BehiG Revision: Status After the Autumn Session 2026

This article separates what is established from what is open: what does the Federal Council's draft say, where does Parliament stand, what applies to digital services today, and what is documented about the entry into force? The research is current as of October 23, 2026. The assessment may change with the decisions of the Council of States.

What applies to private providers today?

According to Pro Infirmis, the current BehiG protects people with disabilities in the private sector only against malicious and deliberate exclusion. In December 2024, the Federal Council chose not to keep this narrow standard in the partial revision (insieme Switzerland). According to the specialist sources we read, the current law does not require private companies to meet specific technical standards on their websites.

It is different for the federal government: in Article 14 paragraph 4, the draft expressly requires the federal administration and companies holding a federal concession to make their digital services accessible without aggravating conditions. This provision does not apply to private providers without a concession. The Digital Inclusion Alliance Switzerland describes what such a standard looks like at federal level: the Ordinance on the Elimination of Inequalities for Persons with Disabilities specifies the requirements for digital accessibility, and the eCH-0059 standard serves as practical guidance for implementation. These rules address the federal administration, not private companies, but they show the direction that technical rules for private providers could take later.

What does the Federal Council's draft provide?

The draft for the partial revision dates from December 20, 2024. According to the dispatch, work and services are to be improved, and for services in particular the services of private parties intended for the public, through an obligation to provide reasonable accommodations. The table summarizes the key articles and adds our assessment for digital services.

What the draft does not contain matters: it names neither a WCAG level nor a deadline for private providers. Technical requirements would only be set by a later ordinance of the Federal Council. This differs from the EU approach, in which Germany's Accessibility Strengthening Act sets out concrete requirements. The wording is the status of December 2024. The National Council's version was not available in full wording for this article and may differ.

What reasonable accommodations can mean in a shop

The draft defines a reasonable accommodation as a change or adjustment that is necessary and suitable in the specific case. For an online shop, this can be shown in a scenario that does not describe a real case: a customer with a visual impairment cannot operate the cart with her screen reader and reports this to the shop. As a substitute solution, the provider could temporarily accept the order by phone or email. In the long run, fixing the error in the shop itself would be the better answer. Exactly this balancing is provided for in Article 12a: a possible substitute solution, the number of users and the size of the company feed into the court's decision. A provider who reacts quickly and records what it did starts from a better position than one who leaves reports unanswered.

Where does Parliament stand?

The partial revision is now part of a larger package. According to Procap, the responsible committee of the National Council decided to include the BehiG reform in the counter-proposal to the Inclusion Initiative. ARTISET accordingly lists business 26.029 as the initiative and counter-proposal with BehiG and disability insurance law revisions. The Federal Office for Equality classifies the two bills as follows: the Inclusion Act is to provide an organizational and programmatic framework for implementing the UN Convention on the Rights of Persons with Disabilities, for example with a national strategy and independent monitoring. The BehiG, by contrast, contains concrete legal claims and measures against disadvantages, mainly in work and services (Federal Department of Home Affairs, February 25, 2026). For private providers, the BehiG revision is therefore the decisive part. The course of events so far:

• ✓ December 20, 2024: The Federal Council adopts the dispatch on the partial revision of the BehiG (Federal Office for Equality).
• ✓ March 2025: The committee of the National Council agrees to take up the bill without a dissenting vote (Foundation Access for All).
• ✓ February 25, 2026: The Federal Council adopts the dispatch on the indirect counter-proposal, the Inclusion Act, and rejects the initiative (Federal Department of Home Affairs).
• ✓ September 16 and 21, 2026: The National Council debates and adopts the Inclusion Act by 108 to 80 votes with 8 abstentions. It recommends rejecting the initiative by 97 to 78 votes with 21 abstentions (watson.ch).
• ✓ Next: The bill goes to the Council of States (sozialesicherheit.ch). The initiative committee names summer 2027 as the time frame for parliamentary treatment.

According to the sources we read, criticism from business focuses mainly on private employment relationships. The Swiss Employers' Confederation (September 22, 2026) considers the measures planned there to go too far and calls on the Council of States to make improvements. How the National Council worded Article 6 on services of private parties in detail does not emerge from the sources we read. That remains to be clarified before providers derive concrete obligations from it.

When will the revised BehiG apply?

No date is documented. Under the draft, the Federal Council determines when the law enters into force, and the law is subject to an optional referendum. The deliberation in the Council of States is still pending. Several provider websites name January 1, 2027 as the planned start, but no such date appears in the official sources we read. In our assessment, entry into force on that date is unlikely, because after the Council of States has deliberated, the referendum period and the bringing into force still follow.

The partial revision should not be confused with the Inclusion Act. The Federal Office for Equality writes that the Inclusion Act could enter into force in 2029 at the earliest. For the BehiG partial revision, it names no date. The technical details for digital services would also follow only after the law, in an ordinance.

What does this mean for websites and online shops in Switzerland?

There is no deadline, but there are good reasons to prepare. The draft relies on reasonable accommodations in individual cases, on an eased burden of proof and on organizational standing. Anyone who later wants to show that their measures were reasonable needs a verifiable assessment of the current state. In addition, the Federal Council is to base technical rules on harmonized national or international standards. In our assessment, WCAG 2.2 at level AA and the European standard EN 301 549 are the obvious points of reference. That is an assessment and not a requirement.

For Swiss providers with customers in the EU, the European Accessibility Act comes on top. Ireland's National Disability Authority writes that its requirements apply to any company trading in the EU, regardless of where it is based. Whether and to what extent your offering falls under it depends on the individual case and should be checked. How enforcement looks across Europe is described in our article One year of the European Accessibility Act: enforcement in Europe.

The comparison with Germany shows how different the two approaches are. The table sets the Federal Council's draft against the German BFSG.

How market surveillance works in Germany is summarized in the interim review of BFSG market surveillance. Nothing can be derived from it for Switzerland, but it shows how a law with a fixed deadline works in practice.

• ✓ Clarify the scope: Do you offer publicly accessible services, for example through a shop, a booking system or a customer portal?
• ✓ Take stock: Check your most important flows with the Livecheck and a keyboard walkthrough, and record the result with a date.
• ✓ Document proportionality: If a measure is not possible right away, note the reasons along the criteria of the draft, that is company size, number of users and a possible substitute solution. Review the criteria again once the legal text is final.
• ✓ Take inquiries seriously: Since reasonable accommodations are case specific, a fixed contact point that answers reports of barriers promptly helps.

SiteCockpit: keeping accessibility in view

As long as the legal text is not final, a verifiable and continuously updated check is the best starting point. Accessibility is not a one-off project but a process of checking, fixing and checking again.

• ✓ easyMonitoring: monitors your website continuously, finds errors such as invisible keyboard focus, weak contrast or missing form labels, and delivers prioritized to-dos.
• ✓ Manual audits: complement ongoing checks where flows such as ordering or booking have to be assessed from start to finish.
• ✓ easyStatement: creates an up-to-date accessibility statement based on real test results and thereby documents your status.

A dashboard with conformance scores shows whether the status of your website improves or worsens after changes. It does not replace a legal statement of conformity.

What makes sense now

No reason to panic, but real need to prepare: after the National Council, the BehiG revision is politically well advanced but not adopted. For private providers, a case-specific obligation to provide reasonable accommodations is emerging, which the Federal Council could later specify with technical requirements, and no entry into force is dated. Anyone who documents and checks systematically now is better placed under any conceivable version of the BehiG, including after a different deliberation in the Council of States.

• ✓ Establish your status: Start with the Livecheck and record the result.
• ✓ Fix the most common errors: Begin with contrast, keyboard use and forms in your most important flows.
• ✓ Keep it in view: Follow the deliberation in the Council of States and keep testing and documentation up to date.

Take it step by step. With easyMonitoring you keep track of your website after every change without having to set up each check from scratch.

Note: This article provides general information on the legal situation (as of 10/23/2026) and does not replace individual legal advice.