Digital accessibility

Declaration on accessibility

As the provider of the muenchen app, Stadtwerke München GmbH attaches great importance to the barrier-free usability of its services for all citizens and users. As a public body within the meaning of Directive (EU) 2016/2102, we endeavor to make our products and mobile applications accessible in accordance with the provisions of the Disability Equality Act (BGG) and the Barrier-free Information Technology Ordinance (BITV 2.0) for the implementation of Directive (EU) 2016/2102.

The legal basis for the barrier-free design is the  Verordnung über die Digitalisierung im Freistaat Bayern (Bayerische Digitalverordnung – BayDiV) in conjunction with the Barrierefreie-Informationstechnik-Verordnung (BITV 2.0).

Status of compatibility with the requirements

Together with the Kompetenzzentrum für Digitale Teilhabe für Alle of the Stiftung Pfennigparade, 6 common user scenarios were defined and then tested.

Stiftung Pfennigparade tests in accordance with the basic requirements of EU Directive 2016/2102. The relevant test points of the EU accessibility requirements for IKT products and services according to the harmonized European standard EN 301 549, version 3.2.1 are applied. Table A.2: Mobile applications.

The muenchen app is partially compatible with the Verordnung über die Digitalisierung im Freistaat Bayern (Bayerische Digitalverordnung – BayDiV) The incompatibilities and/or exceptions are listed below.

Non-accessible content

  1. Some texts that serve as headings are not marked as headings at code level and therefore cannot be accessed with the screen reader.
  2. Not all list structures are marked as a list at code level and therefore cannot be perceived by the screen reader.
  3. The order in which the elements are accessed when using an active screen reader does not correspond to the logical or visual representation.
  4. Some elements cannot be reached when the screen reader is active.
  5. The product does not support landscape orientation.
  6. In some places, texts do not have the required minimum contrast values and may therefore be difficult or impossible to recognize for users with color vision deficiencies.
  7. In some places, graphic control elements do not have the required minimum contrast values and may therefore be difficult or impossible to recognize for users with color vision deficiency.
  8. There are functions that cannot be operated with an external keyboard.
  9. Some texts or words that do not correspond to the main language of the product are not correctly labeled at code level, which leads to incorrect pronunciation by the screen reader.
  10. When a page is called up, the focus is not initially placed on the page title or the main heading. This may make orientation with the screen reader more difficult.
  11. For some dynamic changes in the product that do not receive the focus, no feedback is given by the screen reader about the updated content.
  12. After leaving certain areas of the product, the focus is not set to the opening element as expected, which makes orientation more difficult for blind users.
  13. Some product controls do not display their name, role and value in the expected order when the screen reader is active.
  14. There are controls that do not have the correct role at code level. As a result, screen reader users may not recognize the expected behaviour.
  15. For some dynamic changes in the product that do not receive the focus, the screen reader does not provide any feedback about the updated content.
  16. The product contains text elements whose content differs from the visually visible text content when the screen reader is active.
  17. When using word-by-word and character-by-character navigation with the screen reader, the focus is not or insufficiently tracked when the zoom is active.
  18. Technical support is not yet able to respond immediately to every request regarding the accessibility of the product.
  19. At the moment, technical support can only be contacted by email. The support service is therefore not easily accessible for all user groups.

Creation of this accessibility statement

This accessibility statement relates to the muenchen app, version 1.4.0, for the ANDROID operating system. It was created on October 24, 2023 and last reviewed on March 31, 2023.

Reporting barriers and information on accessibility

Would you like to report existing barriers or request information on the implementation of accessibility? For your feedback and all other information, please contact our responsible contact persons at

The contact person for barrier-free accessibility is:

Stadtwerke München GmbH

Emmy-Noether-Straße 2

80992 Munich

E-mail address:

Enforcement procedure

As part of an enforcement procedure, you have the option of submitting an Antrag auf Prüfung der Anforderungen an die Barrierefreiheit gem. § 11 BayDIV.

Contact details of the enforcement office:

Landesamt für Digitalisierung, Breitband und Vermessung

IT Service Center of the Free State of Bavaria

Enforcement and monitoring body for barrier-free information technology

St.-Martin-Straße 47

81541 Munich


Conciliation procedure

If no satisfactory solution has been found after your feedback to the above-mentioned contact, you can contact the arbitration board in accordance with Section 16 of the Disability Equality Act (BGG). The Arbitration Board BGG has the task of supporting out-of-court dispute resolution in the event of conflicts between people with disabilities and federal public bodies on the subject of accessibility. The conciliation procedure is free of charge. No legal assistance is required. Further information on the conciliation procedure and how to submit an application can be found at:

You can contact the BGG conciliation body directly at