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Guide Origin: Community | ArcKit Version: [VERSION]
/arckit:at-barrierefreiheit assesses Austrian digital accessibility obligations across the country's two separate transposition tracks, determines which apply, and produces a conformance assessment with a remediation roadmap.
- BaFG — Bundesgesetz über Barrierefreiheitsanforderungen für Produkte und Dienstleistungen, BGBl. I Nr. 76/2023, applicable since 28 June 2025. Transposes Directive (EU) 2019/882, the European Accessibility Act. Binds manufacturers, importers, distributors and service providers.
- WZG — Web-Zugänglichkeits-Gesetz, BGBl. I Nr. 59/2019, in force 23 July 2019. Transposes Directive (EU) 2016/2102. Binds federal public bodies for their websites and mobile applications.
An entity can be subject to both. A federal body running an in-scope e-commerce or banking service is the common case.
Inputs
| Artefact | Purpose |
|---|---|
Requirements (ARC-<id>-REQ-v*.md) |
NFR-UX targets and the user-facing functional scope |
Stakeholder analysis (ARC-<id>-STKE-v*.md) |
User groups, assistive-technology users, consumers vs citizens |
| Diagrams / HLD | The actual surfaces — web, mobile, kiosk, terminal, documents |
AT procurement (ARC-<id>-BVERGG-v*.md) |
Any accessibility clause already imposed on a supplier |
Existing Barrierefreiheitserklärung (external/) |
Current published conformance position |
Command
/arckit:at-barrierefreiheit <project ID or entity/service description>
Output: projects/<id>/ARC-<id>-ATBFR-v1.0.md
Assessment Structure
| Section | Contents |
|---|---|
| Applicability Determination | Each track decided independently, with reasoning; microenterprise exemption; Land-level routing |
| Standard and Conformance | EN 301 549 v3.2.1 → WCAG 2.1 AA per-criterion table, test method, non-web clauses |
| Barrierefreiheitserklärung | WZG track — the five required elements of the statutory statement |
| Product and Service Requirements | BaFG track — requirements mapping, conformity route, statutory defences |
| Market Surveillance and Monitoring | SMS versus FFG, with the exposures kept separate |
| Gap Analysis and Roadmap | Prioritised by user impact, with owners, dates and NFR-UX references |
| External References | BaFG, WZG, both Directives, EN 301 549, WCAG 2.1 |
Which Track Applies
| Entity | Surface | Track |
|---|---|---|
| Federal ministry | Citizen portal, mobile app | WZG |
| Land or municipal body | Any | Neither — the applicable Landesgesetz |
| Bank, retailer, telco | Consumer-facing service in Annex scope | BaFG |
| Terminal manufacturer or importer | Self-service terminal, e-reader | BaFG (products — no microenterprise exemption) |
| Federal body running an in-scope e-commerce service | Website plus that service | Both, assessed separately |
One-Page Workflow
| Phase | Key Activities | ArcKit Commands |
|---|---|---|
| Requirements | Capture NFR-UX accessibility targets | /arckit:requirements |
| Applicability and conformance | Determine tracks, assess EN 301 549 | /arckit:at-barrierefreiheit |
| Remediation procurement | Carry the target into the tender | /arckit:at-bvergg |
| Feedback-channel privacy | Where the channel collects personal data | /arckit:at-dsgvo |
| Traceability | Link gaps back to requirements | /arckit:traceability |
Review Checklist
- Both tracks determined independently, with the reasoning recorded rather than only the verdict.
- Microenterprise exemption applied to services only, never to products.
- Headcount and financial evidence for any claimed exemption recorded in the assessment.
- Land-level bodies routed to the Landesgesetz, not assessed under the federal WZG.
- Conformance assessed against EN 301 549 v3.2.1 / WCAG 2.1 AA; any use of 2.2 AA recorded as a deliberate forward-looking choice.
- Test method stated per criterion, distinguishing automated tooling from manual and assistive-technology testing.
- Accessibility statement assessed against all five required elements where WZG applies.
- CE marking applied to products only, never to services.
- Disproportionate burden and fundamental alteration claims backed by a retained, dated assessment.
- No fine regime asserted under the WZG.
Common Gaps
- Treating the microenterprise exemption as entity-wide. § 6 BaFG exempts Kleinstunternehmen for the services they offer or provide. Products are not exempt at any size. A nine-person importer of ticketing terminals is fully in scope, and this is the single most common misreading of the act.
- An exemption with nothing behind it. The Sozialministeriumservice can require an entity claiming the exemption to produce its headcount and financial evidence. A tick-box claim with no figures on file is a gap.
- Assuming the federal WZG covers everything public. The Länder legislate separately. A Land hospital or a municipal portal is outside the federal act.
- Importing the EUR 80,000 figure into a public-sector assessment. That ceiling is BaFG. The WZG carries monitoring, complaints and publication — no administrative fines.
- A statement that recites conformance and lists nothing. The Barrierefreiheitserklärung must enumerate non-accessible content in three categories. A clean statement over a site that fails an automated scan is the fastest way to attract a complaint.
- Automated scanning presented as conformance evidence. A tool finds a minority of WCAG failures. Keyboard traps, focus order and meaningful alternative text need manual and assistive-technology testing.
- CE marking a service. Products take a declaration of conformity and CE marking; services take a published description and retained documentation.
- Assessing emergency calls under the BaFG. Notrufe are transposed through the TKG 2021.
Key Notes
- Standard version: EN 301 549 v3.2.1 is the version cited in the Official Journal, so it is what carries the presumption of conformity under both Directives, and it normatively references WCAG 2.1 AA. Draft v4.1.0 went to public review in November 2025; final v4.1.1, expected to carry WCAG 2.2 AA, is anticipated to be OJ-cited around October 2026
[NEEDS VERIFICATION]. This matches the position/arckit:at-bverggtakes on §107 BVergG, and it differs from the UK, where SI 2022/1097 made the WCAG reference rolling and 2.2 AA is already the monitored target. - Paragraph references: the BaFG § numbers used by this command (§ 3 Z 19 definition, § 6 exemption, § 21 surveillance, § 36 penalties) are drawn from secondary sources because RIS was unavailable at authoring time. Confirm against RIS before external reliance.
- Scope of this command: the entity's own products, services, websites and apps. Accessibility as a procurement clause (§107 BVergG) is
/arckit:at-bvergg.