Skip to content

Digital accessibility for companies: does it apply to us, and what do we need to watch out for?

Since 28 June 2025, new accessibility duties apply in Austria and Germany. A practical guide for companies: who is covered, what is required, and what matters for documents and PDFs.

By Anna Poledna, Klartext AI

8 min read

Diesen Beitrag auf Deutsch lesen

The European Accessibility Act (EAA) has applied since 28 June 2025. Austria implemented it with the Barrierefreiheitsgesetz (BaFG), Germany with the Barrierefreiheitsstärkungsgesetz (BFSG). Requirements that used to apply mainly to public bodies now cover many companies too.

This guide answers the questions companies ask us most often. It shows where to start. For your specific case it does not replace legal advice.

1. Does the law apply to us?

The law covers certain products and services aimed at consumers.

Services include:

  • e-commerce
  • consumer banking services
  • electronic communication services, including messengers
  • e-books
  • elements of passenger transport services: websites, apps, e-tickets
  • access to audiovisual media services

Products include computers and operating systems, smartphones, smart TVs, e-readers and self-service terminals such as ATMs or ticket machines.

E-commerce is broader than many think

It means any website or app through which consumers can conclude a contract. The Austrian Chamber of Commerce (WKO) gives the example of a foot-care practice: as soon as customers can book an appointment or buy products on its website, the business is covered, even though its sector is not named in the law. The entire website is then covered, including the checkout.

Who is exempt

  • Purely B2B offers are not covered.
  • Microenterprises providing services are exempt: fewer than 10 employees and annual turnover or balance sheet total of at most €2 million.
  • There is no such exemption for products.

In Austria, also: the Disability Equality Act

Independently of the BaFG, Austria's Federal Disability Equality Act (Bundes-Behindertengleichstellungsgesetz) prohibits discrimination in access to goods, services and information offered to the public. The WKO points out that this applies to all companies.

2. What is actually required

Accessible digital offers. Website, shop and app must be perceivable, operable, understandable and robust. The benchmark is the standard EN 301 549 and, within it, the Web Content Accessibility Guidelines (WCAG 2.1, level AA). Typical requirements: alt text for images, captions for videos, sufficient contrast, keyboard operation, visible focus, enough time for input. The new version EN 301 549 V4.1.1 of September 2026 already refers to WCAG 2.2, so anything planned now is best aligned with it.

Accessibility information. Companies must describe how their service meets the requirements and name the competent market surveillance authority. In Austria that is the Sozialministeriumservice; in Germany the joint market surveillance office of the federal states (MLBF) in Magdeburg. The WKO recommends a separate, easy-to-find page for this rather than a paragraph in the terms and conditions, because statements in the terms can become part of the contract.

Documentation when something cannot be done. Anyone relying on a disproportionate burden or a fundamental alteration of the service must justify and document it, keep the record for five years and reassess at least every five years.

3. Documents and PDFs: the part that is often overlooked

The law does not name PDFs explicitly. But it only exempts office files published before 28 June 2025. Conversely, documents provided on a covered website or in a covered app since then are part of the offer and must be accessible. This includes product information, price sheets, terms and conditions, forms and documents in the ordering process.

If an old PDF is revised and uploaded again, for example an updated price list, it counts as newly published. This reading is plausible, but not yet confirmed by authorities or courts.

What makes a PDF accessible

  • Tags: the document has a structure marking headings, paragraphs, lists and tables.
  • Reading order: the screen reader reads in the order a person would.
  • Alt text: informative images and charts are described; decorative ones are marked as artifacts.
  • Tables: header cells are marked and linked to the data.
  • Language: the document language is set; passages in other languages are marked.
  • Title: a document title is set and displayed.
  • Fonts: embedded and correctly mapped to Unicode, so special characters are read correctly.
  • Forms: real form fields with clear labels.
  • Navigation: bookmarks and, for long documents, a linked table of contents.
  • No security restrictions that block assistive technology.

Technically, all this is defined in the PDF/UA standard (ISO 14289).

What it looks like in practice

A 2026 study by axes4 and Mindscreen checked almost 70,000 PDFs from 76 German public-sector websites. Only 9.5% were conformant according to the PDF Accessibility Checker (PAC), and 37.4% were not tagged at all. Our own survey of 382 public institutions in Austria arrives at 5.8%. For companies there are hardly any figures yet. An EY Austria study in 2025 found only two of 100 company websites checked that met the requirements.

4. How to check whether a PDF is accessible

Three tools are widely used:

  • PAC (PDF Accessibility Checker): free, checks nearly all machine-checkable criteria and offers a screen-reader preview.
  • veraPDF: open-source validator for PDF/UA, also suitable for checking many files automatically.
  • Adobe Acrobat Pro: the built-in check is a starting point. It does not test against PDF/UA.

Important: no tool checks everything. The PDF Association's Matterhorn Protocol defines 136 failure conditions. 89 of them can be checked by machine, 45 need human judgement. Whether alt text describes an image meaningfully or whether the reading order is right is ultimately decided by a person. The most telling test is with a screen reader, ideally with people who use one every day.

5. Routes to an accessible document

RouteGood forWatch out for
Accessible in the source (Word, InDesign)new documents from maintained templatesneeds trained staff and often add-on plugins; the standard export alone is rarely enough
Manual remediationone-off or very complex documentslabour-intensive: providers charge per hour or per page, and effort rises sharply with complex documents
Automated remediationlarge volumes, archives, documents without a maintained templatecheck the quality carefully: a green tick in a checker is not enough on its own

If you commission PDFs from agencies or printers, write accessibility into the brief. Sensible requirements include: PDF/UA-1 as the standard, an error-free PAC or veraPDF report, a manual check of the criteria no tool can test, agreed alt texts and at least one correction round.

6. Common misconceptions

  • "An overlay plugin makes the website compliant." The European Disability Forum and the IAAP made clear in 2023: overlays do not make a website accessible or compliant with European law. They can even interfere with assistive technology.
  • "The checker is green, so the PDF is accessible." A green result means: no machine-detectable error. About a third of the criteria need human review.
  • "Our scan has OCR, that's enough." Text recognition makes text searchable. Structure, reading order and alt text are still missing.
  • "A paragraph in the terms is enough." The accessibility information belongs on its own, easy-to-find page.
  • "This only affects large corporations." The exemption threshold is fewer than 10 employees. There is no exemption for products.

7. How strictly is it enforced?

Austria: the Sozialministeriumservice is the market surveillance and penalty authority and follows the principle "advice before penalties". According to ORF, 84 proceedings had been opened by June 2026, 74 of them still pending. 36 were started by the authority itself, 22 of those against banks. No fines had been issued by then. Administrative fines of up to €80,000 are possible, with lower caps for SMEs.

Germany: the MLBF has been fully responsible since September 2025. By June 2026 it had received almost 700 reports. Fines of up to €100,000 are possible. So far, mainly competition-law warning letters (Abmahnungen) have been reported.

Europe: in June 2026 a French court ordered Carrefour to reach full compliance within six months, with €500 per day after that.

Checklist to get started

  1. Clarify whether your offer is covered (B2C, sector, company size).
  2. Take stock: website, shop, app, customer portal, downloadable documents, customer service channels.
  3. Set priorities: start with everything in the purchase or contract process.
  4. Publish a page with your accessibility information.
  5. Check documents with PAC or veraPDF, plus spot checks with a screen reader.
  6. Adapt templates and workflows so new documents are accessible from the start.
  7. Write accessibility into briefs for agencies and service providers.
  8. Offer a feedback channel and take responses seriously. This is good practice for companies, even where the law does not explicitly require it.
  9. If something cannot be done: justify and document it.

If you have many existing documents, or documents regularly come about without a maintained template, doclarity can help: it makes PDFs and office documents accessible, shows the veraPDF result transparently and lets you check every spot yourself. More at doclarity.eu

Sources

More articles

information for all

Ready for clarity?

Start with 30 free pages – no card needed, and analysis is always free.

Reach outSign up