The main difference between a BITV audit and a WCAG test lies in their scope: the WCAG (Web Content Accessibility Guidelines) is the international baseline standard for digital accessibility, whilst the BITV (Regulation on Accessible Information Technology) is a German regulation based on the WCAG and primarily applicable to public bodies. For private companies, the Accessibility Enhancement Act (BFSG) has been particularly relevant since 2025, as it also refers to WCAG requirements. This article answers the most important questions regarding both standards and explains when each approach is appropriate.
What is the BITV based on, and how does it relate to the WCAG?
The BITV is based directly on the WCAG and adopts its success criteria as a binding framework. WCAG is an international standard developed by the World Wide Web Consortium (W3C), the current version of which (2.2, published in 2023) is based on 13 guidelines and four core principles: Perceivability, Operability, Understandability and Robustness. The BITV transposes these requirements into German law and specifies them for the public sector.
The Accessible Information Technology Ordinance applies in Germany to federal authorities and public bodies. It stipulates that their websites and mobile applications must meet the requirements of the WCAG at Conformity Level AA. In addition, the BITV requires an accessibility statement and a feedback mechanism through which users can report barriers.
The BITV is the German implementation of the EU Directive 2016/2102 and is based on the European standard EN 301 549. Here are the key relationships:
- EN 301 549 refers to WCAG 2.1 Level AA for web content
- The BITV adopts these technical requirements in full
- WCAG 2.2 is also increasingly being taken into account
WCAG itself recognises three levels of conformance:
Level A: Minimum requirements, without which a website is unusable for certain user groups
Level AA: The de facto standard in practice, required by both the BITV and the BFSGLevel AAA: The highest requirements, which are rarely fully achievable in practice
A WCAG test therefore checks the foundation upon which the BITV assessment is also based. Anyone who passes a BITV assessment generally also meets the core WCAG requirements at Level AA.
What exactly does a WCAG test check?
A WCAG test checks whether a website meets the success criteria of the Web Content Accessibility Guidelines. These include technical and content-related aspects: colour contrast, alternative text for images, keyboard navigability, screen reader compatibility, font scalability and the logical structure of the HTML code. The test covers both automatically detectable criteria and those requiring manual verification.
Specifically, a WCAG test typically covers the following areas:
- Perceivability: Alternative text for images, captions for videos, sufficient colour contrast, no information conveyed solely through colour
- Operability: Full keyboard accessibility, no time limits without alternatives, no flashing content that could trigger seizures
- Understandability: The language used on the page is clear, forms have clear labels, and error messages are understandable
- Robustness: Valid HTML, correct ARIA attributes, compatibility with assistive technologies such as screen readers
Important to note: Automated tools can reliably detect many technical aspects, such as missing alt text, insufficient contrast or incorrect ARIA attributes. Other criteria, such as whether alternative text is worded sensibly or whether all navigation elements are actually accessible via the keyboard, also require manual checking. A good result in the automated accessibility test is a necessary but not sufficient condition for full WCAG compliance.
What exactly does a BITV audit check?
A BITV audit checks whether a website meets the requirements of the Accessible Information Technology Regulation. In terms of content, it is based on the WCAG Success Criteria at Level AA, but supplements these with specific formal requirements: the presence of an accessibility statement, a functioning feedback mechanism and compliance with further national guidelines.
Compared to a standard WCAG test, the BITV audit therefore has a broader scope:
Technical accessibility in accordance with WCAG 2.1 AA (and increasingly 2.2)
Accessibility statement: A publicly accessible document that sets out the compliance status, known exceptions and contact details
Feedback mechanism: Users must be able to report barriers
Arbitration body: Reference to the relevant arbitration body must be provided
The BITV assessment is therefore more formal and documentation-oriented than a standard WCAG test. It is usually carried out by specialist service providers and includes both automated and manual assessment steps. The result is not a binary ‘pass’ or ‘fail’, but a structured assessment of the current status with specific recommendations for action.
Which standard applies to private companies under the BFSG?
In Germany, the Accessibility Enhancement Act (BFSG) has applied to private companies since June 2025; this transposes the European Accessibility Act (EAA) into national law. The BFSG refers to the WCAG, not the BITV. The BITV continues to apply exclusively to public bodies. Private companies falling under the BFSG must design their digital products and services to be accessible in accordance with WCAG criteria.
The BFSG primarily affects companies offering certain digital products or services, including e-commerce platforms, banking apps, streaming services and similar offerings. Small businesses with fewer than ten employees and an annual turnover of less than two million euros are often exempt, but should check this on a case-by-case basis.
In practice, this means that private companies wishing to check their website for accessibility should use WCAG 2.1 at Conformity Level AA as the relevant benchmark. A BITV audit in the formal sense is not mandatory for them, but the underlying technical requirements are largely identical.
When should you opt for a BITV audit and when for a WCAG test?
The choice between a BITV audit and a WCAG test depends primarily on the scope of application: public bodies and authorities require a BITV audit as they are legally obliged to do so. Private companies, agencies and consultants wishing to test websites for accessibility typically rely on a WCAG test as a basis and use WCAG 2.1 AA or EN 301 549 as their technical reference standard.
BITV audit: When is it appropriate?
A BITV audit is the right choice for public institutions that require a formal declaration of conformity and are legally obliged to produce an accessibility statement. A full BITV audit carried out by a certified audit service provider is also recommended if evidence is required for supervisory authorities or the conciliation body.
Key difference from a standard WCAG audit
EU Directive 2016/2102 explicitly stipulates:
“Websites and applications must be accessible; an accessibility statement must be provided; there must be a method for users to report accessibility issues; and a link to enforcement procedures must be provided.”
This makes the BITV audit more formal and documentation-oriented than a standard WCAG test.
WCAG test: When is it appropriate?
A WCAG test is suitable for all scenarios where the aim is to identify and specifically remove barriers without requiring formal certification from the authorities. This applies to agencies reviewing client projects, external data protection and compliance consultants looking to expand their portfolio, and private companies wishing to meet their obligations under the BFSG. The Accessibility Enhancement Act will apply to private companies from June 2025. A regular WCAG test helps to identify problems at an early stage and bring the website up to accessibility standards before legal risks arise.
How can BITV and WCAG checks be carried out automatically?
Automated tools can reliably detect a significant proportion of the WCAG and BITV-relevant testing criteria. These include missing alternative text, insufficient colour contrast, incorrect ARIA attributes, unmarked languages and many other technical aspects. Automated tests save time and make it possible to systematically check large numbers of subpages for accessibility.
However, there is one important limitation: no automated test alone can guarantee a website’s accessibility. Certain criteria can only be assessed manually, for example:
- Whether alternative text is meaningful and descriptive in terms of content
- Whether all navigation elements are actually accessible via the keyboard
- Whether the visible order on the page corresponds to the HTML structure
- Whether content is read aloud in a way that is understandable to screen reader users
The Web Accessibility Initiative (WAI) therefore recommends a combination of automated and manual testing. A good risk score in an automated scan is an important first step, but it is no substitute for a comprehensive manual review. Professional accessibility tools allow issues identified manually to be included directly in the audit report, providing a complete picture.
How decareto supports WCAG and BITV audits
At decareto, we offer automated accessibility software that systematically checks websites for accessibility, taking into account the requirements of WCAG, BITV and BFSG. Our solution is aimed at agencies, external consultants, data protection officers and compliance teams who wish to support their clients efficiently and at scale.
What decareto specifically offers:
- Automated accessibility scans of homepages and subpages, including password-protected areas, in minutes rather than hours
- Detection of around 90 types of accessibility issues, ranging from missing alt text and ARIA errors to contrast problems, based on WCAG 2.1 and prepared for 2.2
- Prioritisation by severity with specific recommendations for action, so you know where to start
- Manual recording of issues that automated tests cannot detect, directly within the report
- Continuous monitoring of hundreds of websites with automatic notifications of changes
- Accessibility statement based on the scan results, as required by the BFSG
- White-label reports that you can pass on to clients directly under your own logo
Automated tools can typically only fully test around 30–40 per cent of the WCAG criteria – the rest requires human assessment. A good scan result means that there are no automatically detectable barriers. It does not replace a full manual audit and does not constitute a legal certificate of compliance. However, it provides you and your clients with a solid, structured foundation for further work on accessibility. Try decareto and carry out your first website accessibility test or create your account now.
