Accessibility law: who is actually affected

Does the accessibility law apply to my website?

For most company websites it does not, for online shops and booking flows it certainly does. The Barrierefreiheitsgesetz (BaFG), the Austrian act implementing the European Accessibility Act, transposes EU Directive 2019/882 and has applied since 28 June 2025. It explicitly covers services for consumers: online shops, e-banking, online bookings, e-ticketing. A plain business card website with no sales or booking function usually falls outside it.

The point where most assessments tip over is the booking calendar. A hotel with an embedded online booking provides a service within the meaning of the act. A medical practice taking appointments through a form is the borderline case currently discussed the most. As soon as the appointment becomes binding, there is more for than against. How I handle that for law firms and medical practices and for health and therapy practices is on the respective industry pages.

Who falls under the microenterprise exemption?

Businesses with fewer than ten employees and no more than €2 million in annual turnover or balance sheet total, but only when providing services. Both size criteria have to be met, the employee criterion and one of the two financial ones. That covers a very large share of Austrian businesses, and it is the reason the topic gets ticked off too quickly in many advisory conversations.

The exemption has a sharp edge: it applies to services, not to products. Anyone who manufactures, imports or sells products is under obligation even as a microenterprise. An online shop sells products. In practice that means the small retailer with five employees and a web shop gets nothing out of the exemption, while the far larger consulting firm without a sales function benefits from it. What that means for a retailer with a shop floor and a web shop is on the retail page.

What happens in the event of a violation?

Administrative fines of up to €80,000, imposed by the competent district administrative authority (Bezirksverwaltungsbehörde), with market surveillance by the Sozialministeriumservice. Official spot checks have been running since the beginning of 2026. Realistically, though, the first step is not a penalty notice but an objection with a deadline for remedy.

The economically more relevant point lies elsewhere: a consumer who cannot complete a booking flow does not buy, and in the worst case complains in public. The lost revenue hits faster than any authority.

What does WCAG 2.2 AA actually require?

Four principles from which testable criteria follow: perceivable, operable, understandable, robust. For a typical company website that means around a dozen points in daily practice that really do get violated regularly. The technical reference in Austria is the harmonized standard EN 301 549, which makes WCAG 2.1 AA binding; version 2.2 is the current state of the art and the more sensible benchmark in practice.

The most frequent violations I come across on existing sites are always the same ones: contrast too low with light gray text on a white background, controls without keyboard focus, images without alternative text, form fields without a linked label, and videos that start automatically on load. None of these points is expensive to fix while the site is still being built.

How do you test this without a consultant?

With an automated testing tool for half of the criteria and with the keyboard for the other half. Automated tools such as axe-core, Lighthouse or the WAVE extension reliably find contrast errors, missing alternative texts and broken form labels. They do not find whether an operating order makes sense or whether an alternative text actually describes the image.

The second part costs ten minutes: put the mouse aside and operate your own website using only the tab key. If you cannot see where you currently are, or if you get stuck in the menu, you have found a violation that no tool reports.

Why do I build accessibly even though I am exempt?

Because as a microenterprise I do fall under the exemption, but I build for clients who do not. Bleier Solutions is a sole proprietorship without employees that provides services: the exemption clearly applies. Even so, this website is built to WCAG 2.2 AA, for two reasons.

The first is evidence: anyone selling a hotel an accessible booking flow should not have contrast errors on their own pricing page. The second is automation: on every change, axe tests run across every page delivered, once in light mode and once in dark mode. A violation breaks the test run and the change does not go live. That is cheaper than any after the fact audit.

What does the market in Carinthia look like?

Of the 24 Carinthian web providers whose sites I reviewed on 24 August 2026, exactly one lists accessibility as a service: designation.at in Klagenfurt, with accessible websites and PDFs. All the others do not mention the topic, even though the law had been in force for fourteen months at that point.

For businesses that are affected, that means you will have to raise the topic yourself, because otherwise it does not come up in the sales conversation. Before you place an order, ask which testing standard the provider uses and whether testing is part of acceptance or billed as an extra.

What does accessibility cost after the fact?

Considerably more than up front: in my experience the effort is two to three times as high. On a new build, accessibility is mainly a question of decisions: sufficient contrast in the color palette, semantic HTML instead of nested containers, visible focus, a sensible heading hierarchy. Those decisions cost no extra time at the start.

Afterwards they are interventions in a finished system: change the color palette, replace controls, label every image individually. With a WordPress installation running a purchased theme, there is the added problem that the theme itself brings the errors along and an update brings them back. How that compares with a hand built solution is covered in WordPress or custom.

How do you start?

By working out whether you are affected at all, and then by measuring instead of guessing. Check first: do consumers buy or book anything on your site? If they do, the law applies even at a small company size as soon as products are involved.

For the measurement, a first look from the outside is enough. The website check on this site tests, among other things, whether all images have alternative text, whether the page language is declared and whether forms link to the privacy policy, three points that are regularly missing in a BaFG context. If you then want to know what fixing it costs, the price range for a new build is on the websites page, with no inquiry and no initial call.

This article is an assessment to the best of my knowledge and not legal advice. Where it comes to drawing the line in an individual case, in particular with appointment bookings and mixed offerings, asking a lawyer is worth the money.