Accessible websites and documents in municipalities: Austria's state laws compared

Why does the WZG not apply to municipalities?

The Web-Zugänglichkeits-Gesetz (WZG) does not cover municipalities, because it only obliges websites and mobile applications of the federal government and of certain federal bodies (§ 2(1) nos. 1 and 2 WZG). These are bodies established for the specific purpose of meeting needs in the general interest, not having an industrial or commercial character, that have at least partial legal capacity and that are financed for the most part by the federal government or by other such bodies, are subject to their supervision or have a majority of their governing bodies appointed by the federal government or by other such bodies (§ 2(1) no. 2(a) to (c) WZG). § 1(1) WZG, too, refers only to websites and mobile applications ‘of the federal government’ (des Bundes).

Directive (EU) 2016/2102 goes further. It expressly counts regional and local authorities (Gebietskörperschaften) among public sector bodies (Art. 3(1) Directive (EU) 2016/2102). In Austria, the federal states transpose this part: according to the FFG (Österreichische Forschungsförderungsgesellschaft), the WZG governs the federal level, while the state laws transpose the Directive at state level (FFG, Legal framework). For a municipality, the law of its own federal state is therefore decisive.

This article covers Austria only. German state laws are not part of the comparison.

Which state laws oblige municipalities? The eight reviewed laws compared

The reviewed state laws of Styria, Upper Austria, Vienna, Lower Austria, Vorarlberg, Burgenland, Tyrol and Carinthia expressly name municipalities as obliged bodies. In substance they follow the Directive closely: largely identical exemptions, a model statement, a feedback obligation and monitoring. They differ in deadlines, complaints bodies and the reference to standards. The comparison is based on the text in the RIS (Austria's federal legal information system) as consolidated on 19 October 2026.

Scope, legacy content and technical standard

In every state, the exemption for office files applies only if the content is not needed for active administrative procedures (Styria: active procedures). Archives are exempt if they are neither needed for active administrative procedures nor updated after 23 September 2019 (for example § 1(2) no. 8 StWZG, § 12(2) no. 8 NÖ ADG 2017).

Statement, deadlines, complaints and sanctions

Vienna additionally requires every body to designate a person or office for complaints and to state it, with contact details, in the accessibility statement. Before lodging a complaint, the user must first contact this person or office (§ 10a(5) Wiener ADG).

What applies in Salzburg?

For Salzburg, the legal position remains open in this comparison. The reviewed archive contains the Salzburger Gleichbehandlungsgesetz (RIS, as consolidated on 19 October 2026); it has no provision on websites or mobile applications. The FFG, by contrast, refers to nine state laws transposing the Directive and lists the Salzburger Teilhabegesetz for Salzburg (FFG, Legal framework). The text of this law was not available for the comparison.

Salzburg is nevertheless part of the monitoring: in the FFG interim report 2025, the state is represented with one in-depth and eleven simplified website checks and one app check; for Salzburg, no complaints about digital barriers were reported in 2025. Municipalities in Salzburg should check the text of the Teilhabegesetz in the RIS themselves.

What does the own sphere of competence mean for municipalities?

Six of the reviewed laws expressly assign the municipality's tasks to its own sphere of competence (eigener Wirkungsbereich). The web obligations themselves are addressed directly to the municipality as the responsible body, for example the statement and the response to reports of shortcomings (§ 12(1) and (5) NÖ ADG 2017).

• Lower Austria: Tasks that the municipality must carry out under the law fall within its own sphere of competence (§ 13 NÖ ADG 2017).
• Upper Austria: The tasks incumbent on the municipality under the law are tasks of its own sphere of competence (§ 19 Oö. ADG).
• Vorarlberg: The municipality's tasks governed by the law are tasks of its own sphere of competence (§ 17 Vbg. ADG).
• Burgenland: Municipalities and associations of municipalities carry out their tasks within their own sphere of competence (§ 63 Bgld. GADG).
• Tyrol: § 85(1) Tiroler GADG concerns Part 2 (2. Hauptstück). The web provision, § 76, is in Part 3; under § 85(2), its tasks belong to the own sphere of competence insofar as municipal bodies act within their own sphere of competence in tasks under § 61(1)(a). § 61(1)(a) covers sovereign administration in state matters and private-sector administration (Privatwirtschaftsverwaltung).
• Carinthia: own sphere of competence, unless § 74(2) and (3) K-LGlBG 2022 provide otherwise (§ 74(1)); these exceptions concern provisions other than §§ 46 to 49.

The StWZG and the Wiener ADG contain no corresponding provision. Several laws also oblige the responsible bodies to cooperate in monitoring (§ 5(1) StWZG, § 15b(4) Oö. ADG, § 10a(5) Vbg. ADG, § 49(1) K-LGlBG 2022). In Vorarlberg, the body concerned bears the stated costs of monitoring (§ 10a(6) Vbg. ADG).

Do municipalities face penalties? Complaints, recommendations and monitoring

No. None of the eight reviewed state laws attaches a penalty to breaches of the web provisions. The StWZG, Bgld. GADG, Tiroler GADG and K-LGlBG 2022 contain no penalty provision at all in the reviewed text. Lower Austria, Upper Austria, Vienna and Vorarlberg have penalty provisions that relate to other sections. For the federal level, the FFG states that neither the EU Directive nor the WZG provides for sanctions or penalties (FFG, Legal framework).

Instead of penalties, the laws provide for complaints bodies that receive and examine complaints; § 10a Vbg. ADG does not specifically name one. If a complaint is justified, the Styrian body issues recommendations for action and proposes measures (§ 6(1) StWZG). In Carinthia, the equal treatment office issues recommendations where necessary (§ 49(3) K-LGlBG 2022). The same model applies at federal level (§ 5(1) no. 2 WZG). The Directive requires an adequate and effective enforcement procedure, for example via an ombudsman (Art. 9(1) Directive (EU) 2016/2102).

All eight reviewed state laws provide for recurring monitoring with a report every three years, for example by the state government (§ 5(1) StWZG, § 12(6) NÖ ADG 2017) or the anti-discrimination officer (§ 76(4) Tiroler GADG). The federal report incorporates the reports of the states (§ 5(1) no. 1 WZG); according to its own information, the FFG also collects the reports of the nine federal states (FFG, Legal framework). In the FFG monitoring 2025, 50% of the websites and apps checked belonged to the federal level, 30% to the states and 20% to the municipal level; 23 websites were checked in depth, 349 in simplified form and 16 apps in depth.

The findings for 2025 (FFG interim report): 64% of the websites and apps checked had a statement (2024: 57%), just under 70% of the statements had no current date, and 73% contained all mandatory content. No website checked in depth fully conformed with the WCAG criteria; on average, 18 WCAG criteria were not met per website checked in depth. In 2025, the federal complaints bodies handled 19 complaints about digital barriers, Carinthia three, Tyrol and Vienna one each, and the other states none. More on the methodology in the article How monitoring bodies check accessibility.

What applies to PDF and Office documents on the municipal website?

PDF and Office files on the website fall under the web obligations; the specific exemption for older office files shows this. Exempt are mainly older office files and archives under the conditions set out above; the other exemptions also apply, such as disproportionate burden. The StWZG defines files in office application formats as documents that are not primarily intended for use on the web and that are included in websites (§ 2 no. 3 StWZG). A municipal newsletter as a PDF or a municipal ordinance as a Word file is therefore covered in principle if it was published after 23 September 2018 or is needed for an active administrative procedure.

The laws set the technical standard via harmonised standards, via Art. 6 Directive (EU) 2016/2102 or via EN 301 549. None of the reviewed state laws mentions WCAG or PDF/UA. According to the FFG, EN 301 549 version 3.2.1 lists WCAG 2.1 at level AA plus some additional criteria (FFG, Legal framework). Details in the article PDF/UA, WCAG 2.1 and EN 301 549.

In its 2025 monitoring, the FFG lists PDF documents that are untagged or incorrectly tagged among the most common errors for WCAG success criterion 1.3.1 ‘Info and Relationships’; PDFs created from scans convey no structural information at all. In 52.5% of the statements surveyed, a disproportionate burden was claimed, often for YouTube videos without audio description and several times for PDFs that supposedly could not be published accessibly as standard (FFG interim report 2025). For this assessment, the laws name in particular the size, economic capacity and nature of the body, the estimated costs and benefits, and the frequency and duration of use (for example § 59(1) no. 10 Bgld. GADG); the assessment is the responsibility of the body concerned (§ 15b(1) no. 10 Oö. ADG). More in the article Disproportionate burden and in the guide to accessible PDFs.

What can a municipality do in practice?

Six steps structure a municipality's work: inventory, priorities, remediation, justification, statement and feedback.

1. Take stock. List websites, apps and downloadable documents with their publication dates. The date determines whether the exemptions apply for office files published before 23 September 2018 and for archives not updated after 23 September 2019.
2. Set priorities. Start with documents needed for active administrative procedures, because the legacy exemption does not apply to them. Then move on to all documents published since the cut-off date.
3. Remediate documents. Make sure the tag structure is correct, with headings, lists and tables; according to the FFG interim report 2025, untagged PDFs and scans are typical sources of errors.
4. Justify exemptions. Document your assessment if you rely on disproportionate burden. In Vienna, the statement must explain which requirements cannot be met and, where applicable, name accessible alternatives (§ 10a(3) Wiener ADG).
5. Publish and update the statement. Use the model statement under Art. 7 Directive (EU) 2016/2102, as all eight laws require, and give the date of the last review. According to the FFG, a review at least once a year is foreseen (FFG interim report 2025). Guidance on structure in the article Accessibility statement.
6. Organise feedback with a deadline. Decide who receives and examines reports and answers them within two months, in Burgenland within four weeks (§ 59(3) Bgld. GADG).

Compliance-Kit supports municipalities with step 3: we make PDF, Word and PowerPoint documents accessible. More at accessible document remediation.