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Checkaccessibilityunder the BaFG.
Since June 28, 2025, the Barrierefreiheitsgesetz (BaFG, Austrian Accessibility Act) has applied in Austria. Among other things, it requires online shops, booking flows, banking services, and apps for consumers to be perceivable, operable, understandable, and robust, and it requires providers to describe how their service meets these requirements. This checklist explains who is covered and who is exempt, which obligations and penalties the law sets out, and how EN 301 549 and WCAG 2.2 relate to each other. It also lists the most important WCAG checkpoints to tick off.
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Accessibility: Checklist for Websites and Shops Under the BaFG and WCAG 2.2
- Format
- PDF, A4
- Length
- 7 pages
- Size
- 97 KB
- Updated
- Oct 25, 2026
- Sources
- 5
- Usage
- Redistribution in unchanged form permitted
WHO IT IS FOR
Who This
Is for.
Scope and exemptions of the BaFG (Austrian Accessibility Act), obligations of service providers, the standards EN 301 549 and WCAG 2.2, checkpoints to tick off, and how to proceed.
- Online retailers and providers of booking or ordering flows for consumers
- Banks, insurance intermediaries, and other service providers with a website or app
- Web agencies and development teams that build websites and apps
- Executives who want to assess whether and how the BaFG affects them
6 SECTIONS
What Is
Inside.
- 01
Who Is Covered by the BaFG
Services for consumers since June 28, 2025, the exemption for micro-enterprises, and which content is excluded.
- 02
What the BaFG Requires of Service Providers
Requirements under Annex 1, information under Annex 3, ongoing compliance, corrective action, and documentation.
- 03
Which Standard Applies: EN 301 549 and WCAG
Presumption of conformity under § 5 BaFG and the status of the European standard in October 2026.
- 04
Core WCAG 2.2 Checkpoints to Tick Off
The success criteria that websites and shops most often fail in practice, Levels A and AA.
- 05
Supervision, Complaints, and Penalties
The Sozialministeriumservice monitors the market; consumers and associations can report issues.
- 06
How to Proceed
From clarifying whether you are affected to lasting compliance; a TOMORIS recommendation.
EXCERPT
Core WCAG 2.2 Checkpoints to Tick Off
- 1.1.1 Non-text Content: images, icons, and image buttons have an equivalent text alternative
- 1.2.2 Captions: pre-recorded videos with audio have captions
- 1.4.3 Contrast: text has a contrast ratio of at least 4.5:1, large text 3:1
- 1.4.4 Resize Text: text can be enlarged to 200% without assistive technology and without loss of content or functionality
- 1.4.10 Reflow: content works at a width of 320 CSS pixels without horizontal scrolling
- 2.1.1 Keyboard: all functions can be operated with the keyboard, including menus, filters, and checkout
- 2.4.7 Focus Visible: the keyboard focus is always visible
- 2.4.11 Focus Not Obscured (new in 2.2): the focused element is not fully hidden, for example by cookie banners or sticky bars
- 2.5.7 Dragging Movements (new): anything that works by dragging also works with a single click or tap
- 2.5.8 Target Size (new): click targets are at least 24 by 24 CSS pixels, with defined exceptions
- 3.1.1 Language: the main language of the page is specified in the code
- 3.3.1 and 3.3.2 Forms: fields are labeled, errors are identified and described in text
- 3.3.7 Redundant Entry (new): data already entered is pre-filled or offered for selection within the same process
- 3.3.8 Accessible Authentication (new): no cognitive function test such as puzzles or retyping, unless another sign-in method or a help mechanism is available
- 4.1.2 Name, Role, Value: controls are correctly named and marked up for assistive technologies
This list is a selection by TOMORIS and does not replace a full review of all Level A and AA success criteria. The wording of the W3C Recommendation WCAG 2.2 of December 12, 2024, is authoritative.
SOURCES
Supported
by Sources.
- Barrierefreiheitsgesetz (BaFG, Austrian Accessibility Act), BGBl. I No. 76/2023, current version in the RIS (opens in a new tab)§§ 2 to 6, 14, 17, 18, 22, 35 to 37, Annexes 1 and 3, version as of October 25, 2026
- Directive (EU) 2019/882 on the accessibility requirements for products and services (opens in a new tab)Art. 4(5), Art. 31
- W3C: Web Content Accessibility Guidelines (WCAG) 2.2, W3C Recommendation December 12, 2024 (opens in a new tab)Success criteria as in Section 04, new criteria, and the removed 4.1.1
- ETSI EN 301 549 V4.1.1, publication directory (opens in a new tab)Versions up to 04.01.01_60
- AccessibleEU: The European accessibility standard EN 301 549 has been updated (September 7, 2026) (opens in a new tab)Status of citation in the Official Journal, WCAG 2.2, annex on Directive (EU) 2019/882
This checklist is a TOMORIS recommendation and provides an overview. It does not replace legal advice or a full accessibility audit; the legal text in its current version and the standards cited are authoritative.
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