Does our price list as a PDF have to be accessible?

That depends on two questions. First: does your website fall under the BFSG? Among the services covered are services in electronic commerce, meaning digital services provided with a view to concluding a consumer contract (section 2 no. 26 BFSG). Second: when was the file published? Office file formats published before 28 June 2025 are excluded (section 1 (4) no. 2 BFSG). Regardless of the legal classification, though, one thing holds: a price list that nobody can have read out loud costs enquiries. The practical route is therefore to keep the prices as a page.

Does the BFSG apply to our small care service too?

The service requirements do not apply to micro-enterprises (section 3 (3) BFSG). A micro-enterprise is a company with fewer than ten staff that either achieves at most 2 million euros in annual turnover or whose annual balance sheet total is at most 2 million euros (section 2 no. 17 BFSG). Many home care services are above that, many below. The exemption concerns the legal duty, not the need: at the end of 2025 a good 7.8 million people with a severe disability lived in Germany (Destatis), and some of them are among your relatives and enquirers.

What exactly does the exclusion for old files mean?

It protects the existing stock, not the format. Section 1 (4) no. 2 BFSG excludes office file formats published before 28 June 2025. A file that has sat unchanged on the website since 2022 falls under it. As soon as you redraft the same price list at the turn of the year and upload it, that counts as a new publication. In practice this means every update is the moment when the document is being touched anyway, and therefore the cheapest point at which to set it up properly.

How do I tell without specialist tools whether a file is any good?

With six steps. Select the text and copy it: if that fails, the file is an image. Search inside the document for a word that is certainly there: if the search finds nothing, the text layer is missing. Open the outline in the viewer: if it stays empty, the headings are merely formatted large rather than marked up. And look at the document properties: they must hold a title and the default language. Two looks at the presentation round it off: does every illustration carry a text alternative, and can the document be read on a phone without pushing in two directions? Together these six checks take a few minutes per document and separate the files that can be repaired from the ones that have to be produced again.

Is replacing the file with a page enough?

For prices, services and menus, usually yes, and it is the simpler route: a page brings structure, language and title with it by default, works on every device and can be updated by changing one line. For documents that are signed or kept as evidence you need both: the page with the content and the file for printing. What matters then is that the old address does not run into nothing after the switch but redirects to the new page.

How do we keep the documents current in the long run?

With a list and a date. The list holds every document with title, version date, size and the pages on which it is linked. The date sits in January, because prices, rates and surcharges change at the turn of the year. Two rules keep the list clean: new versions replace the old one at the same address instead of sitting next to it, and every new file goes through the six checks once before it is uploaded. That keeps the effort at a few minutes per document rather than a large clean-up every two years.

Accessible PDF downloads on a care service website

In short and in plain language

On some care websites, key facts sit in files. Think of the price list, the sign-up form or the weekly menu.

People searching on a phone often get stuck there. A photo of a price list stays empty for screen readers.

The article helps you choose. Which document should become a page? Which one may stay a file?

If it stays a file, it needs real text, a clear order and a title. Accessible means everyone can use it well, also people with a disability.

The article also explains what the accessibility law says about files. We go through your documents and make them easier to read.

On the website of a home care service, the most important details rarely sit on a page. They sit in a file: the price list as a scan, the service catalogue as a text document, the sign-up form for day care, the weekly menu, the house rules, the application form. In the office that is the short route, because the sheet is in the folder anyway. For the daughter looking up the hourly rate on her phone at half past ten in the evening, it is the point where the search ends. This article settles three questions: which document belongs on a page, which one may stay a file, and what a file has to carry so that everyone can read it.

Key takeaways

Under section 3 (1) BFSG, accessible means findable, reachable and usable in the customary manner, without particular difficulty and in principle without outside help. A photographed price list meets none of those three, because it stays empty for screen readers.
The act excludes office file formats published before 28 June 2025 (section 1 (4) no. 2 BFSG). Anyone who redrafts such a file and uploads it again can no longer rely on that exclusion for this document.
Micro-enterprises with fewer than ten staff and at most 2 million euros in annual turnover or balance sheet total are exempt from the service requirements (section 3 (3) together with section 2 no. 17 BFSG). The need on the relatives' side does not disappear with the exemption.
EN 301 549 gives downloadable documents a chapter of their own, chapter 10. Text alternatives, structure, document title and declared language apply there just as sharply as on the web page itself.
At the end of 2025 a good 7.8 million people with a severe disability lived in Germany, 45 percent of them aged 55 to 74 (Destatis). That is precisely the age group that co-signs the care contract.

Why the file is the most expensive drop-off

A file shifts work from the office to the visitor. Anyone who posts the price list as a scan is asking the reader to download the document, open a viewer, push it around in both directions on a phone and find a figure in a table laid out for an A4 sheet. WCAG success criterion 1.4.10 describes exactly the state to be avoided: content should be presentable at a width equivalent to 320 CSS pixels without requiring scrolling in two dimensions (W3C). A page layout manages that; a fixed paper format does not. Then there is the loading path. A file of several megabytes is not a click on a mobile network but a wait, and the link to it usually reveals neither format nor size. How heavily such loads show up in the measurements is covered in the article on loading time and Core Web Vitals.

The audience makes the difference expensive. In the 45 to 64 age group, around 80 percent looked online for information about goods and services in 2025; among 65- to 74-year-olds it was 65 percent (Destatis). These are the children and the partners of the people concerned. In December 2023 just under 5.7 million people were in need of care, and 86 percent of them were cared for at home (Destatis). People cared for at home usually have relatives who compare, calculate and fill in forms. Some of those relatives read poorly: at the end of 2025 a good 7.8 million people with a severe disability lived in Germany, and in 4 percent of cases blindness or a visual impairment was recorded (Destatis). A file without a text layer shuts that group out completely, on the phone just as at the desk.

The two-minute test

Open one of your files on your own phone. Try to select the text and copy it. If that does not work, the document is an image and empty for every screen reader. Then enlarge to double the type size: if you have to push sideways to finish a line, the document is not usable on a phone. Neither test needs a specialist tool, and together they answer the most important question before the stocktaking even starts.

What the law sets out for documents

The German Accessibility Strengthening Act applies to services provided to consumers after 28 June 2025. It lists five categories (section 1 (3) BFSG), and for care providers one of them is primarily relevant: services in electronic commerce. The act describes these as digital services offered through websites and through applications on mobile devices and provided electronically at the individual request of a consumer with a view to concluding a consumer contract (section 2 no. 26 BFSG). What matters, then, is the conclusion of a contract. A purely informational page is assessed differently from a page through which a paid course is booked or a care contract is initiated. How that classification works out for home care services is set out in the article on the BFSG for care services.

Two exemptions matter for documents. First, the service requirements do not apply to micro-enterprises, meaning companies with fewer than ten staff and either at most 2 million euros in annual turnover or an annual balance sheet total of at most 2 million euros (section 3 (3) and section 2 no. 17 BFSG). Second, section 1 (4) no. 2 BFSG excludes office file formats published before 28 June 2025. This is the passage most often misread in practice: what is protected is the existing stock, not the format. As soon as you redraft the price list at the turn of the year and upload it, that document has been newly published. The substance of the requirements is set out in the accompanying regulation, which in section 12 calls among other things for information content to be provided in text formats from which consumers can generate alternative assistive formats.

Products and services are accessible when they can be found, reached and used by people with disabilities in the customary manner, without particular difficulty and in principle without outside help.

Section 3 (1) sentence 2 BFSG, translated

File or page: the decision per document

The useful question is not whether a PDF file is permitted. It is: what is this document for? Anything meant to be read, compared or searched belongs on a page. Anything meant to be printed, signed or kept as evidence may be a file, but then in addition to the page and not in its place. That split settles most cases in a few minutes. It has a second advantage: what sits on a page is found by a search engine in the sentence rather than as an attachment, and it can be updated by changing one line instead of producing a new document. The groundwork is covered in the article on putting accessibility into practice. The list below sorts the documents that most often sit as files on care websites.

Price list and rates belong on a page. They are compared, they change every year, and experience shows they are the most common reason for a phone call.
The service catalogue belongs on a page, organised by service groups. As a file it cannot be found; as a page it answers search queries word for word.
The weekly menu belongs on a page. It is read on a phone, swapped every week and rarely printed.
Sign-up and application forms belong on the page as a form, with the file as an additional route for everyone who prefers to fill things in on paper.
House rules and the care contract may stay files, because they are signed. The content still belongs on a page in short form.
Quality and inspection reports may stay files. The key statements and the inspection date belong next to them as text, otherwise hardly anyone reads them.

The same price list in two forms

The comparison becomes clearer when you put the same document side by side in both forms. The price list is a good example, because of all documents it is opened most often and maintained least often. The same reasoning applies to every document that explains a service, for instance the papers on doctor-prescribed care and its prescription: as long as the explanation sits inside a file, it can neither be found nor quoted nor updated on its own.

Feature	Price list as a file	Price list as a page
Findable through search	only as an attachment, without surrounding text	as a page with a title and a text excerpt
On a phone	fixed paper format, pushing in two directions	flowing reflow from 320 pixels width
Screen reader	empty when there is no text layer	reads out headings, rows and values
Changing one line	produce a new document and upload it	change the line, publish
A second language version	a separate file per language	a language version of the same page
Link from an article	download without a preview	deep link to the section
Date of the figures	buried inside the document	visible above the table

When the document stays a file

Some documents stay files, and that is fine. The same standard then applies to them as to the page. The European standard EN 301 549, on which the German requirements build, draws that line explicitly: chapter 10 covers documents that are not web pages, that are not embedded in web pages and that are provided with web pages without being rendered together with them, in other words downloadable documents (ETSI). For such documents the standard requires, among other things, that they satisfy WCAG success criterion 1.3.1 on info and relationships, that they carry a title describing topic or purpose, and that their default human language can be programmatically determined.

That turns into five traits every file has to carry. First a text layer: the content must be selectable and copyable, because a scan is an image. Second a structure: headings marked up as headings, tables as tables, lists as lists, so that a screen reader knows the order and the relationships. Third the declared language, otherwise the output speaks German text with English pronunciation. Fourth a document title in the properties, because that is what appears in the window title and in the announcement, not the file name. Fifth a text alternative for every illustration that carries a statement: non-text content needs an alternative that serves the equivalent purpose (W3C). The accompanying German regulation adds the principle of providing information through more than one sensory channel.

The scan is the most common case

A scanned price list is not a document but a photograph of a sheet of paper. Screen readers find nothing in it, search finds nothing in it, and enlarging produces blurred edges instead of larger type. If you change only one single thing about your stock, make it this one: every scanned sheet is replaced by the source document or moved onto a page. Every further improvement builds on that.

File name, size and the wording of the link

Even a technically clean file gets lost when the route to it reveals nothing. The link is the last point before the drop-off: this is where someone decides whether to start the download, and this is where a screen reader hears the link text without its surroundings. Six points turn a link into a basis for a decision. They cost a minute per document and take effect on every page where the document is linked, including the overview of your services.

A file name that speaks. price-list-home-care-2026.pdf instead of Scan_0031_final_v3.pdf. The name lands in the downloads folder and is the only label that stays with it there.
Format and size in the link text. Price list from 1 January 2026 (PDF, 210 KB). Anyone on a mobile network decides on that basis whether this is the right moment.
No generic link text. The link text names the document, not the action. A list of links that all read the same is, for a screen reader, a list without content.
The date visible alongside. A document without a date is assumed to be out of date as soon as its content is disputed. The date belongs next to the link, not only inside the document.
Keep the size down. Embedded photographs are the usual reason for double-digit megabytes. Replacing the scan with the source document usually removes most of the weight as well.
One purpose, one document. Bundles with eight attachments in a single file force people to page through. Separate documents can be linked, updated and withdrawn separately.

The rule for every link

A link to a file names three things: what is in it, what format it is in and how large it is. If one of them is missing, the visitor decides blind, and in case of doubt decides against the click.

The review path without specialist tools

For the first round you need neither a testing tool nor training. Six steps settle whether a file is viable at all; everything beyond that is a question of rework. Start with the five files that are opened most often, usually the price list, the service catalogue, the sign-up form, the menu and the application form. Getting those five in order covers the largest share of daily openings.

What comes out of it is a list with three columns: document, finding, decision. The decision has only three values, namely move onto a page, improve the file, or remove it without replacement. The third value is usually underrated: many care websites carry documents that hardly anyone needs any more, yet whose date still counts as a statement. An inspection report from 2019 next to a current offer does more harm than a gap. How such a stocktaking feeds into a relaunch depends above all on how many legacy files come together.

Select and copy

Can the text in the document be selected with the mouse and pasted elsewhere? If not, there is no text but an image, and every further check is beside the point.

Search inside the document

Search for a word that is certainly there. If the search finds nothing, the text layer is missing. If it finds the word in the wrong place, the reading order is disturbed.

Look at the structure

Does the viewer show an outline with headings? If the panel stays empty, the headings are merely formatted large and bold rather than marked up as headings.

Language in the properties

The document properties hold the default language. If it is missing or set to English, the speech output reads German text with the wrong pronunciation.

Check the illustrations

Every illustration that carries a statement needs a text alternative. Purely decorative elements go without, otherwise the announcement grows longer than the content.

Open it on a phone

Open the document on the device most relatives arrive with. Anything that requires pushing in two directions here belongs on a page.

Clearing up the stock and keeping it current

A stock of documents decays quietly. Prices change at the turn of the year, contacts move on, a form gains a field, and the old version stays in the directory because it is still linked somewhere. That is why the document stock belongs in the same rhythm as updates and backups, as described in the article on website maintenance for care services. Without a fixed round, the stocktaking starts from scratch every two years, and each time the pile is larger than it was before. Our maintenance carries that round as a fixed item.

One directory, one list. All documents in one place, with title, date, size and the page on which they are linked. Without that list every check turns into a search.
Replace old versions instead of adding to them. A new file under a new name leaves the old one online. Keeping the address means the old version disappears with the swap.
A date at the turn of the year. Prices, rates and surcharges are the most common reason for an outdated version. A fixed date in January handles the largest part of it.
Check every new file once. The six steps above, before the document is uploaded. Done afterwards, the same work costs several times as much.
Removing is a decision. What nobody needs any more comes off the list, and the address is redirected to the matching page so that old links do not run into nothing.

Anyone starting from scratch has an easier time here: a service building its website alongside the supply contract can draw the line between page and file cleanly from day one, as the article on the website when starting a care service shows. For everyone else the rule of thumb is: the stocktaking usually takes half a day, and moving the five most important documents takes about a week depending on their size. What remains afterwards is a website on which the price list is a page, the sign-up form is a form and the quality report is a file that can actually be opened. If you would rather not go through the stock yourself, we take on the review and the migration as part of accessibility for care websites; a short message through the contact form is enough for a first assessment.

This article is based on data from: the German Accessibility Strengthening Act (BFSG, sections 1, 2 and 3) and its implementing regulation (BFSGV, section 12), gesetze-im-internet.de; EN 301 549 V3.2.1 (2021-03), chapter 10, ETSI; the Web Content Accessibility Guidelines 2.1, W3C; the care statistics, the severe disability statistics and the 2025 survey on internet use in private households, Federal Statistical Office of Germany.

Website & design

Care Website Relaunch 2026: When It Pays Off

Many care websites predate the BFSG, load slowly on mobile and are not accessible. When a clean relaunch really pays off in 2026 - and when patching is enough.

13 min read

Accessibility & operations

BFSG 2025: Accessibility for Care Services

The BFSG has applied since June 2025: which care services are affected, what WCAG 2.2 requires and why accessibility matters most for an older audience.

12 min read

Marketing & occupancy

Switching care provider: a page that welcomes switchers

Switching home care provider: termination without notice under Section 120 SGB XI, costs in advance, a handover without a gap. How to build a switching page with a form.

15 min read