The European Accessibility Act: does it apply to your website?

The European Accessibility Act reached Sweden as lag (2023:254) om vissa produkters och tjänsters tillgänglighet, known there as tillgänglighetslagen or LPTT, and it has applied since 28 June 2025. Since then the Swedish Post and Telecom Authority (PTS) has opened 28 supervision cases against named online retailers, and the list carries names like ica.se, hm.com, ikea.com, coop.se, apotea.se and adlibris.com. This guide sets out which websites the law reaches, which parts of a site are covered, what PTS actually inspects, which exemptions are available and what it costs to leave the problems in place. It is built on the statute itself and on PTS’s own pages, all dated and linked at the foot of the page.

Does the law apply to your website?

Three questions decide it, and they are answered in order.

• Do you sell one of the services listed in Section 4? The list is closed: electronic communications services, services giving access to audiovisual media services, parts of passenger transport by bus, ship, aircraft or train, consumer banking services, the provision of e-books, and e-commerce services. A website that does nothing beyond presenting a company and taking contact inquiries appears nowhere on that list.
• Is the service aimed at consumers? Section 4 applies to those services when they are intended for consumers, so a service sold exclusively to other businesses generally falls outside. Legal form carries no weight: PTS is explicit that a non-profit association offering a service on the list is covered on the same terms as a limited company.
• Is the company larger than a micro-enterprise? Section 10 leaves services provided by micro-enterprises free of the accessibility requirements. The definition in Section 2 demands two things at once: fewer than ten employees, and an annual turnover or balance sheet total of at most €2 million. A company with six employees and €5 million in turnover is therefore no micro-enterprise. The threshold is set in euro, so a company reporting in kronor converts its own turnover before making the comparison.

Three yeses and the requirements apply, whenever the site was built. A single no and this particular law leaves you with nothing to fix. Write the assessment down and keep it, because it is your own to make and it can be tested in supervision.

Which parts of the site are covered

The most useful limitation in the whole regime sits here, and it is easy to miss. PTS assesses that the accessibility requirements for e-commerce services cover the parts of a website that belong to the e-commerce service. The reason the authority gives is that the law points at the services.

In practice the checkout, the product pages, the search function, the account login and the path between them sit inside the requirements, while a press room or a sustainability report on the same domain may sit outside them. PTS is equally clear on two points: each company draws the line itself, and the line can be tested in supervision. Where parts of a website fall under other accessibility requirements, those still apply.

The limitation makes the work plannable. A company with two thousand pages has no need to begin with all two thousand: the purchase flow is the part both the law and the supervision look at, and it is also the part where a defect costs the company an order in the same second it costs the visitor access. We build websites in that order from the start, because building the requirements in costs less than hunting them down afterwards.

What the requirements mean in practice

The law states functional requirements and points at no technical standard. Section 9 gives a presumption: a service that conforms to a harmonized standard is presumed to meet the accessibility requirements, to the extent those requirements follow from the standard. That is the practical route.

The standard is EN 301 549. Three things about it are worth having clear.

• WCAG is a subset of it. Meeting EN 301 549 means meeting WCAG level A and AA, and level AAA stays outside the requirement.
• The standard is broader than the web. EN 301 549 covers software, documents and hardware alongside web content, so a WCAG review covers one part of it.
• It is under revision right now. PTS states that the current version can be used as guidance until the revision is finished.

The four principles behind WCAG are the ones PTS works from in its review: a service has to be perceivable, operable, understandable and robust. Translated into a purchase flow, that means text that can be read and enlarged, everything reachable by keyboard, fields that say what went wrong, contrast that holds, and code a screen reader can make sense of. Alongside the service itself, Section 25 asks for information on how the service meets the requirements, and that information has to be accessible too.

What PTS inspects when a case opens

PTS is market surveillance authority for all the products the law covers and supervisory authority for three of the services: electronic communications services, banking services and e-commerce. A case runs in four steps that the authority describes itself: a request for information, a review of the service, a check of the information about how the service works, and an opportunity for the company to respond.

PTS announced on 15 October 2025 that the planned supervision of e-commerce had begun and was aimed at larger actors established in Sweden that sell products online. The review reached the websites and left the apps out, and it took in three parts of each website: the start page, one product page and the search function. On 3 March 2026 PTS opened eleven further cases and had 28 open supervision cases at that point, against ellos.se, biltema.se, kappahl.com, apotea.se, ahlens.se, mq.se, mathem.se, apotekethjartat.se, kronansapotek.se, hemkop.se, coop.se, systembolaget.se, stadium.se, hm.com, boozt.com, clasohlson.com, netonnet.se, ica.se, apoteket.se, lager157.com, apohem.se, xxl.se, jula.se, snusbolaget.se, willys.se, adlibris.com, lyco.se and ikea.com. The supervision runs through 2025 and 2026, cases are opened stepwise, and which companies it reaches later remains undecided.

Two things make the list less predictable than it looks. Supervision needs no plan behind it: anyone can complain to PTS about poor accessibility, anonymously if they prefer, and the authority uses those complaints when it plans its work. And PTS gives neither advance rulings nor individual advice, because it is the supervisory authority. The assessment of whether you are covered is yours to make.

The exemptions, and what they cost to use

Three exemptions exist, and they differ sharply in price.

Micro-enterprises, under Section 10. The cheapest of the three, because it applies on its own. Services provided by a micro-enterprise are free of the accessibility requirements, and a micro-enterprise handling products has no assessment to document and no authority to notify. Both conditions in Section 2 have to hold.

Disproportionate burden, under Sections 7 and 8. The most expensive one. The requirements fall away to the extent that they would demand a major change to the fundamental character of the product or the service, or impose a disproportionate burden on the company. Whoever invokes the exemption documents that assessment with a justification, keeps it, and notifies the supervisory authority that an exemption is being invoked. A copy goes in if the authority asks for one. An exemption is therefore a document that gets reviewed, and Section 33 lets the authority order a fresh assessment when it finds the old one wanting. Section 7 adds one limit to the ground: where the company has received external funds for the purpose of making that product or service more accessible, the requirements apply anyway, since an exemption should then not reasonably apply.

The transitional provisions. The law leaves out pre-recorded time-based media published before it took effect, document file formats from the same period, and content that counts as archive and has seen no update or edit since 28 June 2025. A service provider may also carry on using products that were lawfully in use before that date, at the latest until 27 June 2030, and may fulfill contracts concluded before it to the end of their term inside the same outer limit. That exemption covers products and contracts, so it does little for a site that is updated every week.

What leaving the problems in place costs

The ladder is written into the law and has four steps. Where the authority finds that a service falls short of the requirements, Section 32 has it first call on the responsible party to remedy the defect within a set time. Where that comes to nothing, the authority may decide whatever orders are needed, and Section 35 allows an order to carry a conditional fine. Alongside that, Section 37 lets the authority impose a sanction charge where a company has disregarded the duties in Sections 6 and 24–26 among others. Minor cases draw no charge, and a decision can come up to five years after the breach ended.

The amount is in Section 39: the sanction charge is set at no less than SEK 10,000 and no more than SEK 10,000,000, weighed against how serious and how extensive the breach is. Special reasons allow it to be reduced in whole or in part. It falls due within thirty days and goes to the state, and decisions under the law can be appealed to the general administrative court.

What a fix costs cannot be stated in general. The price turns on how much of the flow has to be rebuilt, and that is settled by how the site was built in the first place. Our own prices for websites show the range for a build and for a rebuild of an existing site.

What we can show is the cost of building the requirements in from the start. Accessibility is two build gates here. One test recomputes every permitted pair of text and surface straight out of the color file on every change and fails the build below WCAG AA — 29 checks, all of them passing on the last run. On 28 August 2026 we raised the floor for tap targets from 28 to 44 pixels, tested on every page type at nine widths.

Both cost something. Colors that look better than they measure stay out of production, every button and field grew, and the layouts in nine language versions had to be rebuilt in the same pass. That bill came once. A rebuild under a supervision case arrives with a deadline attached.

What this guide leaves unanswered

Four things are worth saying outright.

This guide rests on our reading of the statute and of PTS’s own pages, and it replaces no legal assessment of an individual case. It describes PTS’s remit — electronic communications, banking services and e-commerce — while other authorities supervise the remaining services in Section 4. The product requirements in Section 3, covering everything from payment terminals to e-readers, sit outside it. And it describes the position on 28 September 2026: EN 301 549 is under revision, the supervision is running, and PTS has published no order in the 28 cases. The dates and links below are where you check what has happened since.

The rules on transparency when you use AI in your own customer contact are a different question, with a different authority and a different date.