Accessibility in the workplace is not a standing duty for every business under section 3a paragraph 2 ArbStättV. It is triggered as soon as a person with a disability is employed. From then on, workstations, sanitary, break and on-call rooms and the associated doors, traffic routes, escape routes, emergency exits, stairs and orientation systems must be accessible.
An accessible workplace under number 3.2 ASR V3a.2 exists where buildings, work equipment and sources of information can be reached and used by employees with disabilities in the usual way, without particular difficulty and, as a rule, without outside help. In an office the list is short: entrance and lift, door widths, a usable sanitary room, the escape route, the alarm. The duties quick-check sorts out the rest.
| Rule | Trigger | What is required |
|---|---|---|
| Section 3a paragraph 2 ArbStättV | employment of a person with a disability | accessible design of the areas that person needs access to |
| Section 164 paragraph 4 SGB IX | employment of a severely disabled or equivalent person | disability-appropriate fitting out and technical aids as an individual entitlement |
| Building regulations of the federal states | publicly accessible parts of the building | accessibility regardless of whether people with disabilities are employed |
| Section 1 BFSG | products and services for consumers since 28 June 2025 | no requirements for the workplace |
When the accessibility duty arises
The duty arises on a trigger. Under number 2(1) ASR V3a.2 accessible design is required whenever people with disabilities are employed. What has to be accessible are the areas those employees need access to, not the whole building.
A disability exists under number 3.1 ASR V3a.2 where a physical function, mental ability or psychological health very probably deviates for more than six months from the state typical for that age and this restricts the person at work. Hearing loss, severe visual impairment and loss of strength from muscular disease are named explicitly.
The point that matters is scope: under number 2(3) ASR V3a.2 the duty covers all employees with a disability, not only those known to be severely disabled, including a degree of disability below 50. Looking only at disability cards means checking past the rule.
Where a disability is not obvious, number 4(2) ASR V3a.2 names five sources: the person concerned, the representative body for severely disabled employees, company integration management, the risk assessment, and walkthroughs by the occupational safety specialist.
The dimensions ASR V3a.2 sets
ASR V3a.2 spells out section 3a paragraph 2 ArbStättV and supplements the other Technical Rules for Workplaces with accessibility requirements. It dates from August 2012 and is extended continuously, most recently in the Joint Ministerial Gazette 2025, page 365. Following it satisfies the ordinance to that extent.
| Element | Requirement | Reference |
|---|---|---|
| Clear passage width of doors and gates | at least 0.90 m | Annex A1.7 paragraph 13 |
| Movement area in front of hinged doors | 120 cm, 150 cm where a wall faces the door | Annex A1.7 paragraph 1 |
| Door and gate thresholds | avoid; at most 20 mm with a bevel if unavoidable | Annex A1.7 paragraph 12 |
| Force needed to open a door | no more than 25 N, torque no more than 2.5 Nm | Annex A1.7 paragraph 14 |
| Clear width of escape routes without passing | at least 1.00 m, locally not below 0.90 m | Annex A2.3 paragraph 2 |
| Clear width of escape routes with passing | at least 1.50 m | Annex A2.3 paragraph 2 |
| Controls on the escape route | height no more than 0.85 m | Annex A2.3 paragraph 7 |
The figures apply to employees using a walking aid or wheelchair and deliberately depart from the general dimensions in ASR A1.7 and ASR A2.3. Where an escape route runs through a turnstile, paragraph 6 requires an alternative route.
Not every requirement is structural: number 4(4) ASR V3a.2 also calls for alternatives, such as a button beside the door handle or a ramp beside the stairs.
The two-senses principle: alarm and escape route
The two-senses principle under number 3.3 ASR V3a.2 is the principle of alternative perception: information has to reach at least two of the three senses of hearing, seeing and touch, for example through a simultaneous visual and audible alarm. In an office that means the fire alarm, escape route signage and the escape and rescue plan.
Under Annex A2.3 paragraph 8, alarming employees with visual or hearing impairments who use inner rooms requires the two-senses principle. An inner room can only be left through another room, typically an internal meeting room. A siren alone will not do.
For the escape and rescue plan, Annex A2.3 paragraph 5 requires safety-relevant information to be conveyed understandably: larger characters under table 3 of ASR A1.3, documents handed to employees with visual impairments, and plans legible from wheelchair eye level. When a plan is mandatory is set out in escape and rescue plans in the office.
The last stage is organisational. Annex A2.3 paragraph 9 names buddy arrangements: briefed colleagues who warn, accompany or assist in an emergency. They are named individually and join evacuation drills under paragraph 10.
The risk assessment is the evidence
The risk assessment is the systematic identification and evaluation of all hazards at a workplace required by section 5 ArbSchG. Number 2(1) ASR V3a.2 requires the effect of the disability and the individual requirements that follow to be considered there. Without that item, nothing evidences the check.
In practice: a separate section per person, with the areas they need access to, the deviations found, the measure, an owner and a deadline. Under section 6 paragraph 1 ArbSchG the result, the measures and the review are documented.
Every change is a reason to update: a new hire, a return after long-term illness, a move. Structure and minimum content sit in risk assessment in the office, the usual gaps in 7 risk assessment mistakes in offices, the desk in display screen workstations.
The employment quota from 20 jobs: the second obligation
Accessibility under ArbStättV and the employment quota under SGB IX are two different duties. ArbStättV governs how the workplace is designed when a person with a disability works there. SGB IX governs how many severely disabled people a business must employ, and what falling short of that costs.
Employers with at least 20 jobs on a monthly annual average have to fill at least 5 percent of those jobs with severely disabled people under section 154 paragraph 1 SGB IX. Otherwise section 160 SGB IX levies a monthly compensatory payment for each unfilled mandatory job.
| Metric | 10 employees | 30 employees | 80 employees |
|---|---|---|---|
| Accessibility under section 3a paragraph 2 ArbStättV | case-triggered, no threshold | case-triggered, no threshold | case-triggered, no threshold |
| Employment quota under section 154 SGB IX | no | yes, 1 mandatory job | yes, 4 mandatory jobs |
| Compensatory levy at zero employment | none | 210 euros per month | 720 euros per unfilled job and month |
| Representative body under section 177 SGB IX | from 5 such employees | from 5 such employees | from 5 such employees |
The rates are staggered. For employers with fewer than 40 jobs, section 160 paragraph 2 SGB IX sets 210 euros where no severely disabled person is employed. Otherwise the scale runs from 140 euros at a quota of 3 percent up to 720 euros at zero.
Disproportionate expense and funding
The duty is not unlimited. Where technical measures involve obviously disproportionate expense, number 2(2) ASR V3a.2 lets the employer ensure safety and health protection in a comparable way through organisational or person-related measures. Technical measures stay the priority under number 4(1).
In parallel, the entitlement under section 164 paragraph 4 sentence 3 SGB IX lapses where meeting it would be unreasonable or disproportionately expensive. Disproportionality has to be evidenced, not asserted: a quotation and the examined alternative belong on file.
The funding application comes before the conversion. The integration office may provide cash benefits under section 185 paragraph 3 SGB IX for disability-appropriate fitting out and for technical aids. Measures already ordered are rarely subsidised.
Making a workplace accessible in six steps
In an office the process takes a few weeks and starts with the risk assessment, not a contractor. The order matters, because step five decides the cost.
- Establish the trigger. Check whether a person with a disability under number 3.1 ASR V3a.2 is employed or about to be hired. The duty attaches to employment, not to a disability card.
- Extend the risk assessment. Add the individual requirements as a separate item under section 5 ArbSchG and name the areas the person needs access to.
- Measure routes, doors and sanitary rooms. Check clear door widths, movement areas, threshold heights and the sanitary room against the ASR V3a.2 dimensions; note every deviation.
- Check alarm and escape route. Review escape route width, control heights, the rescue plan and the alarm against the two-senses principle.
- Apply for funding first. Claim integration office benefits under section 185 SGB IX before placing the order.
- Document and train. Record the measures with a date and a responsible person in the risk assessment; train the nominated accompanying persons.
To review the remaining records too, work through the office safety checklist.
Safety Club supports office and administrative businesses through this review: an occupational safety specialist on site plus digital, audit-proof documentation owned by the business. We go through your case in an initial consultation.
This article is general guidance and does not replace legal advice on your individual case. What governs is the current version of the ArbStättV, ArbSchG, SGB IX and ASR V3a.2, together with the building regulations of the federal state you are in.
