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Which laws apply to accessible documents? The EU, Austria, Germany and Switzerland at a glance

European Accessibility Act, Web Accessibility Directive, BaFG, BFSG, BITV, EN 301 549 and PDF/UA: which rule applies to whom, since when, and what it means for PDFs. As of October 2026.

By Anna Poledna, Klartext AI

10 min read

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Anyone working on accessible documents quickly runs into a lot of acronyms: EAA, WAD, BaFG, WZG, BFSG, BITV, EN 301 549, PDF/UA. This post sorts them out: which rule applies to whom, since when, who enforces it, and what it means for PDFs.

As of October 2026. This overview is not legal advice.

At a glance

Companies (B2C)Public bodies
EUEuropean Accessibility Act, Directive (EU) 2019/882Web Accessibility Directive, Directive (EU) 2016/2102
AustriaBarrierefreiheitsgesetz (BaFG), since 28 June 2025Web-Zugänglichkeits-Gesetz (WZG) for the federal level, state laws for states and municipalities
GermanyBarrierefreiheitsstärkungsgesetz (BFSG) and BFSGV, since 28 June 2025Behindertengleichstellungsgesetz (BGG) and BITV 2.0 for the federal level, state laws
Technical benchmarkEN 301 549 (WCAG 2.1 AA, now WCAG 2.2 AA); for PDFs in practice PDF/UAsame

In Austria, the Federal Disability Equality Act (BGStG) also applies to everyone.

1. EU: two directives, two audiences

European Accessibility Act (EAA), Directive (EU) 2019/882

The EAA has applied since 28 June 2025 and covers companies offering certain products and services to consumers.

Services covered (Art. 2(2)): electronic communications, access to audiovisual media, air, bus, rail and waterborne passenger transport (websites, apps, e-tickets, travel information), consumer banking, e-books and e-commerce. E-commerce covers everything offered via a website or app "with a view to concluding a consumer contract" (Art. 3(30)).

Products covered (Art. 2(1)): computers and operating systems, payment terminals, ATMs, ticketing and check-in machines, smartphones, smart TVs, e-readers.

Key for PDFs (Art. 2(4)): the only exemptions are office files published before 28 June 2025, archives not updated after that date, and third-party content. Anything published or updated since then is in scope.

Microenterprises (fewer than 10 employees and turnover or balance sheet of at most €2 million) that provide services are exempt (Art. 4(5)). The exemption does not apply to products.

Disproportionate burden (Art. 14): anyone relying on it must carry out an assessment using Annex VI, document it, keep it for five years, inform the authority and renew the assessment at least every five years. Anyone who received funding for accessibility cannot rely on it.

Transition periods (Art. 32): service contracts concluded before 28 June 2025 may run until they expire, for at most five years. Products already in use may continue to be used until 28 June 2030.

What Annex I requires for documents: information about the service must be available via more than one sensory channel, in text formats that can be used to generate assistive formats, with alternatives for non-text content. Electronic information needed to provide the service must be perceivable, operable, understandable and robust. For banks, information must also be no more complex than language level B2.

Web Accessibility Directive (WAD), Directive (EU) 2016/2102

It requires public sector bodies to make websites and apps accessible:

  • new websites since 23 September 2019
  • all websites since 23 September 2020
  • mobile apps since 23 June 2021

For PDFs (Art. 1(4)): office files published before 23 September 2018 are exempt, unless they are needed for active administrative processes, such as forms.

Public bodies must publish an accessibility statement with a feedback mechanism through which anyone can report barriers or request exempted content in an accessible form.

2. Austria

Barrierefreiheitsgesetz (BaFG), BGBl. I No. 76/2023

Implements the EAA and has applied since 28 June 2025. Scope, exemptions and deadlines follow the EAA. Three points are specific to Austria:

  • Service information (§ 14(2) and Annex 3): must be publicly available in written and oral form, including in an accessible form.
  • Authority (§ 21): the Sozialministeriumservice is the market surveillance authority. It can set deadlines for corrections and, by formal decision, order a service to be stopped, for example.
  • Penalties (§ 36):
BreachMaximum finefor SMEs
non-conforming product or service€80,000€50,000
Annex 3 information missing or deficient€40,000€25,000
other breaches, e.g. authority not informed€16,000€10,000

Transition: products already in use and existing contracts until 28 June 2030, self-service terminals until 28 June 2040 at the latest (§ 37).

Enforcement so far: by June 2026 the Sozialministeriumservice had opened 84 proceedings, 36 of them on its own initiative, 22 of those in banking. 53 companies had reported their own shortcomings, mainly in banking, finance and insurance. No fines had been issued; the authority follows the principle "advice before penalties". Consumers, the consumer association VKI, the Disability Council, the Chamber of Labour and the Chamber of Commerce can report breaches (§ 35).

Web-Zugänglichkeits-Gesetz (WZG), BGBl. I No. 59/2019

Implements the WAD for the federal level: ministries, federal authorities and bodies controlled or mainly financed by the federal government. The states have their own laws for their bodies and municipalities.

  • Office files published before 23 September 2018 and not needed for ongoing administrative procedures are exempt (§ 2(3)).
  • Accessibility statement required (§ 4).
  • Monitoring and complaints body: the FFG, with a report every three years (§ 5).
  • The WZG itself has no penalties. People affected can complain to the FFG and act under the BGStG.

Federal Disability Equality Act (BGStG), BGBl. I No. 82/2005

Applies to the federal administration and to private companies offering goods and services to the public (§ 2). Barriers count as discrimination unless removing them would be a disproportionate burden. Even then, reasonable improvements are owed (§ 6).

People affected are entitled to damages (§ 9). Before going to court, a conciliation procedure at the Sozialministeriumservice is mandatory (§ 14). The Disability Council, the Klagsverband and the Disability Ombudsman can bring a collective action (§ 13).

3. Germany

Barrierefreiheitsstärkungsgesetz (BFSG) and BFSGV

Implements the EAA and has applied since 28 June 2025. The ordinance (BFSGV) sets the technical requirements in detail.

  • Information duty (§ 14 and Annex 3): the accessibility information goes in the terms and conditions "or in another clearly perceivable way" and must itself be accessible.
  • Fines (§ 37): up to €100,000 for non-conforming products or services, up to €10,000 for other breaches, such as missing information.
  • Transition (§ 38): existing contracts and products in use until 27 June 2030. Self-service terminals at most 15 years, so stricter than in Austria.
  • New since July 2026: an amendment to the BFSGV has been in force since 16 July 2026. It closes gaps on self-service terminals and emergency calls. In March 2026 the European Commission had again formally warned Germany about incomplete transposition.

Authority: the joint market surveillance office of the federal states for accessibility (MLBF) in Magdeburg has been responsible since September 2025. By June 2026 it had received almost 700 reports. It works with multi-year surveillance strategies. No fines have been made public yet.

Warning letters: since 2025 there have been waves of competition-law warning letters (Abmahnungen). No court has yet decided whether the BFSG is a market-conduct rule under § 3a UWG, which would make such letters admissible.

Public bodies: BGG and BITV 2.0

At federal level, the Disability Equality Act (§§ 12a to 12c) and the Accessible Information Technology Ordinance (BITV 2.0) apply. They cover websites, apps and electronically supported administrative processes including e-files. Forms, authentication and payment should reach the "highest possible degree" of accessibility. An accessibility statement and feedback mechanism are mandatory. Each federal state has its own rules.

A reform of the BGG is before the Bundestag (printed paper 21/5140). It would require private providers to make "reasonable accommodations". As of October 2026 it has not been adopted.

4. Switzerland in brief

  • The Disability Discrimination Act (BehiG) currently binds the federal administration. Federal websites must meet the eCH-0059 standard, which requires WCAG 2.1 AA.
  • A revision of the BehiG would require private service providers to make reasonable accommodations, explicitly including digital documents, with EN 301 549 as the reference. The parliamentary process is ongoing.
  • Swiss companies selling products or services to consumers in the EU fall under the EAA.

5. The technical standards

EN 301 549 is the European standard for accessible ICT. Clause 10 covers non-web documents, including PDFs. It adopts the WCAG criteria.

  • Version 3.2.1 (2021) is based on WCAG 2.1 AA. It is currently the version that gives a presumption of conformity under the Web Accessibility Directive.
  • Version 4.1.1 (September 2026) is based on WCAG 2.2 AA and for the first time maps to the EAA. It has not yet been cited in the Official Journal of the EU. Ireland's National Disability Authority expects this in December 2026. Until then, there is no harmonised standard giving a presumption of conformity under the EAA.

PDF/UA (ISO 14289) is the technical standard for accessible PDFs.

  • PDF/UA-1 (ISO 14289-1:2014), based on PDF 1.7, is today's common test standard.
  • PDF/UA-2 (ISO 14289-2:2024), based on PDF 2.0, was published in March 2024.
  • The PDF Association's Matterhorn Protocol translates PDF/UA-1 into 136 testable failure conditions. 89 of them can be checked by machine, 45 need human judgement.

How does it fit together? No law names PDF/UA explicitly. The legal benchmark is the principles "perceivable, operable, understandable, robust", made concrete by EN 301 549 and WCAG. PDF/UA is the established technical standard for testing whether a PDF meets these requirements. In practice, PDF/UA and EN 301 549 clause 10 together serve as the benchmark for whether a PDF is accessible.

6. What this means for PDFs

Companies (BaFG, BFSG), for documents published or updated since 28 June 2025 that belong to a covered service:

  • Banks: contracts, pre-contractual information, terms and conditions, account statements, at language level B2
  • E-commerce: product information, accessibility information, documents in the ordering process
  • Transport: e-tickets, timetables, travel information
  • E-books, including in PDF format
  • Products: instruction manuals
  • The accessibility information itself
  • Invoices and order confirmations: plausibly covered as information needed for the service. No authority has confirmed this yet.

Not covered: B2B offers, microenterprises providing services, and sectors outside the scope. In Austria, the general anti-discrimination rule of the BGStG still applies to them.

Public bodies (WAD, WZG, state laws, BITV 2.0): all PDFs on websites and in apps published since 23 September 2018, and older ones if they are needed for ongoing administrative procedures.

Key dates

DateWhat
23 Sep 2018cut-off date for documents of public bodies
23 Sep 2020all public-sector websites accessible
23 Jun 2021public-sector apps accessible
28 Jun 2025EAA, BaFG and BFSG apply; cut-off date for company documents
16 Jul 2026BFSGV amendment in force
2 Sep 2026EN 301 549 V4.1.1 with WCAG 2.2 published
Dec 2026 (expected)V4.1.1 cited in the Official Journal
28 Jun 2030end of transition period for existing contracts and products

If you have many documents covered by these rules, our guide for companies sets out the next steps. doclarity makes PDFs and office documents accessible to PDF/UA and shows the veraPDF result for every document. doclarity.eu

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