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Accessibility Design Guidelines for RPs and EAA Providers

Overview

When designing solutions for the EUDI Wallet Ecosystem, both Relying Parties (RPs) and European Accessibility Act (EAA) Providers must consider accessibility requirements that ensure their services are usable by all citizens, including those with disabilities. This document outlines the high-level accessibility frameworks and key considerations for designing accessible solutions.

Germany's Accessibility Framework

Germany's accessibility framework establishes mandatory requirements for both public and private sector organizations. Understanding these frameworks is essential for organizations operating within the EUDI Wallet Ecosystem.

Public Sector Accessibility

The Behindertengleichstellungsgesetz (BGG) (Act on Equal Opportunities of Persons with Disabilities) has been in force since May 1, 2002. It regulates equality for people with disabilities in the area of public law at the federal level and implements the prohibition of discrimination under Article 3, paragraph 3, sentence 2 of the Basic Law: "No person shall be disadvantaged because of their disability."

Technical Requirements

BITV 2.0 (Barrierefreie-Informationstechnik-Verordnung - Barrier-Free Information Technology Ordinance) implements Section 12b of the BGG and ensures the accessibility of public sector products and services.

BITV 2.0 provides the national legal framework while implementing: - The EU Web Accessibility Directive (EU Directive 2016/2102) - The EN 301 549 standard - The international WCAG 2.1 (Web Content Accessibility Guidelines) Level AA criteria

Private Sector Accessibility

The Barrierefreiheitsstärkungsgesetz (BFSG) (Accessibility Reinforcement Act) aims to make private sector products and services more accessible for people with disabilities and to strengthen equal participation. It transposes the European Accessibility Directive (EAA) (EU Directive 2019/882) into German national law.

Technical Requirements

The BFSGV (Verordnung zum Barrierefreiheitsstärkungsgesetz - Ordinance on the Accessibility Improvement Act) sets out detailed provisions for implementing accessibility requirements for private sector products and services, including websites and online shops.

Key accessibility requirements include:

Functional Accessibility - Identification, authentication, security, and payment functions must be designed to be perceivable, operable, understandable, and robust

Multi-Sensory Communication - Information must be provided through more than one sensory channel

Visual Presentation - Appropriate font type, size, and form - Sufficient contrast and spacing between lines, letters, and paragraphs

Alternative Content - Alternative representations for images and other non-text content

Key Considerations for EUDI Wallet Solutions

For Relying Parties

When integrating with the EUDI Wallet, RPs should:

  • Ensure presentation request flows are accessible to users with varying abilities
  • Provide clear, understandable authentication and data verification flows
  • Test credential presentation and verification processes with accessibility tools

For EAA Providers

When issuing credentials within the EUDI Ecosystem, EAA Providers should:

  • Ensure credential data is structured to be machine-readable and accessible
  • Consider accessibility in credential styling and presentation
  • Design issuing flows that accommodate users with disabilities
  • Follow WCAG 2.1 Level AA guidelines for any user-facing interfaces