European Accessibility Act 2025 – what is it and who is affected by the new rules?

Who is affected by the new obligations

The new rules apply to a wide range of entities. The responsibility for ensuring accessibility lies with:

• manufacturers (individuals or companies producing products under their own brand),
• authorised representatives (acting on behalf of the manufacturer within the EU),
• importers (those bringing products from outside the EU or EFTA onto the EU market),
• distributors (individuals or companies selling products without being their manufacturers or importers),
• service providers (providing services to consumers in the EU).

Importantly, micro-enterprises are exempt from the obligation to adapt products and services to accessibility requirements under the Act. The new provisions apply to medium-sized and large companies, as well as public institutions, which offer products or services covered by the Act.

Which products and services must be accessible under the European Accessibility Act

Products that must be accessible:

• general-purpose computers and their operating systems
• payment terminals, ATMs, ticket machines and check-in kiosks
• terminal equipment for telecommunications and audiovisual services
• e-book readers

Services that must be accessible

• telecommunications services
• access to audiovisual media services
• retail banking services
• passenger transport services (road, air, rail, water)
• e-commerce services and the distribution of e-books

All of the above products and services must be accessible regardless of the user’s level of ability, which means that every consumer should be able to use them freely.

How does this work in practice?

In the case of products, accessibility means that the device has been equipped with features to make it easier for people with disabilities to use. For example:

• special raised markings on the keys so they can be felt by touch,
• the ability to connect headphones and use voice control (a text-to-speech system reads out on-screen commands),
• clear contrast and large text on the screen,
• controls adapted for people with limited mobility,
• instructions available in both audio and text formats.

In the case of services – for example, websites:

• the ability to use screen readers (blind people can ‘hear’ what is on the page),
• appropriate colour contrast and legible text,
• operation of all buttons and forms using only the keyboard (without a mouse),
• no sudden sounds that might startle people with hearing impairments.

Accessibility means that products and services must be designed in such a way that everyone – regardless of their ability – can use them easily and comfortably.

Accessibility checks and the consequences of inaccessible products and services

Anyone using a particular product or service can check whether accessibility regulations are being met. If they notice any issues, they have the right to report the lack of accessibility of the product or service.

Such a report should be addressed to the President of the State Fund for the Rehabilitation of Disabled Persons (PFRON), who may consider it independently or forward it to the relevant market surveillance authority for the sector in question. These authorities include, amongst others:

• the President of the Office of Electronic Communications
• the Minister responsible for digitalisation
• the President of the Railway Transport Office
• provincial road transport inspectors
• directors of maritime offices in the field of maritime transport and the Director of the Inland Waterways Office in Bydgoszcz in the field of inland waterway transport
• President of the Civil Aviation Authority
• Financial Ombudsman
• customs authorities.

The consumer also has the option of lodging a complaint directly with the trader, specifying which product or service fails to meet accessibility requirements and what requirements should be met. Ultimately, the consumer may seek redress through the courts.

If an inspection is initiated by an authorised institution, the trader will first be required to carry out an assessment of the product’s or service’s compliance with accessibility requirements. If they do so incorrectly or fail to carry out such an assessment at all, they will be required to do so within a period of not less than 60 days. In the event of continued inaction, administrative proceedings will commence.

If, as a result of the proceedings, it is found that the product or service does not meet accessibility requirements, the business operator is required to ensure the product or service complies with the requirements, or to withdraw the product from the market – they have 120 days to do so. Additionally, the supervisory authority may prohibit the continued provision of the product or service for a period not exceeding 180 days.

Failure to meet accessibility requirements may result in a financial penalty being imposed on the company. The amount of the penalty depends on the extent of the breach of regulations, the number of products or services affected, and the number of people affected. The penalty may not exceed 10 times the average wage or 10% of the company’s turnover for the previous year.

Author

Adrianna Bracichowicz

Associate

Adrianna Bracichowicz is a dedicated lawyer at our firm, specializing in business law and also in litigation law. She graduated with a master's degree from the University of Wroclaw, and also developed her skills while studying at the University of Bergen in Norway under the Erasmus+ program. She is currently continuing her legal education by completing the first year of her lawyer's apprenticeship.

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