Law & compliance

Getting Serious: Accessibility Becomes Law

11 min read

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Quick answer

The Austrian Accessibility Act (BaFG) has applied since 28 June 2025. It does not cover every website, but an exhaustive list of services set out in the statute: electronic communications services, access to audiovisual media services, elements of passenger transport services, consumer banking services, e-books and services in electronic commerce, meaning online shops. A purely informational company website without a shop, booking or banking function falls outside it. Micro-enterprises employing fewer than ten people, with a turnover or balance sheet total of no more than two million euros, are exempt for services but not for products. The yardstick is the WCAG at level AA, currently version 2.2. The Sozialministeriumservice supervises and can impose fines of up to 80,000 euros. This article is not legal advice.

Since the summer of 2025, Austria has had a law that makes digital accessibility binding. Ever since, half-knowledge has been circulating: that every website is covered, that existing sites have until 2030, that an embedded widget settles the matter. We read the statute itself and sort out what it actually says – and what follows from that for your website.

When did the Austrian Accessibility Act take effect?

The Austrian Accessibility Act (Barrierefreiheitsgesetz, BaFG, BGBl. I No. 76/2023) took effect on 28 June 2025. From that day on, the products and services covered by the statute have had to be offered accessibly. The BaFG transposes the European Accessibility Act into Austrian law.

For providers, that means the preparation window has closed. The statute does contain a narrowly drafted transitional rule for products already in use – more on that below – but no general grace period. Anyone offering one of the covered services has to meet the requirements. What the Austrian Accessibility Act demands in detail, however, depends heavily on what you actually offer. That is precisely where the most common misunderstanding starts.

Who is covered by the Austrian Accessibility Act?

The law covers providers of the services that Section 2(2) lists exhaustively. Among them are online shops, consumer banking services and e-books. Anyone who provides none of these services falls outside the statute – even if the website is large, well known or professionally run.

Which services does the statute list?

The list is short and exhaustive. “Exhaustive” means: whatever is not on it is not covered. The legislator did not draft the enumeration as a set of examples but as a complete list.

  • electronic communications services
  • services providing access to audiovisual media services
  • certain elements of passenger transport services – websites, apps and electronic tickets among them
  • consumer banking services
  • e-books and the software needed to read them
  • services in electronic commerce, in other words online shops

Does an ordinary company website fall under it?

No. A website that informs people about a company, describes its services and offers a contact form provides none of the services named in the statute and is not covered by the Austrian Accessibility Act. Function is what counts: as soon as customers can buy, book or pay on the site, the picture changes.

The Austrian Accessibility Act does not cover every website. It covers the services listed exhaustively in Section 2(2) – among them online shops, consumer banking services, e-books and elements of passenger transport services. A purely informational company website without a shop, booking or banking function falls outside the statute and need not meet its requirements.

Source: RIS: Austrian Accessibility Act, Section 2 (opens in a new tab)

This clarification matters to us because a great deal around the statute is sold through fear. “Every website has to be accessible now” is simply wrong. The reverse holds too: anyone running a shop, embedding a booking system or offering payment services should look closely at their own situation. In borderline cases – a company website with a bolted-on shop module, say – what is actually offered decides the question, not what the page is called. Only a legal assessment can answer it bindingly; this article is no substitute for one.

Is there an exemption for small companies?

Yes, but only for services and only for genuine micro-enterprises. The statute defines one as a company employing fewer than ten people that also has either an annual turnover of no more than two million euros or a balance sheet total of no more than two million euros. For products, the exemption expressly does not apply.

Under the Austrian Accessibility Act, micro-enterprises are exempt from the requirements that apply to services. A micro-enterprise employs fewer than ten people and has either an annual turnover of no more than two million euros or a balance sheet total of no more than two million euros. The exemption does not extend to products.

Source: RIS: Austrian Accessibility Act, Section 6 (opens in a new tab)

The two conditions work together: the headcount has to stay below ten, and on top of that one of the two financial figures has to stay below the threshold. A company with twelve employees is not a micro-enterprise, however modest its turnover. Anyone relying on the exemption should be able to evidence the figures – to the authority, if it comes to that. We have written up the distinction in our glossary under micro-enterprise exemption.

Do existing websites have until 28 June 2030?

No, at least not across the board. Until 28 June 2030, the statute allows service providers to continue offering or providing their services using products that they were already lawfully using before 28 June 2025. The wording says nothing about existing websites.

The Austrian Accessibility Act contains no general grace period until 2030 for existing websites. Until 28 June 2030, the transitional provision merely permits services to continue being provided using products that were already lawfully in use before 28 June 2025. The widespread reading goes further than that wording allows.

Source: RIS: Austrian Accessibility Act, Section 37 (opens in a new tab)

The difference between “product” and “service” is not legal hair-splitting here; it is the heart of the rule. Products in the sense of the statute are things like self-service terminals, payment terminals or e-book readers. Anyone leaning on the transitional provision should therefore have it checked carefully against their own case. We are not a law firm and we give no legal advice – but we would rather say so plainly than lull you into a deadline that does not exist in that form.

What penalties apply if the requirements are missed?

The statute provides for fines of up to 80,000 euros; for micro, small and medium-sized companies the ceiling is 50,000 euros. Market surveillance and proceedings are the responsibility of the Sozialministeriumservice. There is no blanket inspection regime – in practice, proceedings usually start with a complaint.

The economic damage, though, rarely sits in the fine. If part of your customer base gets stuck at checkout, you lose revenue long before any authority hears about it. A form that cannot be filled in without a mouse is not a legal problem; it is an abandoned purchase. How supervision and proceedings work is set out in our glossary under market surveillance and sanctions.

Which standard is accessibility assessed against?

The yardstick is the Web Content Accessibility Guidelines (WCAG) at conformance level AA, currently in version 2.2. The European standard EN 301 549, on which the legislation builds, adopts these success criteria. Level A on its own is not enough; level AAA is not what the law asks for.

The yardstick for digital accessibility is the W3C's Web Content Accessibility Guidelines at conformance level AA, currently version 2.2. The European standard EN 301 549 adopts these success criteria and thereby forms the technical basis against which accessible websites and apps are measured in the European Union.

Source: W3C: WCAG 2.2 (opens in a new tab)

What does level AA mean in practice?

The WCAG are not a design corset but a list of testable criteria. Most of them concern craft rather than looks – an accessible layout usually looks exactly as it did before. The six points that make the biggest difference in our audits:

  • Every function can be reached with the keyboard, and you can always see where you are.
  • Headings follow the right order, lists are lists, buttons are buttons.
  • Text stands out sufficiently from its background – the WCAG set a calculable minimum ratio for this.
  • Images that carry meaning have alternative text; purely decorative ones deliberately have none.
  • Form fields are labelled, and error messages say what to do about it.
  • The page stays readable and operable when you zoom in substantially in the browser.

How do I find out where my website has barriers?

Put the mouse aside and operate your website with the tab key alone. Can you reach everything? Can you always see where you are? Does the menu open, the form fill in, the dialogue close? That single test takes a few minutes and reveals a surprising amount.

A second test: zoom in substantially in the browser. Does everything stay readable and operable, or does the text start to overlap? Automated checkers additionally find the technical faults the eye misses. They are no substitute for a manual audit, though, because they cannot assess a large share of the criteria at all – “no errors found” does not mean “accessible”. How a structured review works is described on our accessible websites service page.

Yes. Accessibility opens up customers who would otherwise drop out, and it forces clean craft: clear structure, plain language, forms that work. Every visitor benefits from that – in bright sunlight, one-handed on a phone, on the underground with the sound off.

The side effect is technically traceable: the same structure a screen reader announces is the structure search engines and answer engines read. Heading levels, meaningful link text and alternative text are SEO fundamentals at the same time. No automatic ranking advantage follows from this, and anyone promising one is overselling. The connection is indirect but stable: what humans can take in easily, machines usually can too. That is the real reason we treat accessibility not as a retrofit but as part of how a website is built.

Frequently asked questions about the Austrian Accessibility Act

Does my website have to be accessible?
Only if you offer one of the services listed in the statute – a purely informational company website does not fall under it. The Austrian Accessibility Act lists the covered services exhaustively: electronic communications services, access to audiovisual media services, elements of passenger transport services, consumer banking services, e-books and services in electronic commerce, meaning online shops.
A website that merely informs people about a company and offers a contact form is not covered. Anyone claiming across the board that every website now has to be accessible is selling through fear rather than benefit.

Source: RIS: Austrian Accessibility Act, Section 2 (opens in a new tab)

When did the Austrian Accessibility Act take effect?
On 28 June 2025. The Austrian Accessibility Act (BGBl. I No. 76/2023) took effect on 28 June 2025 and transposes the European Accessibility Act into Austrian law.
The statute provides no general transitional period for offerings that already existed.

Source: RIS: Austrian Accessibility Act, Section 37 (opens in a new tab)

Are micro-enterprises exempt?
For services yes, for products no. A micro-enterprise is a company employing fewer than ten people that also has either an annual turnover of no more than two million euros or a balance sheet total of no more than two million euros. Both conditions have to be met together: the headcount and one of the two financial figures.
The exemption expressly concerns services only. Anyone placing products on the market cannot rely on it.

Source: RIS: Austrian Accessibility Act, Section 6 (opens in a new tab)

Is it true that existing websites have until 2030?
No. The transitional provision concerns products lawfully in use before 28 June 2025, not existing websites. The wording allows service providers, until 28 June 2030, to continue offering or providing their services using products that they were already lawfully using before 28 June 2025.
The widespread reading that old websites therefore have until 2030 is not supported by that wording. Whether and how the provision applies in an individual case can only be settled by a legal assessment.

Source: RIS: Austrian Accessibility Act, Section 37 (opens in a new tab)

What penalties are possible?
Fines of up to 80,000 euros, or up to 50,000 euros for micro, small and medium-sized companies. Market surveillance is the responsibility of the Sozialministeriumservice. There are no blanket inspections; in practice, proceedings usually begin after a complaint.
The larger economic damage arises earlier anyway: with every purchase that fails at a barrier.

Source: RIS: Austrian Accessibility Act, Section 36 (opens in a new tab)

Is an accessibility overlay on the website enough?
No. An overlay only alters the page afterwards in the browser and is no substitute for proper implementation. Overlay widgets promise accessibility by script. In practice they tend to get in the way of the assistive tools that affected people already use, rather than helping. Responsibility for accessibility stays with the website provider in every case.
Assessment is against the WCAG at level AA. A script that toggles colours and font sizes does not satisfy those success criteria.

Source: W3C: WCAG 2.2 (opens in a new tab)