Professional assessment, as of May 2026. Not legal advice.
The line is drawn at selling, not at size
The law targets digital offerings through which consumers can buy, book, or complete transactions. Running an online shop, offering a booking system, providing online banking, or selling tickets brings you under scope, with no transition period for the website itself.
A purely informational website with no sales or booking function does not fall under it. The Austrian Federal Economic Chamber (WKO) explicitly states that a site showing only information and contact details does not constitute a service in electronic commerce. A purely B2B offering that serves only business customers and enables no consumer transaction on the site is also not covered.
The threshold is function, not company size. Selling or booking for consumers triggers the obligation; a digital shop window does not. Once such a function is added, the answer flips from no to yes.
The microenterprise exemption, drawn clearly
There is an exemption for microenterprises, and, unlike how it is often described, it is clear-cut for the most common case. A microenterprise is one that employs fewer than ten people and has an annual turnover or balance sheet total of at most two million euros. Both conditions must be met simultaneously.
The crucial distinction is between services and products. For services, accessibility requirements are waived for microenterprises entirely, as the Federal Social Office (Sozialministeriumservice) makes clear. Running an online shop counts legally as a service in electronic commerce. A small online shop below these thresholds is therefore exempt. Only those who manufacture or distribute products within the meaning of the law, such as self-service terminals or certain hardware, do not get a full exemption but only relief measures.
There is also a practical relief: microenterprises have no documentation obligation. They only need to provide the relevant facts to the authority on request, not proactively prepare and submit an assessment.
Does this apply to me? A quick overview
| Your presence | Accessibility Act |
|---|---|
| Online shop or booking, 10 or more employees or 2 million or more turnover | Yes, since 28 June 2025 |
| Online shop as a microenterprise (under 10 and under 2 million) | Exempt, because the shop counts as a service |
| Online banking, ticketing, telecoms service | Yes |
| Pure information website without shop or booking | No, though voluntary compliance still makes sense |
| Pure B2B platform without consumers | No |
| Public authority or public body | Separate law (WZG), not the BaFG/EAAG |
This classification follows the interpretation of the Federal Economic Chamber and the Federal Social Office (Sozialministeriumservice). A closer look is worthwhile in only two situations: if your offering includes covered physical products alongside the online shop, and if your figures sit right at the ten-person or two-million threshold. Otherwise the answer is straightforward.
What “accessible” actually requires technically
Behind the word sits a recognised standard, at its core the WCAG guidelines at level AA. In plain terms: images need alternative text, videos need captions, text needs sufficient contrast. The site must be fully operable by keyboard, focus must be visible, form fields must be labelled, and the HTML must be clean enough for screen readers to work with. Those who are in scope must also publish an accessibility statement, findable in much the same way as a legal notice.
When full compliance would be disproportionate
The law has a built-in relief valve that many overlook. If meeting individual requirements would represent a disproportionate burden, meaning excessive financial or organisational effort, those points do not need to be met after an assessment against prescribed criteria. This is governed by sections 17 and 18 of the act.
Honest handling of this belongs exactly where everyone can see it: in the accessibility statement on your website. There you name openly which parts are not yet accessible and why. The statement is not a fig leaf; it is the designated place where limits are made transparent. Nor is it a blank cheque: “too expensive” alone is not enough, the assessment must be sound. Larger companies must document it and submit it to the Federal Social Office (Sozialministeriumservice); microenterprises are exempt from this and only supply the facts on request.
What implementation and review cost
Two cost blocks are worth keeping separate. The first is implementation itself, building accessibly or retrofitting. On a new build it barely registers, because much can be done cleanly from the start. Retrofitting an existing site that has grown organically costs considerably more.
The second is a formal review. A meaningful audit by an accredited, independent certification body, in Austria for example via the WACA certificate, is a separate line item. Depending on scope, this ranges from around 1,500 euros for small sites to 8,000 to 15,000 euros for online shops. The reason: automated tools catch only a fraction of barriers, and a reliable review requires manual testing with screen readers. One role distinction matters here: I build and repair to standard and tell you where you stand. The official certificate is issued by an independent certification body, not by me.
What you risk if you do nothing
Anyone who ignores an obligation risks more than a warning. Administrative fines are graduated by severity and company size and reach up to 80,000 euros, with lower ceilings for smaller businesses. Even an outdated conformity statement can attract a fine of up to 40,000 euros. For a first or minor breach, the legislative materials do emphasise that advice comes before penalty.
There is also a cross-border perspective: in Germany, lawyers began sending formal cease-and-desist letters over missing accessibility as early as summer 2025. Such cases have not yet been documented in Austria, but legal commentators consider them increasingly likely. If you are already in scope, it is not worth waiting for a precedent.
This is the third compliance deadline alongside the EU AI Act and cookie requirements. If you are keeping an eye on one, you should check the others at the same time.
Accessibility built in from the start is the cheapest option
Building a new site accessibly costs a fraction of what retrofitting it later takes. And an existing site can be improved precisely where the law demands it, rather than tearing everything down and starting over. I tell you first whether and where you actually need to act, then bring the site up to standard. Let’s talk.
Frequently asked questions
Has my website had to be accessible since 2025?
That depends on what it does. Anyone offering an online shop, bookings, online banking, or ticket sales for consumers has been in scope since 28 June 2025, with no transition period. A pure information site with no sales or booking function, and a pure B2B offering, do not fall under the law according to the Federal Economic Chamber’s interpretation.
Am I exempt as a microenterprise?
For services, yes. A microenterprise is one with fewer than ten employees and no more than two million euros in turnover or balance sheet total, both at the same time. Since running an online shop counts as a service, a small shop below these thresholds is exempt. Only for the manufacture or distribution of covered products is there relief rather than a full exemption.
What does an accessible website actually mean in practice?
At its core, meeting the WCAG guidelines at level AA. That means, among other things, alternative text for images, captions for videos, sufficient contrast, full keyboard operability, visible focus, and clean HTML for screen readers. Those in scope must also publish an accessibility statement.
What if full compliance is disproportionately expensive for me?
Then the disproportionate burden exception applies. Requirements that represent excessive effort do not need to be met after an assessment. You name these limits openly in your accessibility statement. That is not a blank cheque; the assessment must be sound under the statutory criteria, and larger companies must document it.
What does a professional review cost?
An audit by an accredited external certification body is a separate cost item, ranging from around 1,500 euros for small sites to 8,000 to 15,000 euros for online shops, depending on scope. The effort arises because automated tools only find part of the barriers and the rest must be checked manually with screen readers. The official certificate is issued by an independent body, not by the service provider who built the site.
What happens if I do nothing?
If you have an obligation and ignore it, you face administrative fines graduated by severity and company size, reaching up to 80,000 euros. For a first or minor breach, the legislative materials put advice before penalty. There is also a cease-and-desist risk along German lines, not yet documented in Austria but considered increasingly likely.
Is accessibility worth it even if I do not have to?
Often yes. An accessible site works for more people, tends to be better understood by search engines, and is future-proof if the obligation is extended. On a new build the extra effort is minimal, because much can be done cleanly from the start.
This article provides a professional assessment of the legal situation and does not replace legal advice in individual cases.