Accessibility Act and your website in Austria: who is affected and what to fix

Short answer: under Austria's Accessibility Act (Barrierefreiheitsgesetz, BaFG) your website must be accessible if consumers can conclude a contract online through it, for example in an online shop or a booking system, and your company is not a micro-enterprise. The law has applied since 28 June 2025, the practical standard is WCAG 2.1 AA (via EN 301 549), and fines go up to €80,000. A brochure site with a contact form is usually not covered.

Since the law came into force we have been asked one question more than any other: "Does this apply to me?" The honest answer is that many small company websites in Austria are not covered at all, while many shops that think they are fine are not.

This guide explains who is affected, what "accessible" means in practice, what you have to publish, who checks it and what it typically takes to fix an existing site. It is not legal advice; for borderline cases, ask the WKO or a lawyer. But it should let you judge where you stand in ten minutes.

What is the Barrierefreiheitsgesetz?

The BaFG is Austria's implementation of the European Accessibility Act (EU Directive 2019/882). It sets accessibility requirements for certain products (such as computers, smartphones, ATMs, ticket machines, e-readers) and certain services, and it has applied to new products and services since 28 June 2025.

For websites the relevant part is the services. The aim is simple: people with disabilities (for example blind people using a screen reader, people who can't use a mouse, people with low vision or cognitive impairments) should be able to buy, book and sign up online like everyone else. Public bodies were already covered by a separate law, the Web-Zugänglichkeits-Gesetz; the BaFG now extends similar duties to private companies.

Which websites does the Accessibility Act apply to?

The law covers a closed list of services. For most businesses the decisive one is "services in electronic commerce": services provided electronically, on a consumer's request, with a view to concluding a consumer contract via a website or mobile app. In plain terms, that covers:

• Online shops selling to consumers (B2C), including shop apps.
• Booking sites where consumers book and pay: hotels, holiday flats, courses, events, tours.
• Online appointment tools where a contract with a consumer is concluded (for example paid appointments booked online).
• Digital subscriptions and memberships sold online, and online sales of e-books and digital publications.
• Specific sectors with their own rules: banking services for consumers, passenger transport (websites, apps, e-tickets), electronic communications and access to audiovisual media services.

Not covered are B2B-only websites, and websites that only present a company and invite enquiries without a contract being concluded online. A tradesperson's site with a contact form, an architect's portfolio or a doctor's site without online sales is generally outside the scope.

Is your business exempt as a micro-enterprise?

Micro-enterprises that provide services are exempt from the service requirements. Under the BaFG a micro-enterprise employs fewer than 10 people and has an annual turnover or annual balance sheet total of no more than €2 million.

Three points people often miss:

• The exemption covers services only. Micro-enterprises that manufacture, import or trade in the products covered by the law are not exempt from the product rules.
• If you grow past the thresholds, the duties apply. Planning a new shop now? Build it accessibly from the start, since retrofitting costs more.
• Larger companies can claim a disproportionate burden or a fundamental alteration of the service in exceptional cases, but they have to document the assessment, keep it for five years and repeat it at least every five years. It is not a general escape route.

There are also transition periods: services that use products already in use before 28 June 2025 may continue until 27 June 2030, and contracts concluded before that date may run until they expire, for at most five years. A new or relaunched shop does not benefit from these.

What does accessible mean in practice? WCAG 2.1 AA explained

The BaFG itself describes requirements in general terms: perceivable, operable, understandable, robust. Compliance with harmonised European standards creates a presumption of conformity, and for websites that standard is EN 301 549, which refers to the Web Content Accessibility Guidelines (WCAG) 2.1, level AA. In practice, WCAG 2.1 AA is the benchmark everyone works with. WCAG 2.2 adds a few criteria and is a sensible target for anything built new.

WCAG AA has around 50 success criteria. The ones that cause most failures on real shops and booking sites:

One warning from experience: so-called accessibility overlays, scripts that add a toolbar with "accessibility mode", do not make a site compliant. They don't fix missing labels or a checkout that can't be used with a keyboard, and they sometimes get in the way of screen readers. Accessibility has to be in the code.

Do you need an accessibility statement?

Yes, in substance. Service providers must provide the information listed in Annex 3 of the BaFG and make it available in an accessible form. That covers a general description of the service, explanations needed to understand how it works, and a description of how the service meets the accessibility requirements. In practice this is usually published as an accessibility statement (Barrierefreiheitserklärung).

The law allows it in the terms and conditions or in another document. The WKO recommends a separate, easy-to-find page, for example linked in the footer next to the imprint and privacy policy, rather than hiding it in the T&Cs. A good statement contains:

• Which services the statement covers (shop, booking, app).
• Which standard you follow (EN 301 549 / WCAG 2.1 AA) and how it was checked.
• Known limitations and when you plan to fix them.
• A contact for accessibility problems (email, phone).
• A reference to the market surveillance authority, the Sozialministeriumservice.

Who checks compliance and what are the fines?

Market surveillance lies with the Sozialministeriumservice, centrally organised at its Upper Austria office. It can check websites on its own initiative, and consumers can report violations to it. If a service doesn't comply, the provider is asked to fix it; if that doesn't happen, the authority can impose fines.

The maximum fines under § 36 BaFG are graded by violation and company size:

Fines are the last step, not the first. The bigger practical risk is losing customers who can't complete a purchase, and the cost of an emergency fix under time pressure.

How do you check your website? A 12-point checklist

You can do a first check yourself in an hour. It won't replace a full audit, but it shows whether you have a small or a big problem:

1. Unplug the mouse and go through your shop with Tab, Enter and the arrow keys: menu, search, filters, product, cart, checkout. Can you always see where the focus is?
2. Check the cookie banner first: can you accept or reject it with the keyboard?
3. Run a free automated test (for example the axe browser extension or WAVE) on the home page, a product page and the checkout.
4. Check contrast of body text, buttons and prices with a contrast checker.
5. Zoom the browser to 200 %: is everything still readable and usable?
6. Look at the page on a phone at the smallest width: no horizontal scrolling?
7. Check that every product image has a meaningful alt text.
8. Submit forms with errors: is the error message clear in words, not only in red?
9. Check that every form field has a visible label.
10. Turn on the screen reader (VoiceOver on Mac/iPhone, NVDA on Windows) and try to buy one product.
11. Check that videos have captions.
12. Check that there is an accessibility statement linked in the footer.

Automated tools find roughly the technical part of the problems; keyboard and screen-reader tests find the rest. If points 1, 2 or 10 fail, the checkout is effectively closed to some of your customers.

What does it cost to make a website accessible?

It depends on how the site was built far more than on its size. Honest rules of thumb:

The cheapest moment is a relaunch: if accessibility is part of the design and the component library from day one, it costs little extra. So when you plan a new website or shop, put contrast, keyboard use and the checkout on the brief from the first workshop, not on the list for after launch. If you are planning a relaunch anyway, read how to relaunch without losing SEO and what a website costs in Austria. Ask about funding too: the federal digitalisation funding has ended, but regional programmes may fit. Status and alternatives: our funding article.

When can you relax?

• You are a micro-enterprise providing services: the BaFG service duties don't apply. Accessible design still helps older customers and phone users.
• You only sell to businesses: B2B sales are outside the scope.
• Your site presents and invites enquiries, but no contract is concluded online: generally not covered.

Even then, most WCAG basics (contrast, readable text, clear forms, keyboard use) make a site better for everyone and are increasingly what Google's own quality checks such as Lighthouse look at. It's rarely wasted effort.

Written byChristoph SpeiserProject lead & sales

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