WCAG vs. BITV: What Companies Need to Know About Accessible PDFs in Germany

PDF documents remain a core tool for corporate communication. But as accessibility regulations tighten in Europe, especially in Germany, many organizations find themselves unsure how to comply. Two acronyms come up again and again: WCAG and BITV. If your company is producing documents for German stakeholders—whether you're a local brand or an international enterprise—understanding the difference between these standards is critical. This article explains what WCAG and BITV mean, how they apply to your business, and what you need to create truly accessible PDFs.

What is WCAG and where does it apply?

WCAG stands for Web Content Accessibility Guidelines. Developed by the W3C (World Wide Web Consortium), it's the most widely accepted international standard for digital accessibility. WCAG defines how digital content (including websites and documents) should be structured to be perceivable, operable, understandable, and robust for people with disabilities. It comes in three levels:

Level A (minimum requirements
Level AA (industry standard for compliance)
Level AAA (highest standard, often optional)

The European Union refers to WCAG 2.1 Level AA as the benchmark in its accessibility directives—including for downloadable documents like PDFs.

What is BITV 2.0 and how is it different?

BITV 2.0 stands for Barrierefreie-Informationstechnik-Verordnung, or the German Regulation on Accessible Information Technology. It implements the EU directive into national law and adds specific legal and procedural requirements. BITV 2.0 doesn't just adopt WCAG—it contextualizes it for the German public sector and makes it enforceable. Key differences:

BITV requires WCAG Level A and AA compliance.
It adds legal structure (e.g., deadlines, monitoring, feedback mechanisms).
It refers to the technical norm EN 301 549, which includes WCAG plus format-specific rules (e.g., for PDF files).

Who is legally obliged to provide accessible PDFs?

More organizations than you might think.

Public institutions (mandatory by law):

Federal and state governments, agencies, municipalities
Universities and public educational institutions
Any PDF published on official websites or intranet

These bodies are fully covered by BITV 2.0 and must comply.

Companies working with public bodies:

If you're producing content for a ministry, government site, or a public-facing portal, your PDFs must meet BITV standards.
Accessibility is often a formal tender requirement.

Private companies (in practice) – No general legal mandate but:

Corporate Social Responsibility (CSR) often includes accessibility.
Investor and HR documents aimed at the public may be scrutinized.
B2B clients increasingly demand compliance.
International brands publishing German content must respect BITV.

Future-proofing – European Accessibility Act (EAA):

From 2025, private-sector services like e-commerce, banking, and transport must meet accessibility rules.
That includes documentation (PDFs, forms, user guides).

Bottom line: whether you're required or simply expected to comply, accessible PDFs are becoming a new standard.

Why the difference matters for your business

Many businesses assume that following WCAG is enough. But for the German market, that’s only part of the equation. To meet expectations or legal obligations, your documents must align with WCAG 2.1 Level AA, comply with BITV 2.0 procedures, and be structured according to PDF/UA, the Universal Accessibility standard.

If your company works with public sector clients, participates in German tenders, or publishes documents for German customers, these requirements apply directly to your organization. Even if you're not directly subject to legal enforcement, failing to meet these standards can create reputational risks, lost contract opportunities, or downstream compliance issues when your content is shared in regulated environments.

Understanding these distinctions ensures you're not just technically compliant but also aligned with the expectations of stakeholders in Germany. It positions your company as forward-thinking, responsible, and prepared for future EU-wide legislation.

Creating compliant PDFs is not just a checkbox activity—it requires design, structure, tagging, and validation.

work with a partner who understands the German legal framework, including BITV and BGG, and who has the technical know-how to implement PDF/UA using the right tools and validation procedures.

Most importantly, choose a team that can execute all of this without compromising your brand’s design integrity or voice.

PDF/UA: The technical foundation for accessible PDFs

PDF/UA (ISO 14289-1) is the technical standard for accessible PDFs. It defines how headings, lists, tables, and reading order should be tagged so assistive technologies (like screen readers) can interpret them.

It works alongside WCAG and BITV:

WCAG defines what makes content accessible
BITV defines who must comply and how to enforce it
PDF/UA defines how a PDF must be built to meet those requirements

If your PDF fails PDF/UA checks, it's not accessible—even if your web content passes WCAG.

Let’s talk about your documents.

Understanding the difference between WCAG and BITV isn’t a technical detail—it’s a strategic necessity for doing business in Germany. Accessible PDFs are a legal requirement for many, a compliance risk for others, and a brand opportunity for all. If you need support in creating barrier-free PDFs that meet legal standards and your brand expectations, we’re here to help.

Whether it’s one CSR report or a full library of product PDFs—we help you publish inclusive, compliant, and beautifully designed files for the German market.