Since 1 January 2025, companies with more than 400 employees have been obliged to appoint an accessibility officer. As it is often challenging in practice to find suitable people for this role, many companies are discussing whether persons with disabilities (Section 22a BEinStG) can also take on this task.
A current individual enquiry response from the Ministry of Social Affairs dated 24 January 2025 now officially confirms that it is generally permissible for persons with disabilities to also take on the voluntary role of accessibility officer.
Important framework conditions for the dual function
The appointment can only be made with the consent of the person concerned.
The additional workload must be taken into account.
There are no special reporting requirements or official authorisations for this dual function.
Tasks of the accessibility officer
The main task is to promote comprehensive accessibility. This includes
- Pointing out grievances
- Development of suggestions for improvement
- Cooperation with the responsible internal and external bodies to implement accessibility
However, the ultimate responsibility for ensuring accessibility remains with the company. In addition, the prohibition of discrimination under the Disability Employment Act (BEinStG) also covers discrimination due to architectural or structural barriers, such as non-accessible toilet facilities.
The option of assigning this additional function to persons with disabilities offers companies a pragmatic solution for ensuring accessibility without additional bureaucratic hurdles.
Created: 04.02.2025
Source: Kraft & Kronberger specialised publications
Picture: Marcus Aurelius
