Accessibility in online shops: what applies since June 2025

The Barrierefreiheitsgesetz (BaFG) covers "Dienstleistungen im elektronischen Geschäftsverkehr" for consumers, provided after 28 June 2025 (§ 2 (2) Z 6). § 3 Z 27 defines them as services provided at a distance, electronically, at a consumer's request, with a view to a consumer contract, through websites and mobile apps. The Sozialministeriumservice puts it plainly: webshops are covered, in the browser and as apps. An existing shop is covered too, because what counts is that the service is provided after that date.

Micro-enterprises that provide services are exempt from the accessibility requirements and all duties that come with them (§ 6 (1)). A micro-enterprise employs fewer than ten people and has an annual turnover or an annual balance sheet total of at most 2 million euros (§ 3 Z 19). Both conditions count: eleven staff and 1 million euros turnover means you are not exempt.

The law also names content it does not apply to (§ 2 (3)): recorded audio and video and office documents published before 28 June 2025, third-party content you neither pay for, develop nor control, and archives that are no longer updated. § 37 (2) has transition rules for service contracts concluded before 28 June 2025 and for products already in use. If you sell only to businesses, or are unsure whether a rule applies to you, ask your legal adviser. We do not give legal advice.

Annex 1 of the BaFG asks that information and the website be perceivable, operable, understandable and robust. For e-commerce it adds three points (Annex 1, section 4, lit. g):

• accessibility information about the products and services for sale, where the economic operator provides it,
• identification, security and payment functions that are perceivable, operable, understandable and robust,
• identification methods, electronic signatures and payment services that meet the same four criteria.

The law does not name a technical standard. A shop that meets harmonised standards is presumed to conform (§ 5). The Sozialministeriumservice says it uses EN 301 549 in its checks, and that EN 301 549 refers to WCAG 2.1. In the standard itself, clause 9.0 says that a web page conforming to WCAG 2.1 Level AA meets all of its web requirements in clauses 9.1 to 9.4. So the practical target for a shop is WCAG 2.1, levels A and AA. The authority adds that several harmonised standards for the law are still being worked on.

§ 14 (2) requires you to prepare the information listed in Annex 3, make it available to the public in written and oral form, including accessible formats, and keep it for as long as you offer the service. Annex 3 says where and what: in your general terms and conditions "oder einem ähnlichen Dokument", you state how the service meets the accessibility requirements. That covers:

• a general description of the service in an accessible format,
• the descriptions and explanations needed to understand how the service works,
• a description of how the service meets the requirements of Annex 1.

We build it as a page of its own, linked from the footer and referenced in the terms and conditions. The technical part we can write with you: what we tested, against which criteria, and what is still open. The legal wording stays with you and your adviser.

Two more duties. If you find the shop does not conform, you must correct it and inform the Sozialministeriumservice (§ 14 (4)). If you rely on the exception for a disproportionate burden, you must assess it against the criteria in Annex 4, inform the authority, and repeat the assessment when the service changes and at least every five years (§ 18).

The market surveillance authority is the Sozialministeriumservice (§ 21), with its Landesstelle Oberösterreich in Linz. Consumers can report barriers to it through an online form. Under § 35, the Verein für Konsumenteninformation, the Österreichischer Behindertenrat, the Bundesarbeitskammer and the Wirtschaftskammer Österreich may do the same. The authority checks each report and answers within eight weeks, in writing and in an accessible format.

If the shop does not conform, the authority can order corrective measures by official decision, after giving you at least ten working days to respond (§ 28). It can also order that the non-compliance be made public, or that the service stop. If it finds a breach, it can charge you the cost of the inspection (§ 23 (9)). Decisions can be appealed to the Bundesverwaltungsgericht (§ 31).

Fines are in § 36. Offering a service that does not meet the requirements costs up to 80,000 euros, or up to 50,000 euros for micro, small and medium-sized enterprises. Breaches of documentation and reporting duties, such as not informing the authority about non-conformity, cost up to 16,000 euros.

This takes a browser, a keyboard and an hour. It does not replace a full test against WCAG 2.1, but it finds the barriers that stop people from buying. The success criteria are in brackets.

Keyboard through the checkout

Put the mouse away. Press Tab from the home page to a product, choose a variant, add it to the cart and go through the checkout to the payment step. Every button, menu, filter and form field has to be reachable and usable (2.1.1), and you have to see where the focus is at every step (2.4.7). Watch the cookie banner, size pickers and the payment form, the usual places to get stuck. If the payment page comes from your payment provider, test it too: Annex 1 names payment functions explicitly.

Contrast

Body text needs a contrast ratio of at least 4.5:1 against its background, large text at least 3:1 (1.4.3). Borders of input fields, icons and focus outlines need 3:1 (1.4.11). The developer tools in Firefox and Chrome show the ratio of a text element. Light grey placeholder text and prices in brand colours are the usual suspects.

Alt texts

Every product image that carries information needs a text alternative (1.1.1). "Image 1" or the file name does not count. Describe what a buyer needs: "Ceramic mug, matte green, with a wooden handle". Decorative images get an empty alt text so screen readers skip them.

Form labels

Every field needs a visible label that stays visible while typing, not only a placeholder that disappears (3.3.2). Required fields say they are required in text, not only with a red asterisk.

Error messages

Submit the checkout with a wrong postcode and an empty email field. The shop has to name the field with the error and describe it in text (3.3.1), and suggest a fix where it can, such as "Please enter an email address like name@example.at" (3.3.3). A red border alone is not enough.

Zoom and small screens

Zoom the browser to 200 %. All text has to stay readable and every function usable (1.4.4). At a width of 320 CSS pixels, which is roughly a 400 % zoom on a laptop, the content has to fit without scrolling sideways (1.4.10).

Time limits

If the cart or a payment session expires, the customer has to be able to turn the limit off, adjust it or extend it (2.2.1).

In the WooCommerce and custom shops we build, accessibility is part of the build, not a plugin at the end: real buttons and links instead of clickable boxes, labels on every field, error messages tied to the field, visible focus, colours chosen for contrast, a checkout you can finish with the keyboard, and alt texts in the product editor. Every point on the checklist above is part of that build.

What we do not do: certify your shop, issue a seal or tell you whether the law applies to your company. That is a legal question for your adviser. We can tell you what your shop does today and build what it needs.

Our online shop service shows how we build and look after shops. Send us your shop's address through the contact form, and we will tell you where the checkout gets stuck.