Reasonable accommodations and digital Accessibility

Publication: 17/10/2026

The concept of reasonable accommodation originates from the UN Convention on the Rights of Persons with Disabilities (UN CRPD) and refers to individual adjustments that are necessary to enable people with disabilities to participate equally in society.

These are measures tailored to the specific needs of a person and the respective situation. The aim is to dismantle existing barriers and ensure equal access to services, facilities, and public offerings.

Distinction from General Accessibility

To understand reasonable accommodation, it is important to distinguish between general accessibility measures and individual adjustments.

General accessibility aims to prevent structural, communicative, and digital barriers fundamentally and as comprehensively as possible. An example is the accessible design of public buildings so that they can be used independently by as many people as possible.
Reasonable accommodation, on the other hand, refers to the individual needs of a person. It comes into play particularly when general accessibility measures are not sufficient to ensure equal participation. For example, an additional structural modification may be necessary so that a person with a mobility impairment can access specific premises.

It should be noted that reasonable accommodation does not replace the obligation to provide general accessibility. Rather, it represents a complementary measure to remove individual barriers to participation.

Examples of Reasonable Accommodations

Reasonable accommodations may be required in various areas of life. The following examples illustrate potential application scenarios.

Sign Language Interpreting: Deaf individuals may face communication barriers during doctor visits, official appointments, or consultation sessions if suitable means of communication are not available. Sign language interpreting can represent a reasonable accommodation in such cases. Depending on the circumstances, the interpretation can also be connected digitally.

Workplace Assistance: If an employee requires support with certain tasks that cannot be performed independently due to a disability, workplace assistance may be an option. This includes, for instance, supportive tasks during document processing or when using software that is not designed to be accessible.

Technical Aids in the Workplace: Technical adjustments can also constitute reasonable accommodations. Examples include screen readers, voice control systems, specialized screen magnifiers, or customized input devices. Which measure is suitable depends on individual requirements and specific working conditions.

Legal Framework in Germany

The legal basis for reasonable accommodations is derived from various national and international regulations.

Basic Law (Grundgesetz): Article 3, Paragraph 3, Sentence 2 of the Basic Law stipulates that no person shall be disfavored because of their disability. This prohibition of discrimination forms an essential constitutional foundation for protecting the rights of persons with disabilities.

Act on Equal Opportunities for Persons with Disabilities (BGG): The Federal Disability Equality Act serves primarily to promote equality and accessibility in the federal public sector. It contains regulations on removing barriers and promoting the equal participation of persons with disabilities. For employment relationships in the private sector, labor law provisions, the General Act on Equal Treatment (AGG), and other relevant regulations must also be taken into account.

UN Convention on the Rights of Persons with Disabilities (UN CRPD): The UN CRPD was ratified by Germany and is binding for Germany under international law. Article 2 defines reasonable accommodation as necessary and appropriate modification and adjustments not imposing a disproportionate or undue burden, where needed in a particular case, to ensure to persons with disabilities the enjoyment or exercise on an equal basis with others of all human rights and fundamental freedoms.

The Convention obligates state parties to protect the rights of persons with disabilities and promote their equal participation. Its specifications must be taken into account when interpreting and further developing national law.

Current Political Discussion and the Need for Reform

The further development of disability equality law is a topic of ongoing political discussion. In particular, the extent to which private companies should be obligated to provide accessibility and reasonable accommodations is a significant point of debate.

From the perspective of disability advocacy groups, further action is required here. A central question is under what conditions companies may refuse a requested measure on the grounds of a disproportionate or undue burden.

Although such a limitation is part of the concept of reasonable accommodation, it is crucial that the assessment of reasonableness is transparent and considers the specific circumstances of each individual case. Otherwise, there is a risk that legitimate concerns of persons with disabilities will not be sufficiently taken into account.

Application Process and Practical Challenges

The process of applying for reasonable accommodations can vary depending on the measure, jurisdiction, and legal framework. In practice, the following steps are frequently distinguished:

Submitting an Application: The person concerned contacts the competent benefit provider or responsible authority. Depending on the request, this may be a rehabilitation provider, an integration office (Inklusionsamt), or another relevant agency.
Justification of Need: The applicant explains which barrier exists and why the requested measure is necessary. For technical aids, submitting supporting documents or a cost estimate can be useful.
Review and Coordination: The competent authority evaluates the requirements and the specific need. Early coordination with the affected individual can help identify a suitable and practical solution.

Challenges Regarding Rejections and Delays

If a requested measure is rejected, various legal remedies or complaint options may exist, depending on the legal basis and the responsible agency. In certain cases, conciliation procedures may also be an option.

However, several practical challenges arise during implementation:

Duration of Procedures: Delays can mean that necessary support measures are not available in a timely manner. This is particularly problematic if the measure is needed for an upcoming doctor's appointment, an educational program, or another time-sensitive opportunity for participation.
Limited Capacity: Staffing and organizational bottlenecks at competent authorities and conciliation boards can complicate processing further.
Lack of Awareness: Particularly among private providers and companies, there is sometimes uncertainty regarding which obligations exist to ensure equal participation and under what conditions reasonable accommodations are required.

Conclusion

Reasonable accommodations are an essential tool for eliminating individual barriers and promoting the equal participation of persons with disabilities. They supplement general accessibility measures and make it possible to respond to specific needs on a case-by-case basis.

For this tool to be effective, however, clear responsibilities, transparent decision-making processes, and prompt handling of requests are required. Equally important are increased awareness among responsible authorities and consistent adherence to legal obligations.

The central challenge lies not only in legally recognizing the right to equal participation, but also in effectively guaranteeing it in practical implementation.