1. The Two Laws: BaFG and BGStG
Austria is unique compared to other EU countries: the alt text requirement comes not from one law, but from two — complementing each other and covering different target groups.
🇦🇹 BaFG — Barrierefreiheitsgesetz (since Jun 28, 2025)
Austria’s implementation of the European Accessibility Act (EAA). Applies to private businesses offering certain products and services to consumers.
• Technical standard: WCAG 2.1 Level AA via EN 301 549
• Fines: Up to €80,000 (large enterprises), €50,000 (SMEs), €25,000 (micro-enterprises)
• Enforcement: Sozialministeriumservice (Upper Austria regional office)
• Micro-enterprise exemption: Under 10 employees AND under €2M revenue (services only)
🇦🇹 BGStG — Federal Disability Equality Act (since 2006)
Prohibits discrimination in access to publicly offered goods and services — including digital access. Missing alt text can qualify as discrimination.
• Applies to: ALL businesses that publicly offer goods/services
• No micro-enterprise exemption — even sole proprietors can be affected
• Enforcement: Mediation at the Sozialministeriumservice, then civil lawsuit possible
• Damages: Minimum €1,000 for harassment (§9 BGStG)
⚠️This means: Even if your business is exempt from the BaFG as a micro-enterprise, missing alt text can be challenged as discrimination under the BGStG. In Austria, there is no safe harbor for inaccessible websites.
2. Who Is Affected in Austria?
Directly covered by the BaFG:
✓ Online shops (B2C) — Any store selling to end consumers
✓ Online booking systems — Hotels, vacation rentals, concert tickets, transit tickets
✓ E-banking & digital payment services — Online banking, crypto trading
✓ Online appointment booking — Even if the service itself isn’t covered (e.g. a hairdresser with online booking)
✓ E-commerce platforms — Marketplaces enabling consumer contracts
✓ Electronic communication services — Messengers, video calls
✓ Online donations — Nonprofits with online donation forms
Especially Important: Tourism, Healthcare & Services in Austria
Austria has a unique EAA angle: the BaFG explicitly covers “online appointment booking tools” — regardless of whether the underlying service falls under the BaFG. This affects a massive portion of the Austrian economy:
- Hotels & vacation rentals: Selling rooms directly via your own website (not just via Booking.com) triggers the BaFG. Alt text for room photos, restaurant images, spa facilities, and amenity shots is mandatory.
- Doctors & therapists: Online appointment booking via practice websites or tools like Doctolib → BaFG applies. Practice, team, and service images need alt text.
- Hairdressers, beauty & wellness: As soon as an online booking tool is embedded on the website, the BaFG applies — even for sole proprietors.
- Ski resorts & leisure providers: Online ticket sales for lift passes, admission, or events = electronic commerce = BaFG.
- Restaurants with online reservations: Online table booking (e.g. via Quandoo or own tool) is also covered.
- Bottom line: Due to the explicit mention of online booking, significantly more industries are affected in Austria than in Germany, where the interpretation for pure booking tools is less clear.
Exempt from BaFG (but NOT from BGStG!):
• Micro-enterprises for services — under 10 employees AND under €2M revenue/balance sheet
• Pure information websites — no transaction function (no shop, no booking, no ticketing)
• Pure B2B providers — only if exclusively targeting businesses
• Legacy content — published before Jun 28, 2025 and not modified since
3. What Exactly Is Required for Alt Text?
The BaFG references WCAG 2.1 Level AA via EN 301 549. For alt text, Success Criterion 1.1.1 “Non-text Content” applies. Requirements are identical across the EU:
✓ Every informative image needs a descriptive alt text (80-125 characters recommended)
✓ Every decorative image needs an empty alt attribute: alt=""
✓ Linked images describe the link target in the alt text
✓ Text in images (banners, infographics) must be reproduced in the alt text
✓ No image without alt attribute — a missing attribute is always a violation
✓ No “Image of…” at the start — screen readers announce this automatically
✓ No keyword stuffing — alt text must be natural and descriptive
The BaFG also requires an accessibility statement (§14(2) BaFG) published on your website: conformance status, known limitations, feedback contact, and date of last review.
→ Full guide: What Is Alt Text? 10 Rules + Examples
4. Fines & Consequences: BaFG vs. BGStG
In Austria, consequences come from two directions — both can apply simultaneously:
Path 1: Administrative Fines (BaFG)
The Sozialministeriumservice as market surveillance authority can impose fines scaled by company size:
Up to €80,000
Large enterprises
Up to €50,000
SMEs
Up to €25,000
Micro-enterprises
Additionally: sales bans and remediation orders with deadlines. Appeals go to the Federal Administrative Court.
Path 2: Mediation & Lawsuit (BGStG)
Affected individuals (e.g., blind online shoppers) can initiate mediation proceedings at the Sozialministeriumservice. If mediation fails, a civil lawsuit at district court is possible.
• Mediation: Free for the complainant, mediation-like process
• Damages: Minimum €1,000 for harassment (§9 BGStG)
• Injunctive relief: Court can order accessible design
• No company size exemption: Even sole proprietors are affected
→ Full EAA fine schedule for 12 EU countries
5. Market Surveillance: The Sozialministeriumservice
The designated market surveillance authority for the BaFG in Austria is the Sozialministeriumservice, specifically the Upper Austria regional office. Since June 28, 2025, this authority monitors compliance with accessibility requirements.
What the authority can audit and what you must be able to present:
📋 Technical documentation (§13 BaFG)
Description of the digital offering, applied standards, audit results. Must be created before market placement and retained for 10 years.
📢 Accessibility statement (§14(2) BaFG / Annex 3)
Publicly accessible on the website: scope, assessment basis (e.g. WCAG), measures, exceptions with justification, feedback contact, date.
✅ Conformity assessment (self-assessment)
Unlike CE products: a documented self-assessment suffices for services. No external audit required — but recommended.
Tip: AutoAlt.ai’s processing history (which images were given alt text, when, by which tool) serves as documented compliance evidence for your self-assessment.
6. The Mediation Procedure: Step by Step
The BGStG mediation procedure is Austria’s unique enforcement mechanism — free for complainants, no lawyer required, and low-threshold. Here’s how it works:
- A person with a disability discovers barriers on your website (e.g. missing alt text on product images). They file an informal mediation request. Cost for the complainant: €0. No lawyer needed.
- The Sozialministeriumservice contacts your business and invites you to a mediation session. Participation is voluntary — but refusing looks bad if the case later goes to court. The process is confidential.
- A mediator from the Sozialministeriumservice moderates the discussion. Goal: a mutual agreement — e.g. the business commits to adding alt text to all product images within 30 days. Typical duration: 1-3 sessions over 2-4 months.
- If agreed, a written settlement is signed. The business implements the measures. The procedure ends without costs and without public disclosure. This is the best outcome.
- If mediation fails, the complainant can file a civil lawsuit at district court within one year. Possible claims: injunctive relief (court orders accessibility), damages (material and immaterial), minimum €1,000 for harassment under §9 BGStG.
Important: BGStG mediation is a prerequisite for a lawsuit — you can’t sue directly without first attempting mediation. This gives businesses a chance to resolve issues affordably before they get expensive. Use this window: AI-generating alt text takes less time than a mediation appointment.
7. Austria vs. Germany: Key Differences
| Criterion | 🇦🇹 Austria (BaFG) | 🇩🇪 Germany (BFSG) |
|---|---|---|
| Law | BaFG (BGBl. I Nr. 76/2023) | BFSG |
| In effect since | June 28, 2025 | June 28, 2025 |
| Max. fine | €80,000 | €100,000 |
| Scaled by size? | Yes (€80k/€50k/€25k) | No (flat up to €100k) |
| Market surveillance | Sozialministeriumservice (OÖ) | MLBF (state authorities) |
| Additional equality law | BGStG (covers micro-enterprises!) | AGG (limited digital scope) |
| Mediation procedure | Yes, free for complainants | Not provided |
| Online booking covered? | Yes, explicitly named | Interpretation question |
| Transition period | Until Jun 27, 2030 | Until Jun 27, 2030 |
Takeaway: Austria is, in some aspects, stricter than Germany. The scaled fines are lower, but the BGStG as an additional layer means even micro-enterprises can be held accountable through disability discrimination law. Plus: online booking tools are explicitly covered — a major difference for tourism, healthcare, and services.
8. Alt Text Compliance Checklist for Austrian Shops
Check these 10 points to determine if your Austrian online shop meets the alt text requirement:
All product images (main + gallery + variations) have descriptive alt text with product name
Category images have alt text with category name
No image without alt attribute — decorative images have alt=""
Banners and promotional images with text → text reproduced in alt text
Hotel/room photos with descriptive alt text (room type, amenities, view)
Logo has alt text with company name
Alt text under 125 characters — short, natural, no keyword stuffing
Functional icons (cart, search, menu) have descriptive alt text or ARIA labels
Accessibility statement per §14 BaFG published in footer (Annex 3 BaFG)
Technical documentation per §13 BaFG created and retained for 10 years
Quick check: Chrome → F12 → Lighthouse → Accessibility. Or use the free AutoAlt.ai Accessibility Scanner.
9. Comply in 24 Hours: Step by Step
1
Assessment (30 min)
Chrome → F12 → Lighthouse → Accessibility. Scan your 10 most important pages. Count missing alt text. For most Austrian shops: 60-80% are missing.
2
Install AutoAlt.ai plugin (5 min)
Available for WordPress/WooCommerce, Shopware, Joomla, and Drupal. 50 credits/month free, EU servers, GDPR-compliant.
3
Start bulk generation (1-8 hrs)
Launch the bulk alt text generator for your entire media library. 1,000 images ≈ 30-60 minutes. Larger shops overnight.
4
Spot-check (30 min)
Review 20-30 generated alt texts. Edits cost no credits.
5
Publish accessibility statement per §14 BaFG (1 hr)
Create and publish an accessibility statement per Annex 3 BaFG in your footer. Required contents: scope, assessment basis, measures, exceptions, contact, date.
BaFG-compliant in minutes — for Austrian online shops
AutoAlt.ai generates alt text via AI — GDPR-compliant, EU servers, Made in Germany. Plugin for WordPress, WooCommerce, Shopware, Joomla, and Drupal. 50 credits/month permanently free.
10. Frequently Asked Questions
Is alt text legally required in Austria since 2025?
Yes. Since June 28, 2025, the BaFG requires all covered B2C businesses in Austria to make their digital offerings accessible per WCAG 2.1 Level AA. Alt text for all informative images is one of the most fundamental requirements. Additionally, the BGStG has prohibited digital discrimination since 2006.
What penalties exist for missing alt text in Austria?
BaFG administrative fines: up to €80,000 for large enterprises, €50,000 for SMEs, €25,000 for micro-enterprises. Via BGStG: affected individuals can initiate free mediation and subsequently sue for damages (minimum €1,000 for harassment).
Is my Austrian micro-enterprise affected?
Possibly exempt from the BaFG (under 10 employees AND under €2M revenue). BUT: the BGStG applies to all businesses! Digital barriers can be challenged through a free mediation procedure. In Austria, there is no safe harbor for inaccessible websites.
Does my Austrian hotel need an accessible website?
If your hotel sells rooms directly to guests via its own website (online booking), yes — the BaFG explicitly covers “online appointment/booking tools.” Alt text for room photos, restaurant images, amenities, and facilities is mandatory.
What is the mediation procedure?
A free mediation-like process under the BGStG. A person with a disability can file at the Sozialministeriumservice when discriminated by digital barriers. The procedure aims for a mutual resolution. If mediation fails, a civil lawsuit at district court is possible within one year.
Do I need an accessibility statement?
Yes, per §14(2) BaFG / Annex 3 BaFG. It must include: scope, assessment basis (e.g. WCAG 2.1), measures taken, exceptions with justification, feedback contact details, and date of last update. It must be publicly and accessibly available on your website.
How much does alt text compliance cost?
With AutoAlt.ai: 50 credits/month permanently free (= 50 images). For larger shops: Starter from €4.49/month (100 images) or Pro Pack €45 one-time (1,000 images). All languages and platforms included. A single BaFG administrative fine can cost €25,000-80,000.
Does the BaFG apply to third-party content?
Third-party content whose accessibility you cannot control (e.g. embedded YouTube videos or Google Maps) is exempt per §2(3) BaFG. However, these exceptions must be listed and justified in your accessibility statement. Your own images and content must still be accessible.
Meet Austria's BaFG Requirement — For Austrian Businesses
AutoAlt.ai generates alt text via AI — GDPR-compliant, EU servers. Plugin for WordPress, WooCommerce, Shopware, Joomla, and Drupal. 50 credits/month free.
50 credits/month forever free • No credit card • 2 min setup