and the Supply of Goods and Services. Despite these achievements, as determined by the Commission, the European legal framework in respect of protection against discrimination is still incomplete. There are differences between types of discrimination within and outside of the area of employment. In the protection against discrimination, any ranking is inadmissible. Therefore, Austria must implement the minimum EU requirements on one hand and on the other, also work on the guarantee of a comprehensive protection against discrimination. International points of criticism The situation regarding protection against discrimination in Austria was recently analysed in three international reports: In 2010, by the European Commission against Racism and Intolerance; in 2011, within the scope of the Universal Periodic Review of the UN Human Rights Council and in 2012, by the Commissioner for Human Rights who was appointed by the Council of Europe. The main criticisms were aimed at the high degree of fragmentation of anti-discrimination legislation, the varied levels of protection for the respective groups, the many different institutions, inadequate building laws and building codes with regard to accessibility, insufficient entitlement to the removal of discriminating barriers, as well as long periods of transition for the implementation of accessibility in public buildings. It was also criticised that there were no possibilities for interpleader action in proceedings as were the framework conditions for financial assistance for children with special needs, especially with regard to schools, which were deemed inadequate. In particular gender discrimination, discrimination due to ethnic origin, age and religion were also viewed critically. It was recommended to institute higher compensation for damages in the case of injuries and to collect data relevant to cases of discrimination. AOB sees need for action regarding legislation Since autumn 2012, draft legislation has been under consideration for amendments to the Austrian Equal Treatment Act, the Equal Treatment Commission and Ombudsman Act, the Employment of Disabled Persons Act and the Federal Equal Opportunities for People with Disabilities Act. These amendments are intended to remedy existing inadequacies in legislation for protection against discrimination. Although the recommended changes are steps in the right direction, the AOB sees additional need for action in the current draft legislation and other regulations, similarly to, for example, the Litigation Association of NGOs against Discrimination or the Independent Monitoring Committee for the Implementation of the UN Convention on the Rights of Persons with Disabilities. 62