Accessibility statement
For https://icd360s.de · as at 11.08.2026
At a glance
Partially compliant
- 40 checked and met
- 5 open
- 10 not applicable
- 13 settings for how the pages look
- 5,05:1 contrast in the weakest case — 4.5:1 is required
- Fully operable without a mouse
ICD360S e.V. wants these pages to be usable by as many people as possible. The basis is the Web Content Accessibility Guidelines (WCAG), version 2.2, level AA.
This statement is voluntary. Under § 12a BGG it is public bodies that are obliged to publish one; the association is not one. It stands here because under § 2 (h) of the statutes the majority of the board are people with disabilities — anyone who makes self-representation a principle should be able to account for their own website.
State of compliance
Partially compliant. Of the 55 success criteria of WCAG 2.2 (levels A and AA), 10 do not apply to these pages — there is no video, no audio recording apart from the read-aloud (which is an alternative to the text) and no login with a password. Of the remaining 45, 43 are met, one is only partially met (2.4.11, the focus can be obscured) and one is open (1.3.3). Both are named below.
On 15 August 2026 four criteria that had previously been violated were repaired: reflow at 320 pixels (1.4.10), operating the ledger tables without a mouse (2.1.1), the obscured focus (2.4.11, partially) and the label in the accessible name (2.5.3). The measurements behind this: 20 pages in 5 display states, 6,463 text positions for the contrast, 234 controls for the contrast of borders and icons.
How these figures were arrived at
⚠️ These figures were re-established on 15 August 2026, and the previous version was wrong: it counted 21 criteria as not applicable on the grounds that there were „no forms and no login". Since then the membership application, the contact form and the withdrawal form have been added — which made eight criteria about input, error messages and status messages apply again. Anyone adding a form recounts here: a body of content that changes turns a correct figure into a false one.
No formal BITV test has been carried out. „Partially compliant" therefore means: what could be measured was measured; the rest is open and is not declared as met.
What is in place
13 settings via the symbol at the right-hand edge of the screen. They are kept across all pages.
Text
- Text size
- Typeface
- Line spacing
- Paragraph spacing
- Letter spacing
- Line length
Colours
- Contrast
- Colour scheme
Orientation
- Links
- Headings
- Keyboard focus
- Motion
- Speak button names
4,5:1 is required
- Contrasts measured, not estimated: on 15 August 2026 across ten pages and all three colour schemes, 1031 pieces of text per scheme, in the browser and from the colours actually computed. Weakest value in the light scheme 5.05:1, in the dark scheme 5.77:1, in high contrast 10.13:1 — the requirement is 4.5:1. Nothing falls below it.
- Every page has a colour tone — it helps with navigation but never carries information on its own: the heading and the menu say the same thing, and anyone who cannot distinguish colours loses nothing (WCAG 1.4.1). These tones are calculated too: as text on a light background 6.05:1 to 7.22:1, white type on a coloured surface 6.49:1 to 7.74:1, in the dark scheme 7.89:1 to 10.31:1. The weakest value in the whole colour system is 5.68:1. In high contrast all tones fall away — there, 21:1 comes from black and white alone.
- Text spacing under WCAG 1.4.12 is fully adjustable: line height, paragraph spacing, letter and word spacing.
- Text size follows your browser setting and can additionally be changed in four steps.
- Operable without a mouse. Every page begins with a skip link to the content, all controls have a visible focus outline, which can be strengthened on request.
- Controls are at least 24 × 24 pixels, as WCAG 2.5.8 requires; most reach 44 × 44. Measured at window widths of 320 and 1280 pixels. ⚠️ Until 15 August 2026 this said „at least 44 × 44 pixels". That was wrong — five controls were below it, the smallest at 100 × 20. 44 × 44 is WCAG 2.5.5 and belongs to level AAA; level AA is governed by 2.5.8 with 24 × 24.
- Motion follows the system setting „reduce motion" and can additionally be switched off.
- No third-party code. The pages load nothing from other servers and work without JavaScript apart from one short script of our own; if it is switched off, everything remains operable.
- Read aloud in all eleven languages. Every page has a ready
recording, spoken in the language you are reading it in. It sits on our
own server and is only loaded once you press the button — no outside
service learns who has what read to them. Speed can be changed, and in
German the voice as well.
The recordings are machine-generated. Proper names
and German legal references such as “§ 25 AufenthG” are audibly
mispronounced by a non-German voice; we leave them in all the same,
because otherwise a citation cannot be found again.
Generated with Piper. The Italian voice is based on the corpus serena-synthetic-it-27h (CC BY 4.0), the French one on the corpus Multilingual LibriSpeech (CC BY 4.0), the Spanish one on the corpus OpenSLR SLR61 (CC BY-SA 4.0), the Ukrainian one on the ukrainian-tts-datasets (Apache 2.0), the English one on recordings from LibriVox (public domain); the German, Bulgarian, Polish, Romanian, Russian and Albanian voices on datasets under CC0.
The four principles of WCAG
The 55 success criteria are not a list but four questions. Here is where these pages stand on each of them:
Perceivable
You can take the content in — even without seeing or hearing.
11 met · 3 open · 6 not applicable
Operable
You can operate everything — even without a mouse.
16 met · 1 open · 3 not applicable
Understandable
You understand what is happening on the screen.
11 met · 1 open · 1 not applicable
Robust
It works together with assistive technology.
2 met
What a BITV test would check on top
The BITV test is the established German test procedure. It has not been carried out for these pages — this is what it does differently.
- met
- mostly met
- partly met
- mostly not met
- not met
Only the first two steps count as met. If a single test step comes out worse, the page is not conformant.
Content that is not accessible
The statutes as a PDF
The statutes are additionally available as a certified copy in PDF form. That PDF is a scan; one page of it is a pure image file without a text layer and is not accessible to screen readers.
Alternative: the same text is on the statutes page in full as HTML — searchable, enlargeable and usable with all the display settings. The PDF is the attachment, not the main route.
Not everything in every language
These pages exist in full in German, English, Spanish, French, Italian, Polish, Romanian, Russian, Ukrainian and Albanian and Bulgarian — including the long legal texts. The language can be chosen via the translate symbol at the right-hand edge and is detected from your browser setting on your first visit.
A barrier nevertheless remains, and it is a threefold one. Plain language has existed since 15.08.2026 — by now for every page, including the statutes and the privacy policy, where it helps most. It is, however, German, and it is unchecked: people with learning difficulties have not read the texts yet, which is why they carry no plain-language logo. One exception remains, the membership application — and there the page does not even say so. Ten languages are not the languages of everyone the association addresses under § 2 of its statutes; among them are refugees, who are often only just learning German. And for the legal texts the translation is a reading aid, not the legal position: the German version remains the binding one, because it is the German statutes that are filed with the register court and only the German withdrawal notice that follows the statutory model. That is stated at the top of each of the three pages, not in the small print. For Russian and Ukrainian there is a further point: the EU model texts do not exist officially in those languages either — neither is an official language of the Union — so the translation of those models is our own. Each of those pages says so itself.
Planned: having the plain-language page checked by a review group, plain language for the statutes and the privacy policy as well, plus further languages. Alternative until then: write to us in your own language — we will answer in it.
The focus can still be obscured
Anyone moving through a page with the tab key can in a few cases land on a control that is currently behind the sticky page footer or behind the floating symbols — it then has the focus but cannot be seen (WCAG 2.4.11). Affected are above all the „Back to top" button on very narrow screens and individual links right at the end of the page, below which there is no scrolling distance left.
Measured on 15 August 2026 and considerably improved: of 97 such places, 20 remain, at normal text size 7. Alternative: scroll the page on a little — the control stays operable, and the Enter key works even then.
Not yet tested
One success criterion is open, because it calls for a judgement about content and not a measurement: instructions that rely on shape, location or size alone (1.3.3). These pages refer in several places to „the symbol at the right-hand edge of the screen" — a statement of location. It stands next to the name of the symbol each time; whether that is enough belongs in a review by people.
Re-measured on 15 August 2026 and met since then: the contrast of borders and icons (1.4.11 — 234 controls in three colour schemes, weakest value 3.23:1 against the required 3:1), the behaviour of additional content shown (1.4.13), undoing a pointer input (2.5.2) and the review step before sending the membership application (3.3.4). Repaired the same day were reflow at a window width of 320 pixels (1.4.10), operating the ledger tables without a mouse (2.1.1) and the label in the accessible name (2.5.3).
Feedback and contact
Have you come across a barrier, or do you need content in a different form? Write to us — we will put it right and make the content available to you by another route.
ICD360S e.V.c/o Ionut-Claudiu Duinea
Elsa-Brandström-Straße 13
89231 Neu-Ulm
E-mail: kontakt@icd360s.de
Telephone: +49 731 80159736
Mobile: +49 160 94482053
Enforcement procedure
A conciliation procedure under § 16 BGG is open only against federal public bodies and is not available against an association. If you are not satisfied with our answer, please contact the board again; the names are in the legal notice.