European digital accessibility legislation


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

Directive EU 2016/2102

The Directive EU 2016/2102 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 standards.

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 pages.


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 2019/882 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.