Accessibility: Checklist for Websites and Shops Under the BaFG and WCAG 2.2

The BaFG (BGBl. I No. 76/2023) transposes Directive (EU) 2019/882 and entered into force on June 28, 2025 (§ 37 para. 1). It applies to certain products placed on the market after that date and to certain services provided to consumers after that date (§ 2). For most websites, § 2 para. 2 no. 6 is decisive: e-commerce services, meaning services provided at a distance, by electronic means, and at the individual request of a consumer with a view to concluding a consumer contract via websites and mobile services (§ 3 no. 27).

Public bodies such as the federal government, the federal states, and municipalities are subject to the Web-Zugänglichkeits-Gesetz (Austrian Web Accessibility Act) and state laws for their websites, not to this checklist.

• Website and app designed to be perceivable, operable, understandable, and robust (§ 4 para. 3, Annex 1)
• In the shop: accessibility information on the products offered is provided, where the manufacturer supplies it (Annex 1)
• Identification, security, and payment functions are accessible when they are part of the service (Annex 1)
• The general terms and conditions or a similar document describe how the service meets the requirements: general description, necessary explanations, fulfillment of the requirements (§ 14 para. 2, Annex 3)
• This information is made available to the public in written and oral form, including in an accessible format, and kept for as long as the service is offered (§ 14 para. 2)
• A procedure is in place to keep meeting the requirements whenever the service, the requirements, or the standards change (§ 14 para. 3)
• In case of deficiencies, corrective measures are taken and, if the service does not comply, the Sozialministeriumservice (Austrian federal social affairs agency) is informed without delay (§ 14 para. 4)
• Reliance on a fundamental alteration or disproportionate burden only with a documented assessment, kept for five years and, for services, renewed upon changes and at least every five years (§§ 17, 18)

Anyone who has received public or private funds to improve accessibility cannot claim a disproportionate burden (§ 18 para. 7).

Anyone who meets harmonized standards whose references have been published in the Official Journal of the EU is presumed to conform with the requirements, to the extent the standards cover them (§ 5 para. 1 BaFG). The relevant European standard for digital accessibility is EN 301 549. ETSI published version V4.1.1 in September 2026; it adopts WCAG 2.2 and, for the first time, maps its requirements to Directive (EU) 2019/882 in a dedicated annex. According to AccessibleEU, the European Commission's resource center, version V3.2.1 from 2021, based on WCAG 2.1 Level AA, remains the relevant reference until publication in the Official Journal.

TOMORIS recommendation: test and develop against WCAG 2.2 Level AA now. According to the W3C, WCAG 2.2 builds on 2.1 and is backward compatible; pages that meet 2.2 should also meet 2.1. If you are explicitly required to test against 2.1, keep testing criterion 4.1.1 Parsing, which was removed in 2.2.

• 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.

1. 1

   Clarify whether you are affected

   Is the offering aimed at consumers, does it fall under § 2 para. 2, and are you a micro-enterprise under § 3 no. 19? Record the result and the reasoning in writing.

2. 2

   Take inventory

   List the pages and flows that consumers use: product list and product page, shopping cart, sign-in, checkout, payment, forms, downloads.

3. 3

   Test

   Automated testing tools find only some of the errors; for each page type, add keyboard, zoom, screen reader, and contrast testing.

4. 4

   Fix deficiencies

   Start with templates and components, then the content; demand fixes from third-party providers of payment and sign-in functions or replace them.

5. 5

   Inform and stay compliant

   Publish the information under Annex 3 in the general terms and conditions or a similar document, keep test reports and assessments under §§ 17 and 18, and include accessibility in the acceptance of new features and content (§ 14 para. 3).