Digital accessibility legislation

Accessibility in European legislation is directed with two documents – The Web Accessibility Directive (Directive EU 2016/2102)Opens in a new tab for public sector bodies and the European Accessibility Act (Act EU 2019/882)Opens in a new tab, which increases the reach of accessible public sector services and adds provisions for private sector bodies.

Directive EU 2016/2102

The Directive EU 2016/2102Opens in a new tab was passed on 26 October 2016, and it required EU member states to pass their respective local laws by 23 September 2018 to ensure that the digital services of public sector bodies comply with WCAG 2.1 (Web Content Accessibility Guidelines) Level AA standardsOpens in a new tab.

Enforcement of the act was started in September 2019 for new websites, in September 2020 for older websites, and in June 2021 for mobile applications.

Local laws differ slightly from the EU legislation. Since Wunder has offices in three countries, we have summarized some of them in the Finnish legislation, Estonian legislation, and Latvian legislation sections of this page.

Exceptions

Some digital services, as well as some types of content within them, are exempt from this directive. These exceptions are listed in the text of the directive itself (Article 1, points 3 and 4), and they include:

• Digital services of public service broadcasters.
• Digital services of NGOs that don’t provide services that are essential to the public.
• Office file formats published before 23 September 2018, if and only if they are not currently needed for active administrative processes.
• Online maps and mapping services intended for navigation if and only if essential information is provided in an accessible digital manner.

Accessibility statements

All digital services covered by this directive must contain an accessibility statement. The statement must include, at the very least:

• An explanation regarding the parts of the content (if any) that do not comply with the directive, as well as their justifications and any possible alternatives.
• A way to give accessibility feedback to the public sector body in charge of the digital service.
• A way to submit a complaint to the authorities if the public sector body does not address feedback in a satisfactory manner.

European Accessibility Act

Act EU 2019/882Opens in a new tab was passed in 2019 and will be enforced in member states from 28 June 2025 onwards.

While current European legislation only covers the digital services of public sector bodies, the new act will have a broader reach in both the public and private sectors.

The Accessibility Act provides common accessibility requirements at the EU level, ensuring that member states enforce these requirements for the products and services in question.

The Act aligns with existing EU laws concerning public procurement, Structural & Investment Funds, and transport by utilizing the same accessibility requirements as well as enabling products and services that meet accessibility requirements to circulate freely within the internal market.

Some of the products and services covered by this act include:

• Computers and operating systems
• ATMs, ticketing and check-in machines
• Smartphones
• TV equipment related to digital television services
• Telephony services and related equipment
• Access to audio-visual media services such as television broadcast and related consumer equipment
• Services related to air, bus, rail, and waterborne passenger transport
• Banking services
• E-books
• E-commerce

Microenterprises comprising ten or fewer employees or with annual turnover not exceeding two million euros are exempt.

It is important to note that while the Act will specify what needs to be accessible in terms of functional requirements, it will not dictate detailed technical solutions. This approach allows room for innovation and flexibility in achieving accessibility objectives.

Needless to say, this will result in an enormous demand for developing and upgrading the accessibility of digital services across the EU and beyond.

Resources

• Directive EU 2016/2102Opens in a new tab on EUR-Lex (2016)
• Act EU 2019/882Opens in a new tab on EUR-Lex (2019)
• Web AccessibilityOpens in a new tab on the European Commission website
• European Accessibility ActOpens in a new tab on the European Commission website
• How the new European Accessibility Act can benefit your business by Kati Vera

The Finnish implementation of Directive EU 2016/2102Opens in a new tab is called Act FI 306/2019Opens in a new tab. It is very similar to the European legislation, but a bit more specific in terms of scope.

In addition to applying to the digital services of public sector bodies, this act also applies to the digital services of:

1. Private bodies that are at least 50% funded by public bodies.
2. Public and private bodies providing electronic identification and payment systems.
3. Public and private bodies operating in the water, energy, transport, and postal services sectors.
4. Public and private bodies involved in financial investment, lending activities, and insurance providers targeting the general public.

Finnish implementation of the European Accessibility Act

Unlike some other European countries that have created separate legislation to implement the European Accessibility Act (Directive EU 2019/882Opens in a new tab), the Finnish Parliament has legislated several laws, which have been implemented as amendments to the Finnish Act on the Provision of Digital Services (Act FI 306/2019Opens in a new tab). These amendments were added to Finnish law between the end of January and the beginning of February 2023 and will be enforced starting 28th of June, 2025.

The various amendments include:

• Finlex 102/2023 (in Finnish)Opens in a new tab, Act on the accessibility requirements of some products. Adds amendments to regulate hardware used by consumers such as self-service payment terminals, and audiovisual devices like smart TVs, and e-readers.
• Finlex 103/2023 (In Finnish)Opens in a new tab, Act on amending Sections 1 and 4 of the Act on Market Control of Certain Products. This act amends the Finnish Transport and Communications Agency as the market surveillance authority for accessibility requirements for certain products.
• Finlex 104/2023 (In Finnish)Opens in a new tab, Act on amending the law on the provision of digital services. This act adds services to the Act on the Provision of Digital Services, including provisions for audiovisual content, e-commerce services, transport services, and other electronic communication services such as e-publications.
• Finlex 105/2023 (in Finnish)Opens in a new tab, Act on amending the law on electronic communication services. This act amends the Services that comply with the harmonized standards of Article 15 of Directive (EU) 2019/882 of the European Parliament. It includes provisions for the accessibility of internet connection devices, audiovisual content such as real-time captioning, TV guides, and more.
• Finlex 106/2023 (in Finnish)Opens in a new tab, Act on amending the law on emergency center operations. This act adds provisions to the Emergency Operations Act, such as more ways to 112, including via text messages or interactive methods such as synchronized speech or video.
• Finlex 179/2023 (In Finnish)Opens in a new tab, Decree of the Government about the accessibility requirements of some digital services. This legislation adds provisions to Act 306/2019, including provisions for accessibility statements, banking and financial services, and e-book content and reader functionality.

As with the EU legislation, micro-businesses with 10 or fewer employees are exempted.

Enforcement

1. Throughout Finland, the authority in charge of implementing this act is the Regional State Administrative Agency of Southern Finland.
2. For some products and services, the Finnish Transport and Communications Agency will possibly be the overseeing authority.
3. Public or private sector bodies that do not comply are subject to fines, as described in the Finnish Act on Conditional FinesOpens in a new tab.

Resources

• Act FI 306/2019 (in Finnish)Opens in a new tab on Finlex (2019)
• Regional State Administrative Agencies websiteOpens in a new tab
• Finnish Act on Conditional FinesOpens in a new tab on Finlex (1990)
• Accessibility Directive (In Finnish)Opens in a new tab Ministry of Social Affairs and Health

If you are interested in hearing in detail about how to enhance accessibility in a cost-effective manner, order a recording of our webinar (in Finnish) where the CEO of Annanpura and two experts from Wunder share their wisdom on this topic. By ordering the recording, you will also receive a link to presentation packed with links to useful tools and websites about the topic. 

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In Estonia, there are several legal documents that regulate the accessibility of digital services. Estonian Public Information ActOpens in a new tab, along with Regulation EE 2019/20Opens in a new tab refers to the public sector bodies, while the Products and Services Accessibility ActOpens in a new tab, along with Regulation EE 2022/45Opens in a new tab refers to both public and private sector bodies.

Public Information Act

The Estonian Public Information ActOpens in a new tab(EE – Avaliku teabe seadusOpens in a new tab) was enacted in January 2001, and even though the document was issued way before the Directive EU 2016/2102Opens in a new tab came into force, it has been updated to meet the requirements set by the European Union.

This Act aims to ensure that every person can access information intended for public use based on the principles of a democratic and social rule of law and an open society and to create opportunities for the public to monitor the performance of public duties.

Regulation EE 2019/20

The law “Website and mobile app accessibility requirements and procedures for the publication of accessibility information” (In Estonian “Veebilehe ja mobiilirakenduse ligipääsetavuse nõuded ning ligipääsetavust kirjeldava teabe avaldamise kord”) – Regulation EE 2019/20Opens in a new tab has been enforced since March 2019 and is based on the European Commission’s Implementing Regulation (EU) 2018/1523, which establishes a sample accessibility statement in accordance with Directive (EU) 2016/2102 of the European Parliament and of the Council and deals with the accessibility of websites and mobile applications of public sector institutions (OJ L 256/ 103, 12.10.2018).

The document defines key terms, principles, and technical specifications for designing, developing, managing, and updating websites and mobile applications in order to ensure they are perceivable, operable, understandable, and robust for users. It mandates that websites and mobile applications must ensure accessibility, irrespective of the user’s sensory capabilities.

Products and Services Accessibility Act

Products and Services Accessibility ActOpens in a new tab (in Estonian “Toodete ja teenuste ligipääsetavuse seadus”) is the Estonian implementation of the European Accessibility Act (EU Directive 2019/882Opens in a new tab). The Act was enacted in May 2022 and applies as of 28 June 2025 to products on the market and services provided.

This legal document governs accessibility requirements for a diverse range of products and services. To ensure conformity with the accessibility requirements while also specifying assessment procedures and penalties for non-compliance, the legal document defines the responsibilities of:

• Manufacturers
• Authorized representatives
• Importers
• Distributors
• Service providers

The act establishes a presumption of conformity for products and services meeting relevant standards and designates the Consumer Protection and Technical Regulatory Authority as the supervisory body.

Regulation EE 2022/45

The law “Functional accessibility requirements for products and services and requirements for information about them” (in Estonian: “Toote ja teenuse funktsionaalsed ligipääsetavusnõuded ja nõuded nende kohta antavale teabele”) – Regulation EE 2022/45Opens in a new tab – is a legal document which applies to public procurement, the object of which falls within the scope of the Act on Accessibility of Products and Services, and the intended user of which is a private person (not an enterprise).

This legislation focuses on ensuring accessibility of various products and services for individuals with disabilities, emphasizing clear information, usability, and adaptability for different needs and preferences. It aims to provide equal access to information and services for everyone, regardless of their abilities.

Resources

• Regulation EE 2019/20Opens in a new tab (in Estonian) on Riigi Teataja (2019)
• Estonian Public Information ActOpens in a new tab on Riigi Teataja (2000)
• Products and Services Accessibility ActOpens in a new tab, on Riigi Teataja (2022)
• Regulation EE 2022/45Opens in a new tab (in Estonian), on Riigi Teataja (2022)

In Latvia, there are two legal documents that regulate the accessibility of digital services – Regulation LV 2020/445Opens in a new tab for public sector bodies and the Act on Accessible Goods and ServicesOpens in a new tab for both public and private sector bodies.

Regulation LV 2020/445

Regulation LV 2020/445Opens in a new tab (LV – Ministru kabineta noteikumi Nr. 445 – Kārtība, kādā iestādes ievieto informāciju internetā) was enforced on July 2020 and is the Latvian implementation of Directive EU 2016/2102Opens in a new tab for public sector bodies. The document regulates the procedures and conditions for Latvian institutions to publish information on the Internet and ensure that information is made accessible to all individuals, regardless of their abilities or disabilities. It applies to all state and municipal institutions in Latvia, including ministries, agencies, and government bodies, as well as municipal administration institutions.

It is worth noting that the document does not cover content published by private individuals or businesses, nor does it extend to websites that are not affiliated with state or municipal institutions. However, it underscores the significance of ensuring accessibility in the context of information dissemination on the Internet.

Throughout all of Latvia, the authority in charge of implementing this regulation is the Latvian Ministry of Environmental Protection and Regional Development.

Act on Accessible Goods and Services

Act on Accessible Goods and ServicesOpens in a new tab (LV – Preču un pakalpojumu piekļūstamības likums) was enacted on March 2023 and will come into force on June 2025, and is the Latvian implementation of the European Accessibility Act (EAA, EU Directive 2019/882Opens in a new tab) for both public and private sector bodies. The document regulates rules and requirements regarding the accessibility of goods and services for persons with disabilities in Latvia.

This law establishes the obligations and standards that goods and service providers must adhere to in order to ensure accessibility for individuals with various functional limitations. It applies to various sectors, including public buildings, transportation, electronic communications, education, healthcare, cultural and sports events, as well as information and communication technologies.

The document includes requirements related to accessibility, such as architectural and construction solutions, information and communication devices, websites, and mobile applications. It also imposes obligations regarding the provision and preparation of information for individuals with different disabilities.

Exceptions

The law does not apply or apply partially if:

• the requirements of this law go way beyond the budget of the company (reach the disproportionate burden criteria),
• the modifications that are required for the product or service to be accessible lead to significant changes in the basic character of the product or service,
• the company employs less than 10 employees.

Enforcement

The supervision of this law is divided between several institutions, depending on the industry the product or service is provided to:

• The Public Utilities Commission (Sabiedrisko pakalpojumu regulēšanas komisija),
• The National Electronic Mass Media Council (Nacionālā elektronisko plašsaziņas līdzekļu padome – NEPLP),
• Civil Aviation Agency (Civilās aviācijas aģentūra),
• State Ltd. Road Transport Administration (VSIA Autotransporta direkcija),
• State Railway Administration (Valsts dzelzceļa administrācija),Consumer Rights Protection Centre (Patērētāju tiesību aizsardzības centrs),
• Municipalities.

Resources

• Regulation LV 2020/445 (in Latvian)Opens in a new tab on Likumi (2020)
• Act on Accessible Goods and Services (in Latvian)Opens in a new tab on Likumi (2023)
• Assessment of the website in accordance with the accessibility requirements of the digital environment (in Latvian)Opens in a new tab by the Latvian Ministry of Environmental Protection and Regional Development
• Website and mobile app accessibility (in Latvian)Opens in a new tab by the Latvian Ministry of Environmental Protection and Regional Development