--- title: "Does the EU accessibility law apply to our website?" description: "The Swedish accessibility law names the consumer services it covers. How to tell whether your website is one of them, and what applies if it is." url: https://torn.studio/en/insights/does-the-accessibility-law-apply-to-us locale: en published: 2026-09-29 --- # Does the EU accessibility law apply to our website? > **Short answer:** The law names the consumer services it covers: e-commerce, banking, electronic communications, passenger transport and e-books. A website outside that list falls outside the law. Companies under ten employees and €2 million in turnover are exempt from the service requirements. Where it applies, the standard is EN 301 549, which today means WCAG 2.1 level A and AA. Lag (2023:254) om vissa produkters och tjänsters tillgänglighet has been in force since 28 June 2025. It is the Swedish implementation of the EU Accessibility Act, and it applies to a named list of consumer services. The first question is therefore whether your website is on that list, and most companies can settle it in an afternoon. This article works through the list, the exemption for small companies, the standard that applies where the law bites, and what the Swedish regulator has done about it so far. ## Which websites does the law cover? Section 4 of the law names the services it covers when they are aimed at consumers: electronic communications, services giving access to audiovisual media, elements of passenger transport by bus, ship, aircraft or train, banking services for consumers, e-books, and e-commerce services. A website carrying none of those sits outside this law. E-commerce is the line most companies land on, and the definition in section 3 is tight: services provided at a distance, through websites and services for mobile devices, by electronic means and at a consumer's individual request, for the purpose of concluding a consumer contract. Three things have to hold at once. The visitor is a consumer. The transaction runs on the site. A contract is concluded there. A company site that describes services and collects enquiries through a form concludes no contract, and a wholesale portal selling to registered businesses has no consumer. [Post- och telestyrelsen](https://pts.se/digital-inkludering/lagen-om-vissa-produkters-och-tjansters-tillganglighet/vanliga-fragor-och-svar-om-tillganglighetslagen/), one of the law's five supervisory authorities and the one that covers e-commerce, draws the boundary tighter still. Its published assessment is that only the parts of a website belonging to the e-commerce service carry the requirements, and that each company makes that judgement itself — a judgement PTS says may be tested in supervision. Public bodies answer to a separate law, which has required accessible digital public services since 2019. ## Are we exempt because we are small? Section 10 exempts micro-enterprises from the requirements on services, and section 3 defines one as a company with fewer than ten employees and an annual turnover or balance sheet total of at most €2 million. Both conditions have to hold. The exemption reaches services. It leaves the product requirements in place. There is a second route out, and it costs paperwork. Under section 7 an accessibility requirement falls away where meeting it would change the fundamental character of the product or service, or impose a disproportionate burden on the economic operator. Section 8 attaches the price: the company documents its assessment, keeps it, and notifies the supervisory authority that it considers the exemption to apply. An assessment nobody wrote down is an assessment nobody can rely on. ## What does the law actually require? The requirement in the statute is written in terms of information, user interface and functional design. The detail sits in the harmonized European standard, EN 301 549 — follow it and you are presumed to meet the directive's requirements. PTS answers the WCAG question directly: meeting EN 301 549 means meeting WCAG levels A and AA, and the standard reaches past websites into software, documents and support services. Which version applies is a live question, and today's answer is the older one. EN 301 549 v4.1.1 was published in September 2026, moves the benchmark to WCAG 2.2, adds six success criteria and drops the obsolete 4.1.1 Parsing criterion. The European Commission has still to cite it in the Official Journal of the European Union, and section 9 of the law is what makes that matter: the presumption of conformity attaches to a harmonized standard whose reference has been published there, and to no other. So v3.2.1 and WCAG 2.1 level AA remain the reference for demonstrating compliance, and a supplier quoting WCAG 2.2 as today's legal requirement is ahead of the Official Journal. Automated testing is the point where most compliance claims are weaker than they look, and PTS says so about its own measurements. Automated tools catch technical defects and miss comprehensibility, language and information structure — the failures that affect the largest groups of users. ## How hard is Sweden enforcing this? Harder than the absence of headline fines suggests. PTS opened its first market surveillance of products on 23 October 2025, checking EU declarations of conformity and the accessibility of consumer information. On 3 March 2026 it announced 28 supervision cases against named Swedish e-commerce sites — among them ica.se, hm.com, apotea.se, systembolaget.se and ikea.com. The programme runs through 2025 and 2026, and which companies come next is still undecided. The regulator has also measured the state of things. Report PTS-ER-2026:7, published on 21 April 2026, measured 576 Swedish websites across nine sectors at two points during 2025. Up to 86 percent of public-sector sites carried defects capable of shutting users out, defects were consistently more numerous among private actors, and eight of the nine sectors improved between the April and October measurements. PTS states plainly that the real share of sites with barriers is likely higher, because the method is automated. ## What happens if a site fails? PTS investigates by contacting the company, checking documentation, running tests and analyzing user complaints. Where requirements are unmet it can issue an injunction to fix the defect and follow up on it, and it can decide a sanction charge. Section 39 sets the band at a minimum of 10,000 kronor and a maximum of 10 million kronor, fixed by the seriousness and scale of the breach. Minor cases carry no charge, a charge cannot be decided more than five years after the breach ended, and decisions are appealable to the administrative courts. One transitional rule buys time, and it is narrower than it is usually quoted. A service provider may keep providing services using products it lawfully used before the law came into force, and may run out contracts concluded before that date — in both cases until 27 June 2030 at the latest. A service launched today gets no transition. **Most of the five-year runway is the transitional window, and it covers only products and contracts that predate the law.** - **Law in force; services placed on the market must comply** — 4 months (28 June 2025) - **First market surveillance of products opens** — 4 months (23 October 2025) - **Twenty-eight e-commerce supervision cases opened** — 2 months (3 March 2026) - **PTS publishes its measurement of 576 Swedish websites** — 50 months (21 April 2026, and the transitional window closes on 27 June 2030) The Swedish accessibility calendar, as published by the Riksdag and PTS. Each bar spans the months from its own event to the next one. Source: [Lag (2023:254) — Sveriges riksdag](https://www.riksdagen.se/sv/dokument-och-lagar/dokument/svensk-forfattningssamling/lag-2023254-om-vissa-produkters-och-tjansters_sfs-2023-254/), [PTS — Så tillgängliga är svenska webbplatser](https://pts.se/nyheter-och-pressmeddelanden/pts-forsta-breda-matning-av-tillgangligheten-pa-svenska-webbplatser/) ## Where the work is cheapest Accessibility costs least as a property of the system that builds the pages. On this site every color pair is checked against WCAG AA at the design-token level, so a combination below 4.5:1 for body text cannot be expressed in a page at all. What that takes to set up is covered in [when a design system pays for itself](https://torn.studio/en/insights/when-a-design-system-pays-for-itself). The same logic holds for keyboard order, form labels and focus states: decided once in a component, or re-decided on every page for as long as the site lives. For a site that already exists, the sequence is short. Establish whether the law applies. Measure against EN 301 549 with a tool and a person. Fix by component, starting with whatever stands between a user and a completed purchase. The cost lands in the same place as the rest of a rebuild, which [what an AI-built website costs](https://torn.studio/en/insights/what-an-ai-built-website-costs) sets out line by line. **Read next** - [AI builders and agencies: what each one leaves you to do](https://torn.studio/en/insights/ai-website-builder-vs-agency) - [How code quality is held when AI writes most of it](https://torn.studio/en/insights/quality-when-ai-writes-the-code) - [Website development at Torn Studio](https://torn.studio/en/services/websites) - [What a website costs at Torn Studio](https://torn.studio/en/pricing/websites) ## Common questions ### Does a company website with a contact form fall under the law? On its own, no. The law's definition of an e-commerce service requires a consumer contract to be concluded through the site. A page that describes services and collects enquiries concludes no contract, so it carries none of the service requirements in this law. Other obligations may still apply to it. ### We sell only to other businesses. Are we covered? The services in the law are covered when they are aimed at consumers, and the law defines a consumer as a natural person acting mainly outside a business. A portal that sells to registered companies has no consumer in that sense. Sites that serve both audiences are where the judgement gets difficult. ### Our company has eight employees. Is the exemption automatic? Two conditions have to hold together: fewer than ten employees, and an annual turnover or balance sheet total of at most €2 million. Both, or neither. The exemption also covers services only — a company that puts a product on the market meets the product requirements whatever its size. ### Is WCAG 2.2 the requirement now that EN 301 549 has been updated? The older version still governs. EN 301 549 v4.1.1 was published in September 2026 and moves the benchmark to WCAG 2.2, but the European Commission has still to cite it in the Official Journal. Until that happens, v3.2.1 and WCAG 2.1 level AA remain the reference for demonstrating compliance. ### Can an automated checker prove that we comply? It can prove that specific technical defects are absent, which is useful and much less than compliance. PTS says the same about its own measurements: automated tools find technical faults and miss comprehensibility, language and information structure, which affect the largest groups of users. ### What can PTS actually do if a site fails? It investigates by contacting the company, checking documentation, running tests and analyzing complaints. Where requirements are unmet it can issue an injunction to fix the defect and follow up on it, and it can decide a sanction charge between 10,000 and 10 million kronor. Decisions can be appealed to the administrative courts. ## Sources - [Lag (2023:254) om vissa produkters och tjänsters tillgänglighet](https://www.riksdagen.se/sv/dokument-och-lagar/dokument/svensk-forfattningssamling/lag-2023254-om-vissa-produkters-och-tjansters_sfs-2023-254/) — The statute itself. Evidence for the list of covered services in §4, the e-commerce definition and the micro-enterprise threshold in §3, the micro-enterprise exemption in §10, the presumption of conformity in §9, the exemptions in §§7–8, the sanction band of 10 000–10 000 000 kronor in §39, and the transitional rules running to 27 June 2030. - [Frågor och svar om tillgänglighetslagen — Post- och telestyrelsen](https://pts.se/digital-inkludering/lagen-om-vissa-produkters-och-tjansters-tillganglighet/vanliga-fragor-och-svar-om-tillganglighetslagen/) — Evidence that EN 301 549 requires WCAG levels A and AA, that PTS assesses only the e-commerce parts of a website as covered, that the micro-enterprise exemption reaches services while the product requirements stay in place, and for the limits of automated testing tools. - [PTS granskar ytterligare elva e-handelstjänsters tillgänglighet](https://pts.se/nyheter-och-pressmeddelanden/pts-granskar-ytterligare-11-e-handelstjansters-tillganglighet/) — Evidence for the 28 supervision cases against named Swedish e-commerce sites, announced 3 March 2026, and for the programme running through 2025 and 2026. - [PTS inleder marknadskontroll av laptops, smartphones och surfplattor](https://pts.se/nyheter-och-pressmeddelanden/pts-inleder-marknadskontroll/) — Evidence that the first market surveillance of products opened on 23 October 2025 and covered EU declarations of conformity and consumer information. - [PTS första breda mätning av tillgängligheten på svenska webbplatser](https://pts.se/nyheter-och-pressmeddelanden/pts-forsta-breda-matning-av-tillgangligheten-pa-svenska-webbplatser/) — Evidence for report PTS-ER-2026:7 of 21 April 2026: 576 websites measured across nine sectors, up to 86 percent of public-sector sites carrying defects, private actors consistently worse, and the limits PTS states for its own method. - [The European accessibility standard EN 301 549 has been updated — AccessibleEU](https://accessible-eu-centre.ec.europa.eu/content-corner/news/european-accessibility-standard-en-301-549-has-been-updated-2026-09-07_en) — Evidence that v4.1.1 was published in September 2026, adopts WCAG 2.2, adds six requirements, drops the 4.1.1 Parsing criterion, and is not yet cited in the Official Journal.