TRDigital accessibility in Germany's insurance sector, 2026
An automated WCAG 2.2 assessment of 33 insurer homepages, including six statutory health insurers, after the Barrierefreiheitsstärkungsgesetz (BFSG) began to apply.
Since 28 June 2025, the BFSG has required insurers in Germany to make the digital channels that lead to a consumer contract accessible. We scanned the homepages of 33 insurers, six of them statutory health insurers, against WCAG 2.2 and classified every automatically detected barrier by criterion, principle and level. 26 homepages have at least one barrier at Level A or AA, 384 in total. One problem dominates: low-contrast text makes up 59% of all barriers. The problem is also concentrated: seven insurers hold 65% of all barriers, while seven others show none.
1Key findings
- 59%
Contrast is the sector's main problem. 228 of 384 barriers are low-contrast text. 15 of 33 sites are affected, and five of them hold three quarters of these barriers.
- 65%
Barriers concentrate in a few insurers. The seven sites with the most barriers account for 65% of the total, while seven sites showed no A or AA barrier at all.
- 88%
Barriers are mostly repetition. On 18 of the 26 affected sites, a single error type makes up at least half of the barriers; one fix goes a long way.
- 13 / 33
Screen reader users get stuck on 13 sites. Unnamed buttons and links, and ARIA attributes that do not fit their role, account for 53 barriers.
- 31 / 33
Touch areas are tight on mobile. Four sites fail the AA target size; at the stricter AAA level, 31 of 33 sites have targets below 44 × 44 px.
2Methodology
- STEP 01Select33 insurers operating in Germany, including 6 statutory health insurers.
- STEP 02ScanEach homepage against WCAG 2.2 on 17 October 2026, with the same tool version.
- STEP 03ClassifyEvery barrier tagged by criterion, principle and level.
- STEP 04AnalyseResults grouped by topic and sector. No insurer is named or ranked.
Scope note. The accessibility data in this report is calculated from each insurer's homepage only. Pages behind login, subpages, mobile apps and documents are out of scope; results do not represent an insurer's digital channels as a whole.
Standard disclosure
Automated testing in this study detects only a subset of WCAG 2.2 failures. A clean automated result does not mean a site is accessible or conformant. Barriers under the Understandable principle, such as unclear instructions or unhelpful error messages, and the real behaviour of interactive components can only be assessed through manual review, which is outside the scope of this report. Findings describe detectable barriers, not legal compliance.
3Results
3.1 Barriers by WCAG principle
WCAG groups its requirements under four principles. On German insurer homepages, four in five barriers are Perceivable, driven almost entirely by contrast.
80% of barriers are Perceivable
Share of 384 barriers, with the number of sites affected
Unusually, most barriers are AA
Level A is the most basic level of WCAG
Contrast is 92% of AA barriers
Composition of the 247 Level AA barriers
3.2 Barriers by topic
Nearly half of insurers have contrast barriers
Insurer homepages failing each topic, shown per 10 sites
Contrast. 228 contrast barriers make up 59% of all barriers. They appear on 15 sites, but 174 of them sit on just five. A single update to a design system's colour palette would remove most of them.
Page structure. 45 of the 64 structure barriers come from one pattern: elements given a "presentation" role that still hold meaningful content.
Screen readers. 53 barriers on 13 sites are unnamed buttons and links, and ARIA attributes that do not fit their role. A screen reader announces them only as "button" or "link".
3.3 Distribution across insurers
Seven insurers show no barriers, eight have more than 20
Number of insurer homepages by count of A and AA barriers
of all barriers are held by the 7 insurers with the most
of barriers repeat an error already present on the same site
median barriers per 100 elements examined (range 0 to 11.8)
4Priorities for remediation
Five targeted fixes cover 377 of the 384 barriers detected. The coverage column shows the cumulative share once each fix is added to those above it.
| # | Fix | Barriers · sites | Who benefits | Cumulative coverage |
|---|---|---|---|---|
| 1 | Fix weak contrastWCAG 1.4.3 | 228 · 15 sites | Low vision, older users | |
| 2 | Code page structure correctlyWCAG 1.3.1 | 64 · 10 sites | Screen reader users | |
| 3 | Give buttons and links an accessible nameWCAG 4.1.2 · 2.4.4 | 53 · 13 sites | Screen reader users | |
| 4 | Make touch targets at least 24 pxWCAG 2.5.8 | 18 · 4 sites | Mobile, motor impaired | |
| 5 | Add text alternatives to imagesWCAG 1.1.1 | 14 · 6 sites | Blind users |
The same fixes pay off beyond compliance: better contrast improves readability for every customer in sunlight and at low brightness, and meaningful names and clean structure help search engines and software tools interpret a page.
Beyond Level AA
Level AAA is not required by most regulations and is kept out of the main figures. It shows whether a site that passes AA is truly comfortable to use.
sites have touch targets below 44 × 44 px; 1,302 targets in total.
sites with no barriers still carry AAA warnings, 66 to 112 per site.
sites open links in a new tab without warning.
5Regulatory context
Insurance is not named in the European Accessibility Act, but in Germany the BFSG reaches insurers through their digital sales channels. Statutory health insurers follow a separate, older regime for public bodies.
From public bodies to digital sales channels
Milestones for digital accessibility in German insurance
- May 2002
Disability Equality Act (BGG) for public bodies
- Apr 2019
EU adopts the European Accessibility Act directive
- Jul 2021
BFSG adopted (BGBl. I 2021 p. 2970)
- Jun 2025
BFSG and EAA apply to e-commerce services
- Sep 2025
Joint market surveillance body MLBF begins work
- Sep 2026
EN 301 549 v4.1.1 published, moving to WCAG 2.2
- Jun 2030
Transition ends for systems in use before 2025
Scope
Insurers count as e-commerce service providers where websites and apps lead to a consumer contract: quotes, online applications, appointment booking. Fines of up to EUR 100,000.
Supervision
The joint market surveillance body of the German states began work on 26 September 2025. It acts on complaints and runs its own checks; in serious cases a service can be prohibited.
Health insurers
As public bodies, statutory health insurers follow the public-sector website rules. Six of the 33 sites in this report are statutory health insurers.
Whether a homepage falls under the BFSG depends on what it offers, so this report makes no compliance judgement. But insurer homepages are usually the entry point to quotes and contracts, and 26 of 33 have automatically detected barriers at Levels A and AA, the levels EN 301 549 builds on.
6Implications for executives
Map the pages in scope
The BFSG covers the pages and apps that lead to a contract: quotes, calculators, online applications, appointment booking. Map these journeys and measure them first.
Start with contrast
59% of barriers are low-contrast text. One update to the colour palette in the design system removes most of them across every page.
Assign a single owner
Barriers span design, content and engineering. Without an executive owner and a quarterly target, fixes lose to the campaign calendar.
Put WCAG 2.2 AA in supplier contracts
Agencies and third-party components such as chat, cookie banners and calculators are a major source of barriers.
References
- Barrierefreiheitsstärkungsgesetz (BFSG), BGBl. I 2021 p. 2970. Gesetze im Internet.
- Barrierefreie-Informationstechnik-Verordnung (BITV 2.0). Gesetze im Internet.
- MLBF, Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen. Official website.
- KPMG. “FAQ zur Umsetzung des Barrierefreiheitsstärkungsgesetzes” for banks and insurers.
- AccessibleEU. “The European accessibility standard EN 301 549 has been updated”, 7 September 2026.
- W3C. Web Content Accessibility Guidelines (WCAG) 2.2.
- World Health Organization. Disability and health, fact sheet, March 2023.
Germany insurance sector: digital accessibility report 2026
Complete data, methodology, WCAG criteria table and appendix.
