Austria EAA Compliance and the BaFG

National law Bundesgesetz über Barrierefreiheitsanforderungen für Produkte und Dienstleistungen (Barrierefreiheitsgesetz, BaFG), in English the Federal Act on accessibility requirements for products and services. It was enacted as Article 1 of the Bundesgesetz, mit dem ein Barrierefreiheitsgesetz erlassen sowie das Sozialministeriumservicegesetz geändert wird, published in the Bundesgesetzblatt as BGBl. I Nr. 76/2023 and in force since 28 June 2025 under § 37 Abs. 1. Austria transposed late. The directive required transposition by 28 June 2022, and on 20 July 2022 the Commission sent letters of formal notice to 24 Member States whose full transposition measures had not been communicated. The Nationalrat adopted the BaFG on 6 July 2023 and the Bundesrat approved it on 12 July 2023, so no Austrian transposing law was in force at the deadline. The detailed requirements sit in the annexes (Anlagen) to the Act. § 4 Abs. 3 puts the accessibility requirements for services in Anlage 1, and § 14 Abs. 2 puts the information a service provider has to make public in Anlage 3.

Web standard EN 301 549 is the reference standard. § 5 BaFG gives a presumption of conformity to products and services that meet harmonised standards whose references have been published in the Official Journal of the EU. The Sozialministeriumservice states that the harmonised standards for the products and services the BaFG covers are still being developed, so that presumption has limited practical effect for now. The authority reviews compliance against the BaFG requirements themselves and uses EN 301 549 and the WCAG 2.1 Level AA criteria it references as the detailed benchmark. Austria has no separate national accessibility standard for private-sector websites. The public-sector WZG regime works from the same standard, EN 301 549 version 3.2.1 and the WCAG 2.1 Level AA criteria within it. Conforma scans against WCAG 2.2 AA and EN 301 549.

Enforcement Market surveillance rests with the Bundesamt für Soziales und Behindertenwesen (Sozialministeriumservice), the Federal Office for Social Affairs and Disability. § 21 BaFG makes it the competent authority for official acts under the Act unless the Act says otherwise. The work is carried out for the whole country by the Marktüberwachungsbehörde Digitale Barrierefreiheit at the Landesstelle Oberösterreich in Linz, which publishes an online notification form. Under § 35 BaFG a consumer may report a suspected breach to the Sozialministeriumservice, and the same right belongs to the Verein für Konsumenteninformation, the Österreichischer Behindertenrat, the Bundesarbeitskammer and the Wirtschaftskammer Österreich. The authority has to answer in writing within eight weeks, in an accessible format, saying whether it will open proceedings and giving reasons if it will not. § 36 BaFG sets administrative fines of up to EUR 80,000, reduced to EUR 50,000 where the offender is a Kleinstunternehmen under § 3 Z 19 or a small or medium enterprise under § 3 Z 20, for placing a non-compliant product on the market or offering a non-compliant service; up to EUR 40,000, reduced to EUR 25,000, for conformity assessment, CE marking and service information failures; and up to EUR 16,000, reduced to EUR 10,000, for record-keeping and cooperation failures. § 36 Abs. 4 has the amount set by reference to the scope of the breach, the products, services and people affected, and whether it was repeated, and § 36 Abs. 5 sends the fines to the Unterstützungsfonds für Menschen mit Behinderungen. Public-sector sites run on a separate route. Complaints about federal websites and apps under the Web-Zugänglichkeits-Gesetz go to the monitoring body, the Österreichische Forschungsförderungsgesellschaft (FFG), and each of the nine Länder runs its own procedure.

Who has to comply in Austria

The BaFG covers economic operators that place covered products on the Austrian market or offer covered services to consumers. The services listed in § 2 Abs. 2 are electronic communications with the exception of emergency calls, services giving access to audiovisual media, the websites, apps, electronic tickets, travel information and self-service terminals of air, bus, rail and waterborne passenger transport, consumer banking, e-books and their software, and e-commerce. Micro-enterprises are exempt from the service requirements only. § 6 Abs. 1 exempts a Kleinstunternehmen that offers or provides services from the accessibility requirements in § 4 Abs. 3 and from every obligation tied to them. § 3 Z 19 defines a Kleinstunternehmen as employing fewer than ten people and having either annual turnover of no more than EUR 2 million or a balance sheet total of no more than EUR 2 million. Products carry no equivalent exemption, so a micro-enterprise that places a covered product on the market still has to meet the product requirements. Public bodies sit outside this regime. Federal websites and apps fall under the Web-Zugänglichkeits-Gesetz (WZG), BGBl. I Nr. 59/2019, in force since 23 July 2019, which transposes the public-sector Directive (EU) 2016/2102, and each of the nine Länder has its own law for its own bodies.

The deadlines that matter

28 June 2022

EU transposition deadline for Directive (EU) 2019/882, which passed with no Austrian transposing law in force

20 July 2022

European Commission sends letters of formal notice to 24 Member States over transposition measures that had not been communicated in full; the sources reached here do not name the 24 individually

6 July 2023

Nationalrat adopts the Barrierefreiheitsgesetz

12 July 2023

Bundesrat approves it, and the Act is published later that month as BGBl. I Nr. 76/2023

28 June 2025

BaFG enters into force under § 37 Abs. 1, so products placed on the market and services provided from this date have to comply

28 June 2030

End of the § 37 Abs. 2 transition for products already in lawful use before 28 June 2025 and for service contracts agreed before that date

28 June 2040

Last date under § 37 Abs. 3 for self-service terminals that were already in use before 28 June 2025

WCAG 2.2 AA, EN 301 549

Prove your Austria compliance

Conforma scans your site against WCAG 2.2 AA and EN 301 549, the standard the Sozialministeriumservice uses as its benchmark when it reviews compliance under the BaFG. Each scan lists the specific failures with the page and element they sit on, and keeps a dated record of what was fixed and when, which is the evidence you would hand over if the Marktüberwachungsbehörde Digitale Barrierefreiheit opens proceedings. Conforma also drafts an accessibility statement you can adapt for the information § 14 Abs. 2 BaFG requires under Anlage 3. Automated testing reaches part of what the standard covers, so manual checks are still needed, and a scan on its own does not make you compliant.

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Austria EAA questions, answered

When did the BaFG start to apply, and is there a transition period?

The BaFG entered into force on 28 June 2025 under § 37 Abs. 1, so products placed on the market and services provided to consumers from that date have to comply. § 37 Abs. 2 lets service providers keep using products they were lawfully using before 28 June 2025 until 28 June 2030, and service contracts agreed before 28 June 2025 may run on unchanged until they expire, for no more than five years from that date. § 37 Abs. 3 lets self-service terminals already in use carry on to the end of their economic life, for no more than 20 years after they were put into use and until 28 June 2040 at the latest.

Is my small business exempt from the BaFG?

The exemption covers services only. § 6 Abs. 1 BaFG exempts a Kleinstunternehmen that offers or provides services from the accessibility requirements in § 4 Abs. 3 and from every obligation tied to them. § 3 Z 19 defines a Kleinstunternehmen as employing fewer than ten people and having either annual turnover of at most EUR 2 million or a balance sheet total of at most EUR 2 million. If you place covered products on the market, the exemption does not reach you. Some official summaries repeat the size test without the services limit, so check § 6 Abs. 1 before relying on it.

Which accessibility standard does my website have to meet in Austria?

The reference standard is EN 301 549. § 5 BaFG gives a presumption of conformity to anything meeting harmonised standards cited in the Official Journal of the EU, and the Sozialministeriumservice says those standards are still being developed for the products and services the BaFG covers. It reviews compliance against the BaFG requirements and uses EN 301 549 and the WCAG 2.1 Level AA criteria it references. Building to WCAG 2.2 AA is a safer target for new work, since it keeps every WCAG 2.1 Level AA criterion and adds later ones.

Who enforces the BaFG and what are the penalties?

The Sozialministeriumservice enforces it, through its Marktüberwachungsbehörde Digitale Barrierefreiheit in Linz. § 36 BaFG sets administrative fines of up to EUR 80,000, or up to EUR 50,000 for a Kleinstunternehmen or a small or medium enterprise, for a non-compliant product or service, with lower bands of EUR 40,000 and EUR 16,000 for conformity, information and cooperation breaches. Enforcement has been cautious so far. The Österreichischer Behindertenrat reported on 24 June 2026, citing Sozialministerium figures, that 84 proceedings had been opened and 48 notifications reviewed in the first year, with no administrative fine imposed.

This page is a plain-English summary, not legal advice. Check the cited national law for specifics.

Common fixes to check

Most sites fail the same WCAG checks first. Each guide has a plain-language fix and a before/after snippet you can copy.

WCAG 1.1.1 Images must have alt text Every meaningful image needs alt text so screen-reader users know what it shows. Decorative images get an empty alt attribute so they are skipped. WCAG 1.4.3 Text must have enough color contrast Text needs to contrast with its background so people with low vision can read it. The minimum is 4.5:1 for normal text and 3:1 for large text. WCAG 4.1.2 Form fields must have labels Every input, textarea and select needs an associated label so users know what to enter and screen readers can announce the field. WCAG 4.1.2 Links must have discernible text A link needs text that describes where it goes. An icon-only or empty link is announced as just “link”, so screen-reader users have no idea where it leads.

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A free scan against WCAG 2.2 AA, a plain-language fix for every issue, and a Austria-specific accessibility statement when you need one.