The European Accessibility Act has applied in Sweden since 28 June 2025, through the Act (2023:254) on the accessibility of certain products and services. If you sell to consumers through a website or app, it has to be usable by people with disabilities, unless your company is a micro-enterprise. In practice that means meeting WCAG 2.1 level AA and being able to show how your service meets the requirements.
This article is an overview, not legal advice. If you are unsure whether your company is covered, talk to a lawyer or read the official guidance linked below.
What is the European Accessibility Act?
Its formal name is Directive (EU) 2019/882, and its purpose is to set the same accessibility requirements for certain products and services across the EU. Sweden implemented it in Act (2023:254), often called the accessibility act or LPTT in Swedish.
Do not confuse it with the Swedish DOS Act, which covers the public sector and requires an accessibility statement (tillgänglighetsredogörelse). The European Accessibility Act is aimed at private companies offering certain services and products to consumers.
Who is covered?
The Act lists the services in scope. For most businesses the relevant category is e-commerce services, which the Act defines as services provided at a distance, through websites or mobile apps, at the individual request of a consumer with a view to concluding a consumer contract. That covers more than classic online shops: booking and buying services online counts too.
Micro-enterprises providing services are exempt. Under the Act, a micro-enterprise has fewer than ten employees and an annual turnover or annual balance sheet total not exceeding EUR 2 million.
| Situation | Covered? |
|---|---|
| Online shop selling to consumers, 10 or more employees | Yes |
| Online shop selling to consumers, fewer than 10 employees and no more than EUR 2 million in turnover or balance sheet total | No, micro-enterprise exemption |
| Online booking where the consumer enters a contract on the site | Yes, unless a micro-enterprise |
| Consumer banking, e-books, passenger transport ticketing and information | Yes |
| Purely informational site with no purchase or contract | Normally not as an e-commerce service |
| Selling only to other businesses (B2B) | Normally not, the definition refers to consumer contracts |
The table is simplified. Check borderline cases against the official guidance or with a lawyer.
Which authority supervises what?
Under Ordinance (2023:676) supervision is split:
- The Swedish Post and Telecom Authority (PTS) supervises e-commerce, consumer banking and electronic communications services, and is the market surveillance authority for products.
- The Swedish Agency for the Media (Mediemyndigheten) supervises services giving access to audiovisual media services.
- The Swedish Agency for Accessible Media (MTM) supervises e-books.
- The Swedish Consumer Agency (Konsumentverket) and the Swedish Transport Agency (Transportstyrelsen) share supervision of passenger transport services.
The authorities can order a company to fix shortcomings, and the Act allows a penalty fee of at least SEK 10,000 and at most SEK 10 million, depending on how serious and extensive the breach is.
There are transitional rules running until 27 June 2030, but they mainly concern products already used to provide the service and contracts entered into before 28 June 2025. Do not assume they give your online shop a general grace period.
What does “accessible” mean in practice?
According to PTS, services must be perceivable, operable, understandable and robust. If you follow a harmonised standard, you are presumed to meet the requirements. The standard used as the reference today is EN 301 549, which for web content builds on WCAG 2.1 level AA. A new version based on WCAG 2.2 is on its way, so if you are building something new, aim for WCAG 2.2 now.
A practical checklist
- Contrast. Normal text needs a contrast ratio of at least 4.5:1 against its background, large text at least 3:1.
- Keyboard. Everything must work without a mouse, all the way through checkout.
- Visible focus. Keyboard users must always be able to see where they are on the page.
- Alt text. Images that carry information need descriptive alt text. Decorative images should have empty alt text.
- Forms. Every field needs a proper label, and error messages should say what is wrong and how to fix it.
- Captions. Pre-recorded video with sound needs captions.
- Zoom. The page must still work when text is enlarged to 200 percent, without content disappearing.
- Clear language. Short sentences, meaningful headings and buttons that say what happens next.
Automated tools catch some issues. The rest needs a person testing with a keyboard and a screen reader.
Information about your service’s accessibility
You must prepare information on how your service meets the accessibility requirements. According to PTS guidance, it belongs in the service’s general terms and conditions or an equivalent document, should describe the service and how it works, and must be kept for as long as the service is offered.
This is not the public sector’s accessibility statement under the DOS Act. What matters is that the information is accurate, easy to find and itself readable by everyone.
Why it pays off beyond compliance
Much of what makes a site accessible also makes it easier for everyone to use, and easier for search engines and AI assistants to interpret:
- Clear structure. Real headings and descriptive links help screen readers and search engines understand your content. The same qualities make you easier to cite in AI search.
- Alt text. Google uses alt text to understand what an image shows.
- Fewer drop-offs. A form that is easy to fill in and a clear error message at checkout lose fewer customers, whether they have a disability or not.
Accessibility is also not something you tick off once. Every new product page, campaign and checkout change can introduce new issues, so it needs to be part of the ongoing work on your website.
Frequently asked questions
Does the European Accessibility Act apply to my small online shop?
Not if your company is a micro-enterprise, meaning fewer than ten employees and no more than EUR 2 million in annual turnover or balance sheet total. Once you grow past that, the requirements apply.
Is an accessibility plugin or overlay enough?
No. A tool layered on top of the page does not change how the underlying code works. Accessibility has to be built into the site itself and tested.
What happens if I don’t comply?
The supervising authority can first ask you to fix the shortcomings within a set time. If they are not fixed, it can lead to an order or a penalty fee.
Do I need an accessibility statement?
The accessibility statement requirement comes from the DOS Act and applies to the public sector. If you are covered by the European Accessibility Act, you instead need information about your service’s accessibility, for example in your terms and conditions.
How Almano helps
We build and run websites and e-commerce for companies in the Nordics and the rest of the EU, working in a monthly cycle: build, measure, learn, improve. That makes it easier to keep accessibility in place as your site changes, instead of fixing everything after the fact. Read more about our services.
If you want to go through what the law means for your website, book a free call.
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