My co-blogger Don Torrez’ post, Virginia’s New IT Accessibility Law: What You Need to Know, inspired me to share the progress of accessibility legislation here in Sweden and throughout Europe. June 28 of 2025 brings an important change to European accessibility legislation as the European Accessibility Act (EAA) officially comes into force across all member states. Already in place, the Web Accessibility Directive (WAD) requires public sector websites and mobile applications to meet the standards defined in the EN 301 549 specification. With the new law, the private sector faces similar legal requirements.

Since 2016/2019: Web Accessibility Directive (WAD)

The Web Accessibility Directive, applying to public sector websites, e-services and mobile apps, was adopted in 2016, and then each member state implemented the directive through its own national legislation. For example, in Sweden, the directive was transposed into The Swedish Act on the Accessibility of Digital Public Services, which came into force in 2019. In Swedish the law is called Lagen om tillgänglighet till digital offentlig service or DOS-lagen.

The directive applies to websites, e-services and apps published by the public sector and requires:

• Compliance to EN 301 549, which includes but is not limited to WCAG 2.1 Level AA.
• Publication of an accessibility statement including:
  • The name of the responsible public sector organization.
  • Name of the website, e-service, or mobile application.
  • Whether the service is fully, partially, or not compliant with the requirements.
  • A list of inaccessible content and reasons for inaccessibility.
  • Alternatives offered for non-accessible content, if available.
  • Date when the service’s compliance was last assessed.
  • Date of the most recent update to the accessibility statement.
  • Evaluation method (e.g., internal or external review).
  • A way for users to give feedback or request accessible content.
  • Info about how to file a complaint with the national regulatory authority, including a link. For Sweden the authority is Digg, and the link should be: digg.se/tdosanmalan
  • Any exemptions claimed due to disproportionate burden, with justification.
  • Any excluded content, not covered by the law per Section 9.

Digg provides a template for accessibility statements, in Swedish and English, which can be found here: Skapa en tillgänglighetsredogörelse (Swedish)

From 2025: European Accessibility Act (EAA)

With the EAA, requirements are placed on private sector products and services aimed at consumers. Examples include:

• Smartphones, tablets, and computers
• ATMs, ticketing and check-in machines
• E-books and e-readers
• E-commerce websites and platforms
• Banking services
• Telecommunications services
• Transport services (airlines, trains, buses, etc.)
• TV equipment and digital TV services

These requirements aim to ensure that people with various disabilities can independently use essential technology and services in their daily lives.

Key dates

Although the directive was formally adopted in 2019, EU member states were required to transpose it into national law by June 28, 2022. The compliance deadline for affected businesses is June 28, 2025. From that date onward, relevant products and services placed on the EU market must meet accessibility criteria, with some transitional periods for products already in use.

Who is affected?

The EAA targets large and medium-sized private businesses operating within the EU. Microenterprises (i.e. businesses with fewer than 10 employees and under €2 million in annual turnover) are generally exempt from mandatory accessibility requirements. Business-to-business (B2B) products and services are also excluded.

Supervisory authorities

Each member state is required to appoint a supervisory authority that will monitor website appliance and have the possibility to impose fines for non-compliance. Typically, the task is split between different authorities. In Sweden the responsibility is shared as follows:

The Swedish Post and Telecom Authority (PTS) is the market surveillance authority for all products covered by the Accessibility Act (LPTT) and supervises certain services, including electronic communications, banking, and e-commerce.

The Swedish Media Authority oversees services that provide access to audiovisual media, such as websites, apps, and electronic program guides.

The Swedish Consumer Agency is responsible for parts of passenger transport services, including websites, apps, and electronic tickets.

The Swedish Transport Agency supervises travel information and services delivered via interactive self-service terminals.

The Swedish Agency for Accessible Media (MTM) is responsible for the supervision of e-books.

Requirements

Under the EAA, affected products and services must comply with the EN 301 549 standard. This standard includes criteria for hardware, software, documentation, support services, and more. For websites, requirements include but are not limited to WCAG 2.1 Level AA .

Unlike the Web Accessibility Directive (WAD), the EAA does not require the publication of an accessibility statement. However, providing such a statement can still be a valuable tool for transparency, compliance documentation, and user trust.

Requirements of EN 301 549 that go beyond WCAG

Although public sector websites and apps have been required to comply with EN 301 549 for several years under the Web Accessibility Directive, many parts of the specification remain difficult to interpret.

While WCAG is accompanied by extensive documentation, EN 301 549 is a technical specification that lacks interpretative support. It does incorporate WCAG 2.1 as its baseline for web content accessibility, but it also extends beyond WCAG in several important ways, particularly when considering interactive systems, non-web documents, and hardware-related technologies.

I personally took part in a workshop and conference held in Helsinki in February 2025, and I attended the online versions of the following sessions in Brno. These events, as well as other webinars and discussions with colleagues, have made it clear that even the most seasoned accessibility experts are struggling with understanding the requirements.

Some examples of requirements relevant to websites that are found in EN 301 549 but are not not explicitly addressed by WCAG include:

• Support for user preferences, such as respecting the system setting for dark mode.
• Accessibility of downloadable non-web documents, such as PDF files or Word documents.
• Accessibility of real-time communication services.
• Accessibility of accompanying documentation or help functions.
• Accessibility of authentication methods, such as requiring alternatives to biometric authentication.

There are many more, which may or may not be relevant to a specific web site. IAAP Nordic has listed 64 requirements that go beyond WCAG: visit EN 301 549 requirements that go beyond WCAG and you will find a link to the requirements in a document they have provided.