or both),
  • every issue found, with its location and criterion.

Such a report is a snapshot. Every update, every new plugin and every new campaign page can introduce new barriers. It is a good basis for your accessibility statement and shows that you took the matter seriously. Read more in our article on the accessibility audit.

The seal

A seal or test mark sums up a test result graphically. A well-known example in Germany is the mark of the BIK BITV-Test, a manual test procedure against BITV 2.0 and EN 301 549. Its rules show what matters for credible seals:

  • The mark "BIK BITV-konform (geprüfte Seiten)" only speaks for the tested pages, not the whole website.
  • It must link to the published test report.
  • It may generally not be used if the website runs an overlay tool.

For federal public bodies, § 7 BITV 2.0 requires the accessibility statement to say whether the assessment was done by a third party, for example through certification, or as a self-assessment. Both are allowed. Details are in our guide to BITV 2.0.

Red flags in certificate offers

  • "Certificate on installation": a seal you receive as soon as you embed a script or widget. Overlays do not make a website accessible; see Overlays vs real accessibility.
  • "BFSG certified" or "officially approved": there is no official certification of websites under the BFSG.
  • Guarantees such as "fully compliant with the law" or "protects against warning letters": no tester can promise that.
  • No report: a seal without a traceable report naming pages, date and method says little.
  • Automated only: automated tests detect only part of the requirements. A certificate based solely on an automated scan does not cover, for example, whether alt texts are meaningful or whether the checkout works with a screen reader.
  • No expiry: a result from two years ago does not describe your website today.

What you need instead

  1. Clarify whether you are covered – only then is any further investment worthwhile.
  2. Check automatically and regularly to find technically detectable errors early. Our free check shows this for one page; weekly monitoring checks the whole website.
  3. Have manual testing done, especially of the checkout, forms and navigation – with keyboard and screen reader.
  4. Document the results: audit reports, fixed issues, dates. This helps if the authority asks how you demonstrate conformity.
  5. Publish your accessibility statement – our generator creates a draft from a questionnaire, as a template for your legal adviser.

Our check is an automated check, not a full audit and not a certificate, and it is not legal advice.

Frequently asked questions

Does the BFSG require a certificate for my website?

No. § 14 BFSG requires that the service meets the accessibility requirements and that you provide the information set out in Annex 3. The law does not provide for a certificate, a third-party test or CE marking for websites.

Is there an official WCAG certificate?

No. The W3C, which publishes WCAG, does not check conformance claims. About its WCAG logos it states explicitly that they do not represent review or validation of conformance by W3C or WAI.

How is accessibility measured?

Against the harmonised standard EN 301 549. If a service meets it, § 4 BFSG presumes that it meets the requirements. The currently harmonised version V3.2.1 refers to WCAG 2.1 level AA for websites.

What is an accessibility audit report worth?

A good report documents which pages were tested, when, with which method and which issues were found. It is a snapshot and a good basis for your accessibility statement, but it is not an approval by any authority.

Is an overlay certificate proof of accessibility?

No. An overlay widget does not make a website accessible, and a seal issued by the overlay vendor is no proof. The BIK test mark, for example, may generally not be used at all under the BIK rules if the website uses an overlay.

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