Accessibility requirements for services apply from 28 June 2025.
The accessibility requirements for services arise from the Products and Services Accessibility Act, which transposes into Estonian law Directive (EU) 2019/882 of the European Parliament and of the Council on the accessibility requirements for products and services, also known as the European Accessibility Act (EAA).
Pursuant to subsection 4 of § 4 of the Products and Services Accessibility Act, Regulation No 45 of the Minister of Social Protection ‘Functional Accessibility Requirements for Products and Services and the Requirements for the Information Provided Concerning Such Requirements' (hereinafter the Accessibility Requirements Regulation) has been established. Pursuant to subsection 6 of § 5 of the Products and Services Accessibility Act, Regulation No 46 of the Minister of Social Protection ‘Criteria for the Assessment of Disproportionate Burden of Economic Operators and the Procedure for Notification of Non-application of Accessibility Requirements’ (hereinafter the Disproportionate Burden Regulation) has also been established.
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Accessibility requirements apply to service providers specified in the Products and Services Accessibility Act. Under the Act, a service provider means any natural or legal person who provides a service on the Union market or makes offers to provide a service to consumers in the Union (subsection 2 of § 3 of the Products and Services Accessibility Act).
The Products and Services Accessibility Act does not apply to microenterprises providing services. A microenterprise means an enterprise which employs fewer than ten persons and which has an annual turnover or an annual balance sheet total not exceeding two million euros (subsection 4 of § 3 of the Products and Services Accessibility Act).
Service contracts concluded before 28 June 2025 that do not comply with accessibility requirements, together with all related documents forming part of such contracts, may continue without alteration until they expire but no longer than until 28 June 2030 (subsection 2 of § 22 of the Products and Services Accessibility Act).
Services that rely on inaccessible products used before 28 June 2025 may continue to be provided using such products until 28 June 2030. After that date, the relevant services must be provided using accessible products (subsection 4 of § 22 of the Products and Services Accessibility Act).
Services that meet the following criteria are excluded from the scope of accessibility requirements, regardless of sector:
- pre-recorded time-based media published before 28 June 2025 (time-based media essentially refers to audio and video content, such as video clips);
- office file formats published before 28 June 2025 (essentially non-web documents, such as PDF files);
- website and mobile application content that is neither updated nor modified after 28 June 2025;
- online maps and mapping services; however, in the case of maps intended for navigation, essential information must be provided in an accessible digital format (for example, a written postal address and nearby public transport stops provided alongside a location map);
- third-party website and mobile application content that is neither funded nor controlled by the economic operator. Examples include content automatically embedded from external sources, such as dynamically displayed advertisements. However, such content must not hinder or reduce the functionality of the service provided.
Websites and mobile applications falling within the scope of the Products and Services Accessibility Act are based on the same principles and standards as those applicable to the public sector. This means that the accessibility requirements for private sector websites and mobile applications are likewise derived from the European digital accessibility standard EN 301 549 V3.2.1 (Recital 46 of the European Accessibility Act).
Section 10 of the Accessibility Requirements Regulation establishes two general requirements for the provision of services within the scope of the Products and Services Accessibility Act:
- If products falling within the scope of the Products and Services Accessibility Act are used in the provision of a service, those products must comply with the relevant accessibility requirements established by the Act.
- Websites and mobile applications through which services within the scope of the Products and Services Accessibility Act are provided must be perceivable, operable, understandable and robust.
These widely recognised principles form the basis for specific requirements in several international digital accessibility standards and are used in multiple legal instruments. Perceivable, Operable, Understandable and Robust (also known by the acronym POUR) are the four core principles of digital accessibility. Brief explanations of these principles are provided below.
- Perceivable – content can be perceived through different senses (such as sight, hearing or touch).
- Operable – content can be used in different ways (such as via keyboard navigation or user interface components).
- Understandable – information is understandable and the operation of the user interface is predictable.
- Robust – content is sufficiently robust to be compatible with assistive technologies.
E-commerce services fall within the scope of the Products and Services Accessibility Act pursuant to clause 1 of subsection 3 of § 2 and are defined in clause 1 of subsection 5 of § 2 of the Act.
An e-commerce service is a service provided at a distance, through websites and mobile device-based services by electronic means and at the individual request of a consumer, for the purpose of concluding a consumer contract. Accessibility requirements apply to any online sale of products or services.
Sector-specific functional accessibility requirements applicable to e-commerce services are established in § 22 of the Accessibility Requirements Regulation.
- Information provided in the course of the service must include information on the accessibility of the product or service being sold, where the responsible economic operator has made such information available to the seller in advance. This means that if a manufacturer, importer or distributor has provided accessibility information about a product in an accessible format (for example, a sign language video describing product features), the e-commerce provider must also publish this information in its online store.
- Authentication and payment methods, as well as security features provided as part of the service, must comply with the four principles of digital accessibility.
- Authentication methods, electronic signatures and payment services used in the provision of the service must comply with the four principles of digital accessibility.
The distinction between authentication methods provided as part of the service and authentication methods used in the provision of the service lies in the fact that, in the first case, the service provider offers the authentication and payment solutions itself, whereas in the second case, it uses services provided by another service provider.
Electronic communications services, including emergency communications, fall within the scope of the Products and Services Accessibility Act pursuant to clause 6 of subsection 1 of § 2 of the Act.
An electronic communications service is a service provided under agreed conditions via an electronic communications network, including internet access services, interpersonal communications services or other services consisting wholly or mainly in the conveyance of signals, excluding media services (clause 6 of § 2 of the Electronic Communications Act).
Accordingly, the Products and Services Accessibility Act applies to electronic communications services such as cable television services, data transmission services (internet access) and interpersonal communications services (for example, traditional telephone and mobile telephone services).
Emergency communications include all interpersonal communications services enabling access to emergency services (ie communication between the caller and the Emergency Response Centre for the purpose of obtaining emergency assistance).
Sector-specific functional accessibility requirements applicable to electronic communications services are established in § 16 of the Accessibility Requirements Regulation.
- In addition to voice and text communication, the service must enable real-time text communication. Where video is also used in addition to voice and text, audio, video and text must function synchronously.
- The service must ensure emergency communications enabling responses in the same format as the communication received (for example, if an emergency communication is submitted via video, it must also be possible to respond via video). During emergency communications, voice and text (including synchronised real-time text), or where video is used, voice, text and video, must function synchronously.
E-books and dedicated software fall within the scope of the Products and Services Accessibility Act pursuant to clause 3 of subsection 3 of § 2 and are defined in clauses 2 and 3 of subsection 5 of § 2 of the Act.
An e-book is a service consisting of the provision of digital files that convey an electronic version of a book, that can be accessed, navigated, read and used.
E-book software is dedicated software (including mobile device-based services) used for accessing, navigating, reading and using e-book files, excluding e-reader software.
Sector-specific functional accessibility requirements applicable to e-book services are established in § 21 of the Accessibility Requirements Regulation.
- Where an e-book contains both text and audio, the text and audio must be presented synchronously during the provision of the service.
- The digital file of the e-book must enable assistive technologies to function properly during use.
- The service must enable users with a disability to access the content of the e-book, navigate within its content and layout, perceive its structure and use the e-book flexibly with options for presenting the content.
- Alternative presentations of e-book content and interoperability with different assistive technologies must comply with the four principles of digital accessibility.
- The e-book must be discoverable through metadata containing information about accessibility features. As metadata describes the e-book (author, title, length, method of use, device requirements etc), it must be accessible so that users can understand the nature of the e-book.
- Accessibility features of the e-book must remain applicable regardless of digital rights management measures. This means that copyright protection measures must not prevent the creation of alternative accessible formats, as these constitute alternative presentations of the same content rather than new content.
Financial services fall within the scope of the Products and Services Accessibility Act pursuant to clause 4 of subsection 3 of § 2 and subsection 7 of § 2 of the Act.
For the purposes of the Products and Services Accessibility Act, financial services include:
- payment services referred to in subsection 1 of § 3 of the Payment Institutions and E-money Institutions Act;
- issuance of electronic money as defined in subsection 1 of § 6 of the Payment Institutions and E-money Institutions Act;
- consumer credit and consumer credit relating to residential immovable property as defined in § 3 of the Creditors and Credit Intermediaries Act;
- basic payment services related to payment accounts referred to in subsection 151 of § 709 of the Law of Obligations Act;
- investment services and activities referred to in clauses 1, 2, 4 and 5 of section 1 of § 43 of the Securities Market Act;
- ancillary services to investment service referred to in clauses 1, 2, 4 and 5 of § 44 of the Securities Market Act.
Sector-specific functional accessibility requirements applicable to financial services are established in § 20 of the Accessibility Requirements Regulation.
- Authentication methods, electronic signatures, payment instructions, execution of payment transactions and security measures used in the provision of the service, including blocking of payment instruments, must comply with the four principles of digital accessibility.
- Information provided in the course of the service must be understandable. The complexity of the information must not exceed level B2 (upper intermediate) of the Common European Framework of Reference for Languages.
Certain parts of air, bus, rail and waterborne passenger transport services fall within the scope of the Products and Services Accessibility Act pursuant to clause 5 of subsection 3 of § 2 of the Act.
These parts include websites, mobile device-based services, electronic tickets, electronic ticketing services, provision of transport information, real-time travel information, interactive information screens and self-service terminals.
Clauses 3 to 5 of subsection 9 of § 2 of the Products and Services Accessibility Act exclude the following parts from the scope of accessibility requirements:
- self-service terminals permanently installed in vehicles, aircraft, vessels or rolling stock used in any part of passenger transport services;
- occasional transport services within the meaning of § 5 of the Public Transport Act;
- rural, urban or county routes within the meaning of subsection 2 of § 4 of the Public Transport Act; however, accessibility requirements applicable to interactive self-service terminals still apply.
In addition, subsection 10 of § 2 of the Products and Services Accessibility Act excludes certain waterborne passenger transport services from the scope of accessibility requirements, including services that are provided:
- on excursions and leisure trips (excluding cruises, which are within scope);
- on original, and individual replicas of, historical passenger ships designed before 1965, built predominantly with the original materials, certified to carry up to 36 passengers;
- on sailing vessels;
- on ships certified to carry up to 12 passengers;
- on ships which have a crew of not more than three persons;
- on ships where the distance of the passenger service is less than 500 metres one way.
Sector-specific functional accessibility requirements applicable to long-distance air, bus, rail and waterborne passenger transport services are established in § 18 of the Accessibility Requirements Regulation.
- Requirements relating to the provision of services and information associated with services established in §§ 9 and 10 of the Accessibility Requirements Regulation also apply to long-distance passenger transport services.
- Information regarding the accessibility of vehicles, surrounding infrastructure and the built environment, assistance for persons with a disability, smart ticketing systems and their functions, availability of additional services and real-time travel information must be provided accessibly.
Sector-specific functional accessibility requirements applicable to rural, urban and county routes are established in § 19 of the Accessibility Requirements Regulation. They are subject only to the accessibility requirements for interactive self-service terminals not permanently installed in vehicles.
Services providing access to audiovisual media (AVM) services fall within the scope of the Products and Services Accessibility Act pursuant clause 6 of subsection 3 of § 2 and are defined in clause 8 of subsection 5 of § 2 of the Act
Services providing access to audiovisual media services means services transmitted by electronic communications networks which are used to identify, select, receive information on, and view audiovisual media services and any provided features, such as subtitles for the deaf and hard of hearing, audio description, spoken subtitles and sign language interpretation, and electronic programme guides.
Where audiovisual media content is provided accessibly (for example, with subtitles for the deaf and hard of hearing and/or sign language interpretation), the provider of the access service must ensure that these accessibility features can also be received by users. The scope additionally includes electronic programme guides, websites, mobile applications and set-top box applications.
Sector-specific functional accessibility requirements applicable to services providing access to audiovisual media services are established in § 17 of the Accessibility Requirements Regulation.
- The service must provide electronic programme guides that comply with the four principles of digital accessibility and provide information about the availability of accessibility features.
- The service must ensure the full transmission and sufficient quality of accessibility features, synchronisation of audio and video, and the possibility for users to configure display and usage settings. Accessibility features include subtitles for the deaf and hard of hearing, audio description, spoken subtitles and sign language interpretation.
A service provider must prepare an information document explaining the conformity of services with accessibility requirements. The document must be available in written and oral accessible format and must be retained throughout the entire period during which the service is provided (subsection 2 of § 11 of the Products and Services Accessibility Act).
The information document must include an assessment of how the service complies with the applicable accessibility requirements. The information itself must also be presented accessibly, meaning that it must be perceivable, operable, understandable and robust.
Accessibility information must be provided separately for each individual service. It is permitted to consolidate accessibility information for all services provided by the service provider into a general accessibility policy, provided that each service includes a reference to that policy.
The Products and Services Accessibility Act does not prescribe a specific structure for the information document; however, its purpose is similar to the accessibility statement currently mandatory in the public sector. Service providers may therefore consult public sector accessibility statement templates and guidance materials.
Section 9 of the Accessibility Requirements Regulation establishes requirements for presenting information during the provision of services:
- Information must be provided on how the service functions, as well as on the accessibility features of the product used in the provision of the service, assistive devices, interoperability with service elements, and the relationship between the service and the product.
- Electronic information necessary for using the service must be presented consistently and appropriately and it must comply with the four principles of digital accessibility.
- Where support services are available, information about the accessibility of the product or service and its compatibility with assistive technologies must be provided using accessible means of communication.
- User instructions for the service or information relating to the service published on the service provider’s website must comply with the requirements established in subsection 6 of § 6 of the Accessibility Requirements Regulation.
Subsection 6 of § 6 of the Accessibility Requirements Regulation establishes the following requirements for user instructions and information relating to products or services published on the service provider’s website:
- Information must be understandable and perceivable through more than one sensory channel (for example, text that is visually readable should also be compatible with screen readers);
- Information must be presented in a comprehensible manner (for example, using vocabulary understandable to the target audience instead of unnecessarily complex technical terminology);
- Information must take into account the needs of persons with visual impairments (including sufficient contrast and adaptability according to user settings);
- Non-text content must have accessible alternatives (for example, alternative text for images, subtitles for the deaf and hard of hearing in audio and video content etc);
- Information must include a description of software compatible with assistive technologies, together with a list of assistive technologies tested with the service (for example, screen reader and browser combinations compatible with an online store);
- Information must include a description of the user interface and functionality of the service. This description must comply with the requirements established in § 7 of the Accessibility Requirements Regulation and must specifically indicate whether the service includes the relevant accessibility features set out therein.
Section 7 of the Accessibility Requirements Regulation establishes requirements for the functionality and user interface of products within the scope of the Products and Services Accessibility Act; however, these requirements also apply to descriptions of service user interfaces and functionality. Among other things, the following requirements apply:
- Descriptions must be usable by persons with a physical disability (for example, enabling navigation using only a keyboard);
- Descriptions must not trigger photosensitive seizures (for example, by avoiding animations flashing more than three times per second);
- Descriptions must be compatible with assistive technologies (for example, enabling access through screen readers);
- Descriptions must be adaptable for persons with visual impairments (for example, allowing content magnification);
- Colour or sound must not be the sole means of conveying information, actions must be indicated, responses must be prompted and elements must be distinguished (for example, by highlighting mandatory form fields that have been left incomplete).
Accessibility requirements do not need to be applied where compliance would impose a disproportionate burden on the economic operator or would fundamentally alter the nature of the service (subsection 5 of § 4 of the Products and Services Accessibility Act). In such cases, the service provider must carry out an assessment in accordance with the Disproportionate Burden Regulation (subsections 1 and 6 of § 5 of the Products and Services Accessibility Act).
An assessment must also be carried out where the service is altered, it is requested by the Consumer Protection and Technical Regulatory Authority (CPTRA) during supervisory proceedings, or where five years have passed since the previous assessment. Detailed procedures are established in the Disproportionate Burden Regulation.
When assessing disproportionate burden, the economic operator must take into account the following criteria:
- the ratio between the net cost of complying with accessibility requirements and the total cost of providing the service;
- the ratio between the estimated costs and benefits for the economic operator compared with the expected benefit for persons with a disability;
- the ratio between the net cost of complying with accessibility requirements and the economic operator’s net turnover.
When notifying the Consumer Protection and Technical Regulatory Authority of the non-application of accessibility requirements, the economic operator must provide the following information:
- the name and email address of the economic operator and, where relevant, the role of the economic operator in relation to the product;
- the name of the product or service;
- the product classification according to the list of products established under the Products and Services Accessibility Act;
- the target group of the product or service;
- the accessibility requirements that are not being applied to the product or service;
- the reasons for non-application of the accessibility requirements;
- confirmation that the economic operator has not received funding for improving accessibility from resources other than its own funds.
Where the economic operator has received external funding for improving accessibility, it may not rely on disproportionate burden as justification for non-compliance.
The Products and Services Accessibility Act introduces several accessibility requirements. Accessibility requirements that impose a disproportionate burden on an economic operator or fundamentally alter the nature of a product or service do not need to be applied.
However, accessibility requirements that do not impose a disproportionate burden and do not fundamentally alter the product or service must be implemented in full. Further information is available in our guidance document (please note that the document is available in Estonian only).
Economic operators are required to notify the Consumer Protection and Technical Regulatory Authority where accessibility requirements cannot be implemented. The economic operator must download, complete and sign the relevant form. Please note that the notification form is available in Estonian only.
The signed file must be sent to [email protected].
The requirements outlined on this page represent only part of the content of the applicable legislation. Service providers are responsible for familiarising themselves in detail with the requirements set out in legislation and harmonised standards.
What accessibility requirements apply to products and services within the scope of the Products and Services Accessibility Act?
Recital 46 of the European Accessibility Act states that private sector websites and mobile applications must comply with the same European digital accessibility standard (EN 301 549) that applies to public sector websites and mobile applications. A new version of EN 301 549 is currently being prepared due to the expansion of its scope of application; however, based on currently available information, the core requirements of the standard will remain largely unchanged.
What does the ‘four principles of digital accessibility’ mean?
These principles are:
- Perceivable
- Operable
- Understandable
- Robust
These widely recognised principles form the basis for specific requirements in several international accessibility standards and are also referenced in different legal acts.
Perceivable
Content must be perceivable through different senses. For example, images must include descriptions and videos must contain subtitles. In addition, there must be sufficient contrast between background and text colours.
Operable
Content must be usable in different ways. For example, a website must be fully operable using only a keyboard. If a page contains time-limited content (such as an automatically rotating carousel or session timeout), users must have the possibility to pause it or extend the time limit.
Understandable
Content must be uniformly understandable. Texts must be readable and easy to understand. Forms must include clear labels and instructions.
Robust
Content must function reliably in different situations, on different devices and across different browsers. For example, enlarging website content must not cause information to become hidden from the user. Content must also be compatible with assistive technologies.
What must the information document describing the conformity of the service with accessibility requirements contain?
Subsection 2 of § 11 of the Products and Services Accessibility Act requires service providers to prepare an information document explaining the conformity of the service with accessibility requirements. This document must be made available to the public in written and oral accessible format and retained throughout the entire period during which the service is provided.
The information document is similar to the accessibility statement currently mandatory in the public sector. Its purpose is to inform users, provide explanations and offer a practical and user-friendly solution for accessibility-related concerns. The statement must include information about the owner of the relevant website and/or application and explain how the service complies with accessibility requirements.
The Products and Services Accessibility Act does not prescribe a specific structure for the information document, meaning that service providers may determine its format at their own discretion. Service providers may consult public sector accessibility statement templates and guidance materials; however, the information document itself must comply with the requirements established by the Products and Services Accessibility Act.
In addition, it is recommended to continue the common practice widely used in Estonia, where a clearly distinguishable link to the accessibility statement is placed in the header or footer of every webpage. The statement may be prepared on the basis of an accessibility assessment carried out either internally or by a partner organisation (such as a developer or an accessibility assessment provider).
Do the accessibility requirements established under the Products and Services Accessibility Act apply only in digital environments (ie not to paper documents such as printed invoices)?
No. The Products and Services Accessibility Act also applies in physical environments (for example, accessibility requirements for self-service terminals). However, the Act does not establish accessibility requirements for paper invoices.
Where do the requirements for e-commerce services originate and which requirements apply?
Recital 46 of the European Accessibility Act states that private sector websites and mobile applications must comply with the same European digital accessibility standard (EN 301 549) that applies to public sector websites and mobile applications. A new version of EN 301 549 is currently being developed due to the expansion of its scope of application; however, based on currently available information, the core requirements of the standard will remain largely unchanged.
When providing e-commerce services, accessibility must be ensured throughout the entire user journey. This includes the selection of goods or services, registration and payment processes, receiving purchase confirmations by email, and access to information regarding purchase, return and exchange conditions. The purpose of these requirements is to ensure that all users, regardless of disability or specific access needs, can use e-commerce services independently and without barriers.
What specific requirements apply to e-commerce services?
Accessibility obligations applicable to e-commerce services apply to any online sale of products or services. In practice, this means that information provided during the service must include information about the accessibility of the products or services being sold, where the responsible economic operator has previously made such information available to the seller.
This means that if a manufacturer, importer or distributor has provided accessibility information about a product in an accessible format (for example, a sign language video describing product features), the e-commerce provider must also publish this information in its online store.
In addition, the service provider must ensure that authentication methods, payment methods and security functions provided as part of the service comply with the four principles of digital accessibility. This requirement also applies where the service provider uses a technical e-commerce solution provided by another company.
Who is responsible for the accessibility of the source code and technical architecture of the platform – the platform provider as the developer of the technical solution or the merchant as the service provider within the meaning of the Products and Services Accessibility Act?
The Products and Services Accessibility Act follows the principle of service provider responsibility rather than ownership of the technical platform or the contractual development relationship. This means that, in the context of e-commerce services, the service provider, ie the merchant, is responsible for ensuring that the service as a whole complies with accessibility requirements, regardless of the business model or technical solution used.
This principle derives directly from legislation:
- Subsection 2 of § 3 of the Products and Services Accessibility Act defines the service provider as any person who provides a service on the Union market. In e-commerce, this is generally the merchant, regardless of which technical platform or software solution is used.
- Subsection 1 of § 11 of the Products and Services Accessibility Act requires the service provider to ensure that the service complies with accessibility requirements. Accordingly, the merchant is responsible for ensuring that the e-commerce service as a whole complies with accessibility requirements, including the usability of the website or mobile solution from the consumer’s perspective.
- Clause 1 of subsection 3 of § 2 of the Products and Services Accessibility Act establishes e-commerce as a service within the scope of the Act. The explanatory memorandum specifies that the e-commerce provider must ensure accessibility throughout the entire purchasing journey, including authentication, payment and delivery options.
Where third-party platforms, plugins or technical solutions are used in the provision of e-commerce services, responsibility may be shared between different economic operators depending on their role and level of control over the specific solution. The Products and Services Accessibility Act does not impose direct obligations on a platform provider unless it is itself the service provider on the Estonian market or provides services to Estonian consumers.
The Products and Services Accessibility Act applies to the economic operator providing the service to the consumer, rather than to technical intermediaries within the supply chain. The merchant therefore remains responsible even where it does not develop the platform itself and instead uses a leased platform solution.
Accordingly, under the Products and Services Accessibility Act, the merchant as the e-commerce service provider is responsible for ensuring that the service as a whole is accessible, regardless of whether the technical platform belongs to the merchant or to a third party. The platform developer is responsible only for the technical quality of its own software, whereas obligations under the Products and Services Accessibility Act apply solely to the service provider offering the service to consumers.
Is the merchant responsible only for the content and design choices they add or for the entire environment as a whole?
The merchant is responsible for ensuring accessibility throughout the entire user journey in the provision of e-commerce services. This includes the selection of goods or services, registration and payment processes, receiving purchase confirmations by email, and access to information regarding purchase, return and exchange conditions. The purpose of accessibility requirements is to facilitate independent use of services by persons with a disability.
For the exception regarding third-party content established in clause 2 of subsection 9 of § 2 of the Products and Services Accessibility Act to apply, several conditions must be fulfilled simultaneously:
- the content is neither funded nor developed by the merchant; and
- the merchant has no control or influence over the content.
For example, where a merchant pays for the use of a platform through which goods are sold, one of the conditions for the exception is not fulfilled. Consequently, the platform used by the merchant must comply with accessibility requirements even if the merchant does not itself develop or control the platform. The same applies to integrated third-party payment services or similar solutions for which the merchant pays.
The merchant cannot delegate its legal responsibility to the technology provider but must ensure that the chosen and managed environment is accessible and barrier-free for consumers at every stage.
However, where an online store contains third-party content that the merchant does not pay for, does not develop and cannot influence, such content does not need to comply with accessibility requirements.
How does the Consumer Protection and Technical Regulatory Authority interpret the role of the merchant regarding payment solutions (eg bank links) or delivery option modules (eg Omniva/Itella plugins) used in online stores?
Authentication methods, payment methods and security-related functions provided as part of the service must comply with the four principles of digital accessibility even where the service provider uses services offered by another provider (§ 22 of the Accessibility Requirements Regulation). If delivery selection forms part of the e-commerce process, the merchant must ensure that this component also complies with the four principles of digital accessibility.
The exception established in clause 2 of subsection 9 of § 2 of the Products and Services Accessibility Act does not apply to payment solutions or delivery option modules, as these are not considered ‘third-party content’ but rather functions forming an integral part of the service, which the merchant selects, finances and influences.
What is the responsibility of the merchant regarding embedded social media feeds or video platform content (eg YouTube) within an online store?
Embedded social media feeds or video platform content (such as YouTube or Instagram) may, in certain circumstances, fall within the third-party content exception, depending on the role of the content within the e-commerce service.
Where the content constitutes independent third-party content merely displayed by the merchant (for example, social media or video feeds used for marketing purposes), it may fall within the exception, provided that the merchant does not exercise substantive control over, develop or finance the content.
However, where an external platform is used as an essential part of providing the service – for example, for product instructions, important information or other information necessary for concluding a consumer contract – it cannot be treated merely as third-party content. In such cases, the content forms part of the e-commerce service and the merchant is responsible for ensuring that the information is accessible to consumers even where it is technically hosted on an external platform.
Accordingly, marketing and supplementary content may, under certain conditions, fall within the exception. Content necessary for providing the service (such as product information or instructions) must comply with accessibility requirements regardless of the platform on which it is presented. Responsibility depends not on the platform itself but on the role of the content and the merchant’s ability to control or influence it.
What constitutes a substantive modification that creates an obligation to bring a website into compliance with accessibility requirements?
Pursuant to subsection 5 of § 22 of the Products and Services Accessibility Act, audio and video content, office file formats (such as PDF files) and website content published before 28 June 2025 may continue to be used unchanged if they are not modified after that date.
Where modified content is directly related to the use of the service or to making a purchasing decision, the service provider must ensure that the service is designed and provided in compliance with applicable accessibility requirements (subsection 1 of § 11 of the Products and Services Accessibility Act).
A substantive modification includes, for example, changes that:
- affect the structure, functionality or logic of website use;
- add or modify information essential for using the service;
- change the manner in which consumers use the service or obtain information.
Example:
Online store C published product instruction videos for ten products on 1 January 2024. On 1 January 2026, updated instruction videos for the same products were created. This constitutes updated content, meaning that the replacement video instructions must comply with accessibility requirements.
Example:
Online store D was launched in 2024. In 2026, the service provider adds a new ‘Find Your Size’ feature allowing users to enter measurements and receive recommended clothing sizes. As this changes how consumers use the online store and obtain product information, the feature constitutes a substantive modification and must comply with accessibility requirements.
Example:
Online store E published a product image gallery for shoes in 2024. In 2026, only the display order of the images is changed. As no new content was added and functionality remained unchanged, this does not constitute a substantive modification.
Does the automatic updating of product prices or stock levels make the entire product page ‘updated’ and therefore subject to accessibility requirements?
A website is considered part of an e-commerce service and the service provider must ensure that information presented in connection with the service complies with accessibility requirements. Under the Accessibility Requirements Regulation, websites must be designed and presented in a manner that is perceivable, operable, understandable and robust.
Automatic updating of product prices or stock levels constitutes an update of the product page. This means that the updated price and stock information themselves must be presented accessibly. For example, price information must be readable by screen readers and must also be perceivable through sufficient colour contrast. Important information must not be conveyed solely through colour or visual indicators.
However, such updates do not automatically mean that the entire product page must be redesigned. Content published before 28 June 2025 and not modified thereafter (such as product images) continues to fall within the exception provided for in subsection 5 of § 22 of the Products and Services Accessibility Act.
How should minor technical or design changes (eg security patches or CSS updates) that do not alter the content itself be treated?
Minor technical or design changes that do not affect website functionality, structure or the user journey are generally not considered substantive modifications within the meaning of subsection 5 of § 22 of the Products and Services Accessibility Act.
Such changes may include security updates, bug fixes or cascading style sheet (CSS) changes intended to improve system operation or visual consistency without altering how the service is used. Consequently, such modifications do not generally create an obligation to treat the website as updated or to bring it entirely into compliance with accessibility requirements.
However, where a technical or design change affects the user journey, interaction logic or content perceivability (for example, contrast or navigability), it may constitute a substantive modification requiring an assessment of accessibility compliance obligations.
The law therefore permits website content created before 28 June 2025 to remain in use unchanged until the content itself is updated in a way that affects the provision of the service to consumers. Routine technical maintenance does not fall within this category.
How should PDF instructions, terms of use or product introduction videos uploaded before 28 June 2025 be treated if they remain an active part of the sales process and are accessible to consumers?
Pursuant to subsection 5 of § 22 of the Products and Services Accessibility Act, pre-recorded audio and video content, office file formats (such as PDF files) and other website content published before 28 June 2025 may continue to be used unchanged after that date, provided they are not modified or updated.
Accordingly, there is generally no obligation to retroactively make PDF instructions, terms of use or product introduction videos published before 28 June 2025 accessible merely because they remain available on the website or continue to form part of the sales process.
However, where such content is modified, updated or replaced after 28 June 2025, it is considered new or modified content and must comply with accessibility requirements.
In addition, e-commerce providers are required to publish accessibility information regarding products and services offered on their websites where the responsible economic operator has previously made such information available in an accessible format (subsection 1 of § 22 of the Accessibility Requirements Regulation).
This means that if a manufacturer, importer or distributor has provided accessibility information about a product in an accessible format (for example, a sign language video describing product features), the e-commerce provider must also publish this information in its online store.
If an undertaking concluded a service contract relating to its online store (eg a development or maintenance contract) before 28 June 2025, does this mean the online store does not need to comply with accessibility requirements until 2030?
This provision must be interpreted together with the scope of application of the Products and Services Accessibility Act.
The Products and Services Accessibility Act applies to services provided by service providers to consumers, including e-commerce services. Accordingly, the contracts referred to in subsection 2 of § 22 of the Act primarily concern service contracts concluded with consumers under which services are provided.
The purpose of this provision is to avoid situations in which undertakings would have to retroactively amend already concluded consumer contracts solely because those contracts do not take accessibility requirements into account. At the same time, the intention is to ensure that, following the date of application of the provisions, services offered on the market comply with accessibility requirements.
Where an undertaking provides e-commerce services to consumers after 28 June 2025, the service must comply with accessibility requirements regardless of when contracts relating to the technical solution of the online store were concluded.
Last updated: 22.05.2026
