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Accessibility in the restaurant industry – an underestimated issue

Around 13 million people in the UK live with a recognised severe disability. In addition, there are millions of older people who suffer from impaired vision, motor difficulties or cognitive impairments – without being officially classified as ‘disabled’. They are all potential guests. And they all regularly encounter unnecessary barriers in the catering industry.

One of these is the menu. Too small print, poor colour contrast, no accessible digital menu – for many people, this means guessing, asking questions, relying on help. Or simply going elsewhere.

As a restaurateur, you have the opportunity to change that. And from 2025, you will also have to do so in some areas.

Legal basis: What applies and when?

The Accessibility Enhancement Act (BFSG)

The Accessibility Enhancement Act (BFSG), which transposes the European European Accessibility Act (EAA) directive into German law, has been in force since June 2025. It obliges companies to offer certain digital products and services in an accessible format.

Relevant for restaurateurs: Anyone who operates a website, online shop or app – for example, offering online reservations, digital menus or ordering apps – must design them to be accessible. The requirements are based on the internationally recognised Web Content Accessibility Guidelines (WCAG 2.1, conformance level AA).

Exceptions apply to micro-enterprises (fewer than 10 employees and less than £2 million in annual turnover) if accessibility represents a disproportionate burden. For everyone else, action is needed now.

Existing regulations for the public sector

If you operate a restaurant in a public building or are part of a publicly funded institution (e.g. canteen in a government office, university canteen, event catering for municipal institutions), stricter requirements may already apply under the Barrier-Free Information Technology Ordinance (BITV 2.0) or comparable state regulations.

What does WCAG 2.1 mean for digital menus?

The WCAG – the Web Content Accessibility Guidelines of the World Wide Web Consortium (W3C) – define how digital content must be designed so that it can be used by as many people as possible. They are divided into four basic principles: Perceivable, Operable, Understandable and Robust (POUR).

For a digital menu, this means specifically:

Perceivable

All content must be presented in such a way that it can be perceived by as many people as possible – regardless of sensory limitations.

  • Contrast ratio: Text must have a minimum contrast ratio of 4.5:1 against the background (for large fonts from 18pt: 3:1). A light grey on a white background is therefore not permitted.

  • Alternative text for images: Each image of a dish needs descriptive alt text so that screen reader users know what is depicted.

  • No purely visual information: Allergens must not be identified solely by colour, as people who are colour blind cannot recognise this. Symbols or text must supplement or replace the colour.

Usable

All functions of the map must be usable without a mouse, i.e. via keyboard or voice control.

  • Keyboard navigation: Menu items, filters and buttons must be accessible via the tab key.

  • No time limits: If your digital map has sessions (e.g. in an ordering app), there must be no hard time limit without warning.

  • Focus indicators: When navigating with the keyboard, it must always be clear which element is currently active.

Understandable

Content and operation must be clear and predictable.

  • Mark language: The HTML code of the page must declare the language of the content (lang=‘en’) so that screen readers can read it correctly.

  • Error messages: If your map has ordering functions and an input error occurs, the error message must clearly describe what was wrong and how it can be corrected.

  • Consistent navigation: Categories and navigation elements should be arranged in the same way on all subpages.

Robust

Content must be structured in such a way that it is compatible with current and future assistive technologies (screen readers, Braille displays, etc.).

  • Clean HTML: Use semantically correct HTML – headings as <h1>, <h2> etc., lists as <ul> or <ol>, no purely visual formatting without structural meaning.

  • ARIA labels: Where HTML semantics are insufficient, ARIA attributes help to provide screen readers with additional contextual information.

Practical implementation: How to make your digital menu accessible

Step 1: Take stock

Before you optimise, you need to know where your menu stands. Tools such as the WAVE Web Accessibility Evaluator (free, wave.webaim.org) or the axe browser extension scan your website and highlight violations of WCAG criteria at a glance.

Step 2: Check contrasts and typography

Check all font-background combinations with a contrast checker (e.g. contrast-ratio.com). Pay particular attention to price information, ingredient lists and footnotes – these are often set in small, light grey font and then fail the WCAG test.

Minimum font size for continuous text on digital menus: 16px. For headings, use a correspondingly larger font size.

Step 3: Add alt text to images

Each image of a dish needs specific alt text that describes the dish – not just ‘image’ or “photo”. Good alt text for a pasta dish could be: ‘Tagliatelle with porcini mushrooms, Parmesan and fresh thyme in a deep plate’. Decorative images with no informational content are given an empty alt attribute (alt=‘’) so that screen readers skip them.

Step 4: Test keyboard navigation

Open your digital menu and try to navigate it using only the tab key. Can you access all categories, dishes and filter functions? Is it always clear where you are? If not, your developer will need to make adjustments.

Step 5: Publish an accessibility statement

The BFSG requires affected companies to publish an accessibility statement on their website. This documents the current implementation status, known deficiencies and a contact channel for feedback. Templates for this can be found at the Federal Accessibility Agency.

Printed menus: What can be improved?

The BFSG primarily applies to digital offerings. There is currently no nationwide legal requirement for accessibility for printed menus. Nevertheless, it is worth paying attention to barrier-free design here too – not only for ethical reasons, but also because it improves readability for all guests:

  • Font size at least 12pt, preferably 14pt for dishes and descriptions

  • High-contrast design – black text on a white or cream background is most legible

  • Sans serif fonts such as Arial, Helvetica or Gill Sans are easier to read for people with visual impairments than serif fonts

  • Sufficient line spacing (at least 1.5 times) makes reading easier for people with dyslexia

  • Have large menus in large print available on request – a simple A3 printout with enlarged text can be a real bonus for visually impaired guests

What are the consequences of violating the BFSG?

Violations of the Accessibility Enhancement Act can be punished by market surveillance authorities. The competent authorities of the federal states can impose fines for violations. In addition, recognised associations have the right to issue warnings – similar to competition law. The risk of costly warnings should not be underestimated, especially if competitors are actively monitoring the new legal situation.

Furthermore, anyone who operates a digital map that cannot be used by people with disabilities may, in certain circumstances, be accused of discrimination under the General Equal Treatment Act (AGG).

Accessibility as a competitive advantage

Accessibility sounds like a lot of work – and initially it is. But the perspective is worth it: around 25 per cent of the population benefit directly from accessible services, if you include older guests, people with temporary limitations (e.g. broken arm, eye infection) and parents with small children in addition to people with disabilities.

Accessible digital menus are also better for SEO: search engines read alt text, clean HTML structure and semantically correct markup – and reward them with better rankings. Accessibility and search engine optimisation go hand in hand here.

Conclusion: Act now, don't wait

The Accessibility Enhancement Act is in force. Anyone who operates digital menus, ordering apps or online reservations and is not a micro-enterprise must take action – now at the latest. But even regardless of legal obligations, an accessible menu is a better menu. It is more readable, user-friendly, better structured and excludes no one.

Start by taking stock, fix the most obvious shortcomings in contrast and alt text, and then work systematically towards a fully WCAG-compliant solution. Your guests – all of them – will thank you for it.