Accessibility Act: What has applied to websites and online shops since June 2025

Since 28 June 2025, the Accessibility Act (Barrierefreiheitsgesetz, BaFG) has applied in Austria. Since then, shop owners regularly ask us whether it affects them and what exactly they need to do. The short answer: if you conclude contracts with consumers through your website and are not a micro-enterprise, you need to act. This article does not replace legal advice. It does show where the boundaries lie and what we check in our projects.

Who the act applies to

The BaFG implements the EU's European Accessibility Act. For websites, one category matters most: e-commerce services. These are services where a consumer concludes a contract via a website or an app (§ 3 no. 27 BaFG). That is the classic online shop. But it can also be an appointment booking with payment, ticket sales or a subscription taken out online.

A purely informational website is not covered. If you present your services and offer a contact form, you do not conclude a contract through it. A shop that only sells to businesses does not fall under this category either, because the act is about consumer contracts. The Austrian Economic Chamber (WKO) points out that purely informational parts of a website can be distinguished from the checkout process. In practice, we still treat the whole website the same way. The path to the shopping cart almost always leads through the home page, the navigation and the product pages.

The exemption for micro-enterprises

Micro-enterprises that provide services are exempt from the requirements (§ 6 para. 1). Under § 3 no. 19, a micro-enterprise is one that employs fewer than ten people. In addition, either the annual turnover or the annual balance sheet total must not exceed 2 million euros.

Two points are often overlooked. First, the exemption only applies to services. If you manufacture or import products that fall under the act, you have obligations even as a micro-enterprise. Second, you must be able to prove the exemption if the Sozialministeriumservice asks (§ 24 para. 2). If your business grows, at some point it will no longer be exempt. Then it helps if the shop is already prepared.

Which standard applies

The act does not specify contrast values or a checklist. It describes requirements in Annex 1 and refers to harmonised standards: if you comply with them, you are presumed to meet the requirements (§ 5). In practice, the relevant standard is the European norm EN 301 549. Its chapter on websites adopts the Web Content Accessibility Guidelines (WCAG) 2.1 at level AA. According to the Ministry of Social Affairs, the standard is being revised with regard to the European Accessibility Act.

That is why we develop to WCAG 2.1 AA. We also include the points the W3C added with WCAG 2.2 in October 2023. These include sufficiently large click targets and a keyboard focus that does not disappear behind a fixed header or the cookie banner. In a new project, this takes hardly any extra effort. But it saves rework when the standard is updated.

What belongs in the accessibility statement

The BaFG does not use the term accessibility statement. It requires “information on conformity” (Annex 3). This means a document in which you explain how your offering meets the requirements. It contains at least:

• a general description of the service in an accessible format,

• the explanations needed to understand how the service works, such as ordering, payment and delivery,

• a description of how the service meets the accessibility requirements.

This information must be available in writing and orally, including in an accessible form (§ 14 para. 2). The act allows you to put it in your terms and conditions. The Austrian Economic Chamber advises against this and recommends a separate, easy-to-find section. We agree. We create a separate page and link it in the footer. There we also list known limitations and a contact for feedback. The act does not explicitly require this. But it helps you learn about problems before they reach the authority.

Who checks and what happens after a complaint

The responsible body is the Sozialministeriumservice as the market surveillance authority. Consumers can report suspected breaches. The same right applies to the Association for Consumer Information (VKI), the Austrian Disability Council, the Federal Chamber of Labour and the Austrian Economic Chamber (§ 35). The authority must examine every report. Within eight weeks, it tells you in writing whether it will open proceedings.

If it finds that a service does not meet the requirements, you first receive the findings for comment. You have at least ten working days for this (§ 28 para. 3). The authority then asks you to fix the shortcomings within a reasonable period. If that does not happen, it can oblige you to do so by official decision. The decision can also order you to inform the public or to withdraw the offering. In addition, § 36 provides for fines. As a small or medium-sized business, offering a service that is not accessible puts you at risk of up to 50,000 euros.

The most likely path to proceedings is therefore a customer who fails at your checkout and complains. The best protection is a checkout that works.

What we check in projects

Automated tests such as axe find some of the errors, far from all of them. That is why we also check by hand. We take the home page, a product or service page and the entire path up to the order confirmation:

• Contrast: Body text needs a ratio of at least 4.5:1 to the background. Large text and controls such as the border of an input field need at least 3:1. Light grey text on white is a classic.

• Keyboard: The entire path must work without a mouse, from the menu to filters and variants to payment. We go through every page once with the Tab key.

• Visible focus: People who use the keyboard need to see where they are. Many designs remove the focus outline because it gets in the way. Instead, we design it to match the brand.

• Alt texts: Product images get a short description. Purely decorative images get an empty alt attribute so that screen readers skip them.

• Forms: Every field has a visible label. Placeholder text that disappears as you type is not enough. Error messages say what is wrong and how to fix it.

• Headings: The structure follows a logical order from H1 downwards. This lets screen reader users jump through the page by heading.

On top of that comes everything we did not build: payment providers, cookie banners, chat widgets and shop apps. They are part of your service, even if someone else programmed them. If a widget breaks keyboard navigation, we look for an alternative or build the feature ourselves. Finally, we go through the path once with a screen reader, using VoiceOver on the Mac or NVDA on Windows.

We advise against so-called overlays that a script places over the website. They fix neither missing labels nor broken keyboard navigation. Accessibility comes from design and code.

For new shops, we plan for this from the start. For existing ones, we begin with the checkout, because that is where the act applies. You can read how we build shops under E-Commerce & Shop Systems.