What Austria's Accessibility Act means for PDF documents
Austria transposed the European Accessibility Act through the Barrierefreiheitsgesetz (BaFG), Federal Law Gazette I No. 76/2023. Since 28 June 2025, covered products and services have had to be accessible. For PDFs this mostly concerns invoices, contracts and terms that are generated continuously, as soon as they belong to a covered service.
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General orientation, not legal advice. Whether and to what extent your organisation is affected should be assessed case by case with a qualified adviser. Section references are to the BaFG as published in the Austrian Federal Legal Information System (RIS); English terms are our own descriptive translations.
The European framework and the role of EN 301 549 and PDF/UA are described in European Accessibility Act and PDFs. This page deals with the Austrian rules.
How the BaFG is structured
Germany put its requirements into a separate regulation. The BaFG contains them directly in its annexes. Section 4 obliges economic operators to place on the market only products, and offer only services, that meet the requirements of Annex 1. Annex 3 covers information about services, Annex 4 the criteria for disproportionate burden.
Under section 5, products and services are presumed to conform where they meet harmonised standards whose references have been published in the Official Journal of the EU. In practice that means EN 301 549. For PDFs it comes down, essentially, to the WCAG criteria as applied to documents.
Scope
Section 2 BaFG covers products placed on the market after 28 June 2025, such as consumer computer hardware, payment and self-service terminals, and e-readers. It also covers services provided to consumers after that date. These include electronic communications services, elements of passenger transport services, consumer banking services, e-books and dedicated software, and e-commerce services. Our industry overview explains what this means sector by sector.
Definitions are in section 3. Consumers (no. 18) are natural persons acting outside their trade, business or profession. Offerings aimed exclusively at businesses therefore generally fall outside the service obligations.
Content exemptions that affect PDFs
Section 2(3) BaFG excludes certain content of websites and mobile apps, including:
- office file formats published before 28 June 2025 (no. 2),
- third-party content that the operator neither funds, develops nor controls (no. 4),
- archives whose content is not updated or edited after 28 June 2025 (no. 5).
An unchanged 2023 PDF in a download archive may therefore be exempt. A PDF that is created, updated or republished after the cut-off date and forms part of a covered service has to be accessible. In practice that hits continuously generated documents hardest: invoices, account statements, contract documents, tickets.
Microenterprises
Under section 6 BaFG, microenterprises providing services are exempt from the service requirements and the related obligations. Section 3 no. 19 defines a microenterprise as employing fewer than ten people with an annual turnover or balance sheet total not exceeding EUR 2 million. Products are not covered by the exemption. Section 6(2) also provides for guidelines to help microenterprises apply the law.
Obligations of service providers
Section 14 BaFG requires services to meet the requirements and the information under Annex 3 to be provided. According to Annex 3, that information belongs in the general terms and conditions or a similar document. It includes, among other things, a general description of the service in an accessible format and a description of how the service meets the requirements. If your terms and accessibility information are PDFs, those PDFs must themselves be accessible.
Where a service does not conform, corrective action must be taken (section 14(4)). Providers using self-service terminals must also give information about the accessibility of the surrounding built environment (section 15). Exceptions for fundamental alteration (section 17) or disproportionate burden (section 18) are possible. They require a documented assessment.
Market surveillance by the Sozialministeriumservice
Under section 21 BaFG, the competent market surveillance authority is the Sozialministeriumservice (SMS), Austria's Federal Office for Social Affairs and Disability. It monitors products and services and can take measures concerning services (section 28) and formal non-conformity (section 29), for instance when the Annex 3 information is missing. Usually the operator is first invited to comment and asked to correct the problem. A formal decision follows only if the non-conformity persists. SMS decisions can be appealed to the Federal Administrative Court (section 31).
Complaints and conciliation
Under section 35 BaFG, consumers can report suspected breaches to the Sozialministeriumservice. The Consumer Information Association (VKI), the Austrian Disability Council, the Federal Chamber of Labour and the Austrian Economic Chamber have the same right. The SMS examines the report and states in writing and in an accessible format within eight weeks whether it will open proceedings. If it will not, it has to give reasons.
The Federal Disability Equality Act (BGStG) continues to apply alongside the BaFG. Anyone who feels discriminated against in accessing goods and services must go through a conciliation procedure at the Sozialministeriumservice before taking a claim to court (sections 10 and 14 et seq. BGStG). An inaccessible contract or invoice PDF can come up this way too.
Penalties under section 36 BaFG
Breaches are administrative offences. The Sozialministeriumservice imposes fines, with tiered maximum amounts.
| Type of breach | Maximum fine | Micro, small and medium-sized enterprises |
|---|---|---|
| Para. 1: placing non-conforming products on the market, offering or providing non-conforming services | EUR 80,000 | EUR 50,000 |
| Para. 2: e.g. shortcomings in conformity assessment, documentation, service information, corrective action, CE marking | EUR 40,000 | EUR 25,000 |
| Para. 3: e.g. retention, information and cooperation duties towards the SMS | EUR 16,000 | EUR 10,000 |
The amount depends on factors such as the extent of the breach, the number of products, services and people affected, and repeated breaches (section 36(4)). Fines go to the support fund for people with disabilities.
Transitional provisions
Under section 37 BaFG, service providers may continue to use products they lawfully used before 28 June 2025 until 28 June 2030. Service contracts concluded before 28 June 2025 may continue unchanged until they expire, but for no more than five years. Self-service terminals may be operated until the end of their economic life, for no longer than 20 years after being put into use and not beyond 28 June 2040. Newly created documents have no transitional period.
BaFG and the Web Accessibility Act
The BaFG targets economic operators and their consumer offerings. Websites, apps and documents of the federal government and certain public bodies fall under the Web Accessibility Act (Web-Zugänglichkeits-Gesetz, WZG), while the federal provinces have their own laws. See our guide to accessible PDFs in the public sector. Publicly owned companies that provide consumer services should check whether both regimes apply to them.
Working through your PDFs
First settle three questions: do you offer a covered service, is it aimed at consumers, and is your company above the microenterprise thresholds? Only once that is clear does work on the documents make sense.
Separate continuously generated documents from unchanged legacy files and archives, and write down how you classified them. Run the current PDFs through a PDF/UA check for tags, title, language and fonts. What a checker cannot see is covered by the manual points in the checklist.
The biggest lever is usually the invoice and contract generator. Once it outputs tagged PDFs, much of the day-to-day output is in better shape. For documents without a source file, tagging the PDF after the fact creates a technical base structure that is then reviewed manually. And do not forget the Annex 3 information: it has to be published accessibly in your terms or a similar document.
EasyPDFUA supports checking and conservative tagging (basic tags, title, language, links, fonts/Unicode). A report or a tagged copy does not prove compliance with the BaFG. For the situation in Germany, see our guide to the BFSG.
Frequently asked questions
Who enforces the Accessibility Act in Austria?
The Sozialministeriumservice, which section 21 BaFG makes the competent market surveillance authority. It also receives reports from consumers and from certain organisations.
How high are the penalties under the BaFG?
Up to EUR 80,000 for offering non-conforming services or placing non-conforming products on the market, or up to EUR 50,000 for micro, small and medium-sized enterprises. Other breaches carry maximum fines of EUR 40,000 or EUR 16,000.
Does the BaFG apply to older PDFs?
Not while they stay unchanged. Office file formats published before 28 June 2025 and archives not updated after that date are exempt under section 2(3) BaFG. Newly created or revised PDFs are covered.
Does the BaFG apply to public authorities?
No. Websites, apps and documents of public bodies are covered by the federal Web Accessibility Act and the respective provincial laws. The BaFG targets economic operators with offerings for consumers.