Accessible CAPTCHA: WCAG 2.2 and the European Accessibility Act

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Quick answer

Many CAPTCHAs rely on visual or cognitive tasks that exclude people who use screen readers or have motor or cognitive impairments. WCAG 2.2 sets the common benchmark, and in Germany the BFSG, which implements the European Accessibility Act, has applied to many online services since 28 June 2025. The most accessible CAPTCHA is one the visitor never has to solve.

Why puzzles are an accessibility problem

  • Image selection depends on sight and fast visual recognition. A screen reader cannot describe the pictures by design.
  • Distorted text is hard to read for people with low vision or dyslexia.
  • Audio alternatives are hard to understand for people with hearing impairments and for non-native speakers.
  • Timed or drag-and-drop interactions are difficult for people with motor impairments.

What the standards say

WCAG 2.2 success criterion 3.3.8 (Accessible Authentication, Minimum, level AA) says a login step must not depend on a cognitive function test such as solving a puzzle, unless an alternative or assistance is available. It applies to authentication, but it shows the direction of travel for all form checks.

The European Accessibility Act (Directive (EU) 2019/882) requires many consumer-facing digital services to be accessible. In Germany it is implemented by the Barrierefreiheitsstärkungsgesetz (BFSG). Check whether your service is in scope and whether a CAPTCHA on your checkout, sign-up or contact form could block users.

Checklist for accessible bot protection

Checklist for choosing an accessible CAPTCHA
CheckWhat good looks like
InteractionNo puzzle to solve; if there is a challenge, a non-visual alternative exists.
KeyboardEverything works with the keyboard only, with a visible focus.
Screen readerStates such as “verifying” and “done” are announced.
Time limitsNo short timeouts that a slow user cannot meet.
EvidenceA published accessibility statement or audit report, not only a badge.

Why proof-of-work helps

With proof-of-work the browser does the work and the visitor does nothing. There is no image to interpret and no memory or reading task, so the check is no barrier by itself. BurgCaptcha follows this approach; see the accessibility statement for details.

Frequently asked questions

Does the European Accessibility Act apply to my website?

It applies to certain consumer-facing products and services, such as e-commerce, banking services and e-books, with exceptions for micro-enterprises providing services. Check the BFSG and ask a lawyer about your case.

Is an audio CAPTCHA an accessible alternative?

It helps people who cannot see images, but it excludes people with hearing impairments and is hard for many users. A check the visitor does not have to solve is better.

What WCAG level should I aim for?

Level AA of WCAG 2.2 is the usual benchmark in procurement and in the harmonised standard for the European Accessibility Act.

Sources

See BurgCaptcha on your own forms.