On June 28, 2025, the implementation deadline for EU Directive 2019/882, the so-called European Accessibility Act, expired. The directive obligates member states to make digital products and services accessible. Germany has formally transposed the requirements into the Barrierefreiheitsstärkungsgesetz (Accessibility Strengthening Act). Yet while the law exists, it remains unclear who monitors compliance, how often testing occurs, and what consequences apply for non-compliance. A central dashboard displaying the compliance status of public websites in real time does not exist.
United States Postpones, Germany Stays Silent
In the United States, the Office for Civil Rights postponed publication of a long-awaited rule on digital accessibility under Section 504 of the Rehabilitation Act again in May 2026. Disability advocacy groups have filed suit in response, because the delay leaves schools, universities, and agencies uncertain which technical standards apply. The debate centers on whether a law from 1973 suffices for today's digital infrastructure. Germany faces a structurally similar problem: the obligation to provide accessibility is codified, but enforcement remains diffuse. Federal, state, and municipal authorities each hold jurisdiction, a central body that coordinates enforcement and documents it publicly is absent.
Estonia Measures Automatically
Estonia has operated an automated monitoring system for the accessibility of public websites since 2018. The system tests all registered government domains quarterly for conformity with the Web Content Accessibility Guidelines 2.1. Results are published in a public dashboard that displays the compliance status of each website in traffic-light colors. Agencies that fail to meet requirements receive a deadline for remediation. After the deadline expires, status is tested and documented again. The system creates transparency, enables comparison, and generates institutional pressure without additional bureaucracy. In Germany, a comparable system does not exist. The federal monitoring body for accessibility of information technology tests by sampling, the states organize their own procedures, a unified, publicly accessible data foundation is absent.
Enforcement Without Measurement Is Rhetoric
Whoever mandates accessibility but does not measure it shifts the problem from legislation into enforcement and lets it dissolve there. The implementation deadline of the European Accessibility Act has passed, yet the question of how many of the thousands of websites of German agencies are actually compliant remains unanswered. The Accessibility Strengthening Act provides for sanctions in cases of non-compliance, but without systematic testing it remains unclear against whom these could be imposed. In the United States, the rule is postponed because technical implementation is unclear. In Germany, the rule exists, but implementation remains opaque. Both lead to the same result: uncertainty for agencies, lack of accountability to citizens, stagnation in enforcement.
Dashboard Instead of Sampling
A public dashboard following the Estonian model would make enforcement visible. Every agency would know where it stands. Every citizen could verify which administrations fulfill their obligation. Testing occurs automatically, costs are low, impact is high. Such a system requires no new legislation, merely the decision to take enforcement seriously. Estonia made that decision in 2018. Germany let a deadline pass in 2025 without creating a comparable instrument. The question is not whether Germany possesses the technical capacity to build such a system. The question is whether the political will exists to make enforcement transparent.
Structure Follows Measurement
Accessibility is not an abstract goal but a measurable requirement. Whoever does not measure it cannot enforce it. Whoever does not enforce it makes it a recommendation. Germany has formally implemented the EU directive, but without central monitoring, enforcement remains fragmented. The United States postpones its rule because implementation is unclear. Germany has the rule but leaves implementation in the dark. Both constitute enforcement failure. An automated dashboard would make enforcement visible, create comparability, and generate institutional pressure. The technology exists, the model is documented, the decision is pending.
Band 3 "Bauplan" describes how decision becomes impact. Whoever takes enforcement seriously must make it measurable. The book shows how structures emerge that compel implementation rather than hope for it. Available at projekt-freistaat.de/bauplan.