European digital accessibility legislation


Scope and timeline

Directive EU 2016/2102 (updated by Decision EU 2018/2048 and Decision EU 2018/1523, and in combination with Standard EN 301 549 V2.1.2) requires that EU member states pass legislation to ensure that the digital services of public sector bodies comply with WCAG 2.1 Level AA standards. Enforcement starts on different dates for different types of content:

  1. For newer websites (published after 23 September 2018): from 23 September 2019 onwards.
  2. For older websites (published before 23 September 2018): from 23 September 2020 onwards.
  3. For mobile applications: from 23 June 2021 onwards.

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. The local laws often 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.
  • Etc.

Accessibility statements

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

  1. 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.
  2. A way to give accessibility feedback to the public sector body in charge of the digital service.
  3. A way to submit a complaint to the authorities, if the public sector body does not address feedback in a satisfactory manner.