Arckit At Barrierefreiheit

⚠️ Community-contributed command — not part of the officially-maintained ArcKit baseline. Output should be reviewed by a qualified accessibility practitioner and Rechtsabteilung before reliance. Citations to BaFG / WZG / EN 301 549 may lag the current text — verify against RIS. Items marked [NEEDS VERIFICATION] must be confirmed before external use.

You are helping an enterprise architect generate an Austrian Accessibility Assessment. Austria transposed the EU accessibility regime along two separate tracks, and which one applies is a question about the entity, not about the technology:

• 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 economic actors: 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 and bodies governed by public law 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. Determine applicability first, then assess only the tracks that apply.

Not this command's job. $arckit-at-bvergg already covers accessibility as a procurement clause (§107 BVergG). This command assesses the entity's own products, services, websites and apps. If you are writing a tender, run $arckit-at-bvergg.

User Input

$ARGUMENTS

Instructions

Note: Before generating, scan projects/ for existing project directories. For each project, list all ARC-*.md artifacts, check external/ for reference documents, and check 000-global/ for cross-project policies. If no external docs exist but they would improve output, ask the user.

Step 0: Read existing artifacts from the project context

MANDATORY (warn if missing):

• REQ (Requirements) — Extract: NFR-UX / accessibility requirements, user-facing functional scope (FR-xxx), channels and interfaces
  • If missing: warn that conformance cannot be scoped without knowing which surfaces exist. Proceed only on the description in $ARGUMENTS.

RECOMMENDED (read if available, note if missing):

• STKE (Stakeholder Analysis) — Extract: user groups, assistive-technology users, disability representation, whether users are consumers (BaFG) or citizens accessing a public service (WZG)
• DIAG / HLD — Extract: the actual user-facing surfaces — web, native mobile, kiosk, terminal, documents, e-books

OPTIONAL (read if available, skip silently):

• BVERGG (AT Procurement) — Extract: any accessibility clause already imposed on a supplier, so the assessment and the contract agree
• RISK (Risk Register) — Extract: existing accessibility, reputational or enforcement risks for cross-reference
• SOBC — Extract: entity size, turnover and headcount, which drive the BaFG microenterprise exemption

Step 0b: Read external documents and policies

• Read any external documents in external/ — extract any existing Barrierefreiheitserklärung, prior accessibility audit or VPAT, assistive-technology test reports, SMS or FFG correspondence, and user complaints about barriers
• Read any global policies in 000-global/policies/ — extract accessibility policy, design-system conformance statements, content style guides
• If a prior accessibility statement or audit is found, use it to pre-populate conformance status and to identify what has drifted since.

Step 1: Identify or Create Project

Identify the target project from the hook context. If the project doesn't exist, create it with .arckit/../arckit-claude/scripts/bash/create-project.sh --json --name "<project-name>" — the --name is required, and without it the script exits 1 rather than returning a path.

Step 2: Read Source Artifacts

Read the artifacts identified in Step 0 in full. Extract every user-facing surface into an inventory — this inventory is the unit of assessment for the rest of the command.

Step 3: Template Reading

Read .arckit/templates-custom/at-barrierefreiheit-template.md if it exists, otherwise .arckit/templates/at-barrierefreiheit-template.md.

Step 4: Generate the Austrian Accessibility Assessment

1. Detect version: Check for existing ARC-{PROJECT_ID}-ATBFR-v*.md files. Increment the minor version if one exists; otherwise start at v1.0.

2. Auto-populate Document Control: resolve the <!-- DOC-CONTROL-HEADER --> marker per .arckit/templates/_partials/RENDERING.md.

   • Classification: Offen once the accessibility statement is published, Eingeschränkt while non-conformances are open, since the gap list is an unremediated to-do list.

3. Section 1: Applicability Determination — do this first; it gates sections 3 and 4.

   Decide each track independently and record the reasoning, not just the verdict.

   • WZG applies if the entity is a federal public body, a body governed by public law, or a body predominantly publicly funded, and the surface is a website or mobile application. The federal WZG does not reach Land-level bodies — the Länder legislate separately, so a Land or municipal body is assessed against its Landesgesetz, not this act. Name the applicable Landesgesetz if the entity is a Land body [NEEDS VERIFICATION: confirm the applicable Landesgesetz and its current text].
   • BaFG applies if the entity is a manufacturer, importer, distributor or service provider and the product or service is in Annex scope. In-scope products include general-purpose computer hardware and operating systems, self-service terminals (payment terminals, ATMs, ticketing and check-in machines, information kiosks), consumer terminal equipment for electronic communications, terminals for audiovisual media services, and e-readers. In-scope services include electronic communications services, audiovisual media services, elements of air/bus/rail/waterborne passenger transport services, consumer banking services, e-books and dedicated software, and e-commerce services.
   • Microenterprise exemption (BaFG only, and services only). A Kleinstunternehmen — fewer than 10 persons employed and annual turnover of at most EUR 2M or balance-sheet total of at most EUR 2M — is exempt from the accessibility requirements for services it offers or provides (§ 6, definition at § 3 Z 19) [NEEDS VERIFICATION: confirm both § numbers against RIS]. Products are not exempt: a nine-person importer of self-service terminals is fully in scope. State explicitly which limb of the test each criterion meets, and record the headcount and financial figures relied on — the Sozialministeriumservice can require an entity claiming the exemption to produce that evidence on request. An exemption asserted without evidence in the file is a finding, not a pass.
   • If neither track applies, say so with the reasoning and stop the substantive assessment there — still produce sections 5 and 6 covering why, and any voluntary conformance target the entity has adopted.

4. Section 2: Standard and Conformance Mapping — shared across both tracks; write it once.

   • Both tracks route through EN 301 549 as the harmonised standard giving a presumption of conformity. The version that binds is the one cited in the Official Journal: today v3.2.1, which normatively references WCAG 2.1 Level AA.
   • Draft v4.1.0 went out for 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: confirm the OJ citation date and version]. Assess against 2.1 AA. Name 2.2 AA only as a forward-looking target where the product or contract lifetime runs past that citation, and mark it as a deliberate choice rather than the legal floor.
   • Produce a per-criterion conformance table for WCAG 2.1 AA (Supports / Partially Supports / Does Not Support / Not Applicable), each row carrying the evidence: which surface, which test method, which date.
   • Record the test method honestly — automated scan alone is not conformance evidence. Distinguish automated tooling, manual expert review, and assistive-technology testing with real users.
   • EN 301 549 covers more than the web. Where the inventory includes hardware, terminals, documents or e-books, assess the non-web clauses too and say which ones.

5. Section 3: Barrierefreiheitserklärung (WZG track — mark N/A with reason if WZG does not apply)

   The accessibility statement is a statutory deliverable, not a courtesy page. Required content:

   • Conformance status in the statutory wording: vollständig konform, teilweise konform, or nicht konform with EN 301 549 / WCAG 2.1 AA.
   • Non-accessible content, split into the three categories the Directive requires: content incompatible with the accessibility requirements, content excluded as a disproportionate burden (unverhältnismäßige Belastung, with the assessment that justifies it), and content outside the scope of the legislation.
   • Preparation method and date — self-assessment or third-party evaluation, with the date, and a commitment to keep the statement current.
   • Feedback mechanism — a working contact channel through which a user can report a barrier or request content in an accessible form, with the response commitment.
   • Enforcement pointer — where a complaint goes if the feedback mechanism does not resolve it: the FFG (Österreichische Forschungsförderungsgesellschaft), which handles WZG monitoring and complaints.

   Assess the existing statement against this list where one exists, and flag a statement that recites conformance without listing known non-conformances — that is the most common failure and it is visible to any auditor who runs a scan.

6. Section 4: Product and Service Requirements (BaFG track — mark N/A with reason if BaFG does not apply)

   • Map each in-scope product or service to the applicable BaFG accessibility requirements, including the information obligations (accessible instructions, and a description of how the service meets the requirements published with the service).
   • Conformity assessment and declaration: for products, the economic actor draws up an EU declaration of conformity and affixes CE marking; the internal production-control route applies where the harmonised standard is used. For services, there is no CE marking — the obligation is the published description plus retained supporting documentation. Do not apply CE marking to a service.
   • Disproportionate burden and fundamental alteration are the two statutory defences. Both require a documented assessment retained on file, re-assessed when the product or service changes and periodically thereafter. An undocumented claim of burden is not a defence — record it as a gap.
   • Emergency communications (Notrufe) are transposed separately through the TKG 2021, not the BaFG. Flag it as out of scope here with a pointer, rather than assessing it under the wrong act.

7. Section 5: Market Surveillance, Monitoring and Exposure

   • BaFG — Sozialministeriumservice (SMS), the Bundesamt für Soziales und Behindertenwesen, is the market surveillance authority (§ 21) [NEEDS VERIFICATION]. It monitors proactively, can order remediation within a set period, and in serious cases can require a product's withdrawal from the market or prohibit a service. Administrative penalties reach EUR 80,000 (§ 36) [NEEDS VERIFICATION: confirm the § and the tier structure], tiered by severity and set lower for SMEs and microenterprises. Give the exposure as a range against the specific conduct, not a bare headline number.
   • WZG — FFG performs monitoring and handles complaints, and Austria reports to the European Commission on a triennial cycle. The WZG carries no administrative fine regime: the consequence is a finding, a complaint, and publication, not a penalty. State this plainly rather than importing the BaFG number into a public-sector assessment.
   • Where both tracks apply, keep the two exposures separate. They are different authorities with different powers over different surfaces.

8. Section 6: Gap Analysis and Remediation Roadmap

   • One row per non-conformance: surface, criterion, severity, user impact, owner, target date, and the track it arises under.
   • Prioritise by user impact first and enforcement exposure second. A blocked login path outranks a decorative contrast failure regardless of which act is in play.
   • Where remediation needs procurement, note the handoff to $arckit-at-bvergg so the conformance target lands in the Leistungsbeschreibung rather than being rediscovered at acceptance.
   • Cross-reference each engineering item to an NFR-UX requirement ID, creating them via $arckit-requirements if they do not exist.

Populate the External References section per .arckit/references/citation-instructions.md. BaFG (BGBl. I Nr. 76/2023), WZG (BGBl. I Nr. 59/2019), Directive (EU) 2019/882, Directive (EU) 2016/2102, EN 301 549 v3.2.1 and WCAG 2.1 MUST appear in the Document Register.

Before writing the file, read .arckit/references/quality-checklist.md and verify all Common Checks plus the ATBFR per-type checks pass.

Use the Write tool to save to:

projects/{project_id}/ARC-{PROJECT_ID}-ATBFR-v{VERSION}.md

Step 5: Summary Output

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✅ Austrian Accessibility Assessment Generated
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📄 Document: projects/{project_id}/ARC-{PROJECT_ID}-ATBFR-v{VERSION}.md
📋 Document ID: {document_id}
📅 Assessment Date: {date}
🔒 Classification: Offen (Eingeschränkt while gaps are open)

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📊 Applicability
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| Track | Applies | Basis |
|-------|---------|-------|
| WZG (public sector)  | {Yes / No / Land-level — see Landesgesetz} | {reason} |
| BaFG (products/services) | {Yes / No / Exempt — Kleinstunternehmen, services only} | {reason} |

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📊 Conformance (EN 301 549 v3.2.1 → WCAG 2.1 AA)
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| Result | Count |
|--------|-------|
| Supports | {N} |
| Partially Supports | {N} |
| Does Not Support | {N} |
| Not Applicable | {N} |

Test method: {automated / manual expert / assistive-technology}

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⚡ Critical Actions
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{List 🔴 High priority gaps}

Exposure: {BaFG: SMS, up to EUR 80,000, tiered | WZG: FFG monitoring and complaints, no fine regime | Both, assessed separately}

Next steps:
1. {If WZG applies and no statement exists: publish a Barrierefreiheitserklärung}
2. {If remediation will be procured: Run $arckit-at-bvergg}
3. {If gaps need engineering: Run $arckit-requirements to raise NFR-UX items}
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Important Notes

• Applicability is about the entity, not the technology. The same web application is assessed under the WZG for a federal ministry and under the BaFG for a bank. Decide the track before assessing anything, and support both where both apply.
• The microenterprise exemption covers services only. § 6 exempts Kleinstunternehmen offering or providing services; it does not exempt products. A nine-person importer of ticketing terminals is fully in scope. This is the single most common misreading of the BaFG.
• An exemption without evidence is a gap. The SMS can require an entity claiming the microenterprise exemption to produce the supporting headcount and financial evidence. Record the figures in the assessment.
• The federal WZG does not cover Land bodies. The Länder legislate separately. Route a Land or municipal body to its Landesgesetz rather than assessing it here.
• The WZG has no fines. Do not carry the BaFG's EUR 80,000 ceiling into a public-sector assessment. The consequence there is monitoring, complaint and publication.
• Assess against WCAG 2.1 AA. EN 301 549 v3.2.1 is the OJ-cited version and it is what carries the presumption of conformity. WCAG 2.2 AA arrives with v4.1.1, expected around October 2026 [NEEDS VERIFICATION]; specifying it earlier raises the bar above the legal floor and must be recorded as a deliberate decision. This matches $arckit-at-bvergg.
• Automated scanning is not conformance. A statement resting on a tool report alone is a finding. Record the test method for every criterion.
• Verify citations: BaFG paragraph numbers here are drawn from secondary sources because RIS was unavailable at authoring time. Confirm § 3 Z 19, § 6, § 21 and § 36 against RIS before external use.
• Use Write Tool: Accessibility assessments carrying a per-criterion table run 2,000–4,000 words. Always use the Write tool.

Success Criteria

• ✅ Assessment document created at projects/{project_id}/ARC-{PROJECT_ID}-ATBFR-v{VERSION}.md
• ✅ Applicability determined for both tracks independently, with reasoning recorded
• ✅ Microenterprise exemption applied to services only, never to products, with the headcount and financial evidence recorded
• ✅ Land-level bodies routed to the applicable Landesgesetz rather than assessed under the federal WZG
• ✅ Conformance assessed against EN 301 549 v3.2.1 / WCAG 2.1 AA, with WCAG 2.2 AA appearing only as an explicit forward-looking decision
• ✅ Per-criterion table carries evidence and test method, not just a verdict
• ✅ Barrierefreiheitserklärung assessed against all five required elements where WZG applies
• ✅ Conformity assessment route correct per type — CE marking for products, published description for services
• ✅ Disproportionate burden and fundamental alteration claims backed by a documented, retained assessment
• ✅ Emergency communications flagged as TKG 2021 rather than assessed under the BaFG
• ✅ SMS and FFG exposures stated separately and correctly, with no fine regime asserted under the WZG
• ✅ Gap analysis prioritised by user impact first, with owners, dates and NFR-UX cross-references
• ✅ Items requiring practitioner verification marked [NEEDS VERIFICATION]

Example Usage

$arckit-at-barrierefreiheit Accessibility assessment for 001 — federal ministry citizen portal and its companion mobile app

$arckit-at-barrierefreiheit Vienna fintech, 8 staff, EUR 1.4M turnover, consumer banking app plus a self-service card-issuing terminal in branches

$arckit-at-barrierefreiheit Assess both tracks for a public transport operator — passenger information website, ticketing app, and platform ticket machines

Suggested Next Steps

After completing this command, consider running:

• $arckit-at-bvergg -- Carry the accessibility conformance target into the tender's Leistungsbeschreibung and award criteria (when Remediation or the service itself will be procured)
• $arckit-requirements -- Raise the conformance gaps as NFR-UX requirements so they enter the delivery backlog (when Gap analysis produced non-conformances needing engineering work)
• $arckit-at-dsgvo -- Assess DSG obligations where the feedback mechanism collects personal data (when Feedback mechanism or complaints channel processes personal data)