Frequently asked questions about new accessibility requirements for products and services

The supervision will begin on 28 June 2025 for both products and services. 

For products, the requirements apply only to new products placed on the market after 28 June 2025. Products previously placed on the market will not be required to meet the accessibility requirements at a later date. 

For services, the situation is different: older services that were offered before 28 June 2025 must be updated to meet the new accessibility requirements.

Yes, there are exceptions to the starting date of supervision in the form of a transition period. 

Products used for the provision of services must comply with accessibility requirements after a transitional period of five years, i.e., by 28 June 2030. The transitional period applies to products whose main purpose is to provide services covered by the European Accessibility Act. 

Such products include: 

• set-top boxes whose main purpose is to provide access to audiovisual media services 

• e-readers, such as Kindle, specially designed for reading electronic books

In addition, self-service terminals introduced before 28 June 2025 may continue to be used for the provision of similar services for 20 years from their introduction. 

Service contracts concluded before 28 June 2025 may be continued as is until their validity expires but not for longer than 28 June 2030.

Placing a product on the market means making a product available to consumers for the first time in the European Union market. A product is made available in the market when it is provided in the market for distribution, consumption or use on the European Community market in the course of a commercial activity, whether in return for payment or free of charge. It should be noted that each individual product can only be placed on the Union market once.

Traficom monitors the compliance of products and services based on notifications made by manufacturers, importers, distributors and service providers as well as customer contacts. The agency also guides and advises economic operators to ensure the conformity of their products and services.

In addition, Traficom has access to the surveillance measures referred to in the Act on the Market Surveillance of Certain Products, such as performing checks and obtaining products for examination. If the product does not meet the requirements, the economic operator may be ordered to bring the product into conformity. Traficom may also prohibit an economic operator from manufacturing a product, placing a product on the market, making a product available on the market or otherwise handing over a product or ordering a product to be withdrawn from the market. The costs incurred from these measures may be imposed on the economic operator. The deliberate or grossly negligent attachment of a CE marking (see question 19) to a non-compliant product is prohibited and may result in a fine.

Provisions on measures concerning services are laid down in the Act on Electronic Communications Services. If the service fails to meet the accessibility requirements, Traficom may issue a notice to the service provider and obligate the provider to bring the product into compliance.

A conditional fine may be imposed to enforce the orders.

Yes, nonconformity with the accessibility requirements is possible in certain situations. 

An economic operator may deviate from the accessibility requirements on the basis of the exemption criteria laid down in law. These include a change in the nature of the product or service resulting in a fundamental change in the nature of the product or service, in which case compliance with the requirements causes undue burden on the economic operator. 

An assessment of whether compliance with accessibility requirements constitutes an undue burden must be made by comparing compliance costs with operational and capital costs as well as net compliance costs with net turnover and as a cost-benefit assessment that particularly pays attention to the needs of persons with disabilities when using the product. An operator may not rely on an undue burden if it receives funding from sources external to its own resources to improve accessibility.

Invoking exemption grounds requires an assessment of the fulfilment of the prerequisites for deviation and submitting a notification of non-conformity to the supervisory authority. See question 16 on the notification duty.

Products subject to supervision include:

1. Consumer computer hardware with operating systems such as smartphones, tablets, desktop and laptop computers.
2. Self-service payment terminals.
3. Automated teller machines, ticketing machines and check-in machines that provide services referred to in Chapter 3 a of the Act on the Provision of Digital Services*
4. Interactive self-service terminals providing services referred to in Chapter 3 a of the Act on the Provision of Digital Services and services belonging to local and regional bus and rail transport.The scope of application does not include terminals installed as fixed parts of vehicles or non-interactive terminals, such as timetable displays in stations.
5. Consumer terminal equipment used for electronic communications services, e.g. smartphones, but also including devices such as modems and routers.
6. Consumer terminal equipment used for audiovisual media services, including digital converter boxes and smart televisions.
7. E-readers whose main purpose is to enable users to read and access e-books, including the wireless Kindle e-reader.
8. Other products used for the provision of services and identification services referred to in Chapter 3 a of the Act on the Provision of Digital Services, including the authentication tools provided by banks.

*Services referred to in Chapter 3 a of the Digital Services Act are services covered by the European Accessibility Act. These include passenger transport services, e-book and e-commerce services, electronic communications services and services providing access to audiovisual content as well as certain consumer banking services such as consumer credits, investment services and payment services.

Services subject to supervision include:

1. Digital services provided as part of passenger transport services, including service providers’ websites and mobile applications, electronic travel ticket services and e-tickets.
2. E-books, i.e., electronic books, that are readable on a browser or a mobile application - all written works published in digital format, including fiction, non-fiction and textbooks and professional digital libraries and online bookshelves.
3. E-commerce services, i.e., services offered on websites and as mobile device-based services, in which distance selling agreements can be concluded in accordance with the Consumer Protection Act.
4. Electronic communications services, i.e., internet access services including broadband services, and interpersonal communications services including telephone calls, SMSs, instant messaging services (e.g., Whatsapp, Messenger) and email.
5. Services providing access to audiovisual content services, including websites for services such as Yle Areena, Katsomo and Netflix, mobile applications, applications offered on televisions and set-top boxes, hybrid television services and electronic programme guides.
6. Certain consumer banking services such as consumer credit, investment services and payment services.

Of these, Traficom’s supervision covers electronic communications services and services providing access to audiovisual content services as regards the requirements concerning all services, for the parts that do not concern services laid down in the Act on the Provision of Digital Services, i.e., websites and mobile applications. However, the Act contains provisions on additional requirements concerning communication services and services providing access to audiovisual content services, the compliance with which is also supervised by Traficom in the context of websites and mobile applications.

The remaining services mentioned above will be supervised by the Regional State Administrative Agency’s Accessibility Supervision Unit until 31 December 2024. Accessibility supervision duty has been transferred to Traficom as of 1 January 2025, from which point on all supervision under the European Accessibility Act will take place at Traficom.

They do not. The European Accessibility Act requirements do not apply to services that enable interpersonal interaction only as a minor ancillary function and are connected to another service, such as an online game. Therefore, chats between computer game players do not have to comply with accessibility requirements.

Telephone and text messaging services based on numbers are traditional telephone services. This means that calls and messages are connected based on a telephone number instead of via the internet.

With regard to products, the market surveillance of accessibility is focused on manufacturers, importers and distributors operating in the market of a Member State. In other words, companies operating in the Finnish market are supervised in Finland. For example, a non-EU manufacturer cannot be subjected to measures in case of non-compliance, but if a company established in Finland imports a product into Finland, the importer’s obligations apply to said company. 

With regard to services, supervision is directed at a company providing services in Finland, even if said company is located elsewhere. This also means that large multinational companies providing communication services or audiovisual media services, such as WhatsApp and Netflix, are obliged to comply with accessibility requirements when providing their services in EU Member States. 

The supervision of accessibility requirements requires cooperation between the authorities of different Member States. The supervisory authority of each Member State will supervise the products and services on the market within its territory. The same requirements and standards apply in different Member States. When a product or service is non-compliant in Finland, it is non-compliant in all Member States. Non-compliant products or services are reported to the authorities of other Member States, in which case the detected non-compliance also leads to measures in other EU countries. 

A microenterprise refers to a company that employs fewer than 10 employees and whose annual turnover or balance sheet total does not exceed EUR 2 million.

For services, the accessibility requirements do not apply to microenterprises. Microenterprises providing services covered by the European Accessibility Act are excluded from the scope of the Act and national legislation. However, microenterprises are encouraged to take accessibility requirements into account in their operations and to comply with them. Compliance also benefits the enterprises as it improves the availability of services.

For products, accessibility requirements also apply to microenterprises, i.e., they are obliged to comply with accessibility requirements, but they are exempted from the notification obligation and the documentation of the exemption that applies to economic operators. In other words, microenterprises do not need to notify the supervisory authority or prepare an assessment if they deviate from the accessibility requirements on the basis of an undue burden or a thorough change.

However, when participating in a tendering process for public procurement, the microenterprise must meet all the same requirements as other participants.

The responsibilities and obligations are determined in more detail according to the role of each operator but some of the responsibilities apply to everyone (see questions 14-17).

An economic operator refers to an entity that supplies a product or service to the market, either alone or together with other operators, and is responsible for its part for ensuring the conformity of the product or service. 

• In the context of placing products on the market, economic operators include the manufacturer, importer and distributor of the product. 
• Operators providing services are referred to as service providers.

The responsibilities and obligations are determined according to the role of each operator but some of the responsibilities apply to everyone. 

a) Manufacturers

The manufacturer must: 

• ensure that the product is designed and manufactured in accordance with accessibility requirements. One way to demonstrate compliance is by following a harmonised standard.
• prepare technical documents and the EU Declaration of Conformity. The technical documentation and the EU declaration of conformity must be kept for a period of five years after the product has been placed on the market.
• attach a CE marking to the product (see question 19 on the CE marking). 

In addition, the manufacturer is responsible that: 

• the product bears a batch or serial number or other marking that the product can be identified with. 
• the product is also accompanied by clear and understandable instructions and safety information in both Finnish and Swedish so that information on the use and properties of the product is available to consumers. The product must also include the manufacturer’s contact details.

b) Authorised representative

The manufacturer may designate an authorised representative whose responsibility it is to: 

• ensure that the EU Declaration of Conformity and the technical documentation are available to the market surveillance authority 
• cooperate with the authority to rectify any non-conformity of the product. 

However, the manufacturer may not transfer to the authorised representative the responsibility for the design and manufacture of the product in accordance with the requirements or for the production of documents.

c) Importers

The importer must:

• before placing the product on the market, ensure that the manufacturer has complied with its obligations to draw up an EU Declaration of Conformity and to attach a CE marking to the product (see question 19) as well as other required information and instructions. A product may not be placed on the market if it does not meet the accessibility requirements. 
•  notify the manufacturer and the market surveillance authority of the non-conformity.
• notify its contact details in the product and keep a copy of the EU Declaration of Conformity at the disposal of the market surveillance authority for a period of five years after the product has been placed on the market. 
• ensure that the storage or transport of the product does not jeopardise compliance.

The importer shall be subject to the obligations of the manufacturer if the importer places the product on the market under his own name or trademark or modifies the product already placed on the market in a manner that may affect compliance. 

d) Distributors

The distributor 

• must verify that an EU Declaration of Conformity has been prepared for the product and that the product bears a CE marking (see question 19 on the CE marking). 
• must also verify that the manufacturer and importer have attached the required contact information, product identification information and instructions to the product. 
• must also ensure that the storage or transport of the product does not jeopardise compliance.

The obligations of the manufacturer will apply to the distributor if the distributor places the product on the market under its own name or trademark or modifies a product already placed on the market in a manner that may affect compliance.

Common obligations of operators

If a manufacturer, distributor or importer considers or suspects that a product placed on the market does not meet the accessibility requirements, it must:

•  immediately bring the product into conformity or withdraw it from the market. The operator may also invoke undue burden or fundamental change (see question 5) as grounds for deviating from the accessibility requirements. 
• inform the Market Surveillance Authority of any deficiencies and corrective measures and of any appeal to the exemption grounds. See question 16 on the notification duty. The manufacturer and the importer must keep records of products which do not meet the accessibility requirements.
• upon request, provide the market surveillance authority with identification data for the last five years of all other economic operators that have either supplied a product to it or to which it has supplied a product. 

at the request of the market surveillance authority, provide all necessary information and documentation to demonstrate compliance in a language easily understood by the authority and cooperate with the authority to assess accessibility or to remedy non-compliance.

The service provider must: 

• ensure that the service meets the requirements set for it by the European Accessibility Act and national law. One way to demonstrate compliance is by following a harmonised standard. 
• if the service does not meet the accessibility requirements, deficiencies and corrective measures must always be reported to the supervisory authority. The operator may also invoke undue burden or fundamental change as grounds for deviating from the accessibility requirements. The authority must also be notified of this deviation. See question 16 on the notification duty.
• at the request of the authority, provide all necessary information to demonstrate compliance and cooperate with the authority to bring the service into conformity.
• In the case of a digital service referred to in the Act on the Provision of Digital Services, i.e., a website or mobile application, an accessibility statement must be prepared for the service. The template and instructions for the statement are available at www.saavutettavuusvaatimukset.fi. The accessibility statement must include a general description of the digital service and a report on how the digital service meets the accessibility requirements. The Regional State Administrative Agency for Southern Finland will monitor compliance with accessibility requirements until 31 December 2024, after which the supervision duty will be transferred to the Finnish Transport and Communications Agency Traficom from 1 January 2025.

The actual accessibility statement does not have to be drawn up for communications services or services providing access to audiovisual content services that are not websites or mobile applications. 

However, the service provider must publish a description of the service and its activities in an accessible format in order to assess the fulfilment of accessibility requirements. If the service provider deviates from the accessibility requirements by invoking undue burden or fundamental change, information must also be provided to specify the accessibility requirements that the service does not meet.

This information must be stored for as long as the service is provided and the up-to-dateness of the information must be checked at least every five years and whenever changes are made to the service.

Operators are obliged to notify the authorities of the non-compliance of a product or service. There are two types of notifications:

1. If a product or service is non-compliant but bringing it into conformity would fundamentally change the product or service or cause an undue burden on the operator (see question 5), the operator may invoke these grounds for exemption laid down in law. 

   The operator must document this appeal by preparing an assessment of whether the prerequisites for the deviation are met and notify the authority of the appeal. If the authority finds deficiencies in the assessment, it requests that the operator rectify the deficiencies detected within a set deadline. The authority may order the operator to perform a new assessment within a certain period of time. In the case of services, the assessment must always be performed whenever the service is changed and at least every five years.

2. If an operator finds a product or service to be non-compliant but does not wish to invoke the exemption grounds, or if it is not possible to invoke the exemption grounds, the operator must notify the authority of the deficiency it has detected and notify the corrective measures and the timetable for rectifying the deficiency. 

A form for submitting notifications will be available on Traficom’s website when the supervision begins on 28 June 2025. 

The provision of a communication service and a service offering access to audiovisual content may consist of different service chains that involve several different parties in the provision and transmission of the service. The starting point must be that each operator in the supply chain is responsible for the accessibility of the service.

If users access the audiovisual content through the audiovisual content service provider’s own website or application, for instance, the service provider is also responsible for ensuring the accessibility of the audiovisual content service. If the service is used through another service provider’s website or application, the service provider is responsible for ensuring that the service is accessible. For its part, the network operator transmitting the content is also responsible for the accessibility of the service. 

As regards their electronic programme guides, audiovisual content service providers, such as TV channels, must provide the information in an accessible manner. The transmitter of information is responsible for the accessibility of the service, and the service provider that ultimately compiles and displays the content is responsible for ensuring that the programme guide is accessible to the viewer.  

Services providing access to audiovisual content services, such as YLE Areena, operate on certain terminal devices. The terminal devices must meet the accessibility requirements laid down in the Act on the accessibility requirements for certain products and services. However, the service provider providing access to the audiovisual content service cannot be required to ensure that its service will operate at all times and on all terminal devices. For example, if a service is used with a specific application, the terminal device either supports or does not support that application.

The existing standard EN 301 549 is updated to comply with the requirements of the European Accessibility Act. The planned completion date of the Final Draft of the standard is by 30 April 2025. This draft will not be subject to significant changes at this point. The publication as an EN standard is planned to take place on 15 February 2026 and a reference to the standard in the Official Journal of the EU to take place on 31 May 2026, at which point the standard will be given the status of a harmonised European Standard. 

In addition, the ETSI standard ES 204 009 will be developed for the implementation of Full Conversation and Real Time Text, with a planned completion date of the Final Draft being set for August 2025.

In response to the European Accessibility Act, a total of three new harmonised standards will be prepared and three existing standards will be updated. The deadline for the completion and harmonisation of these standards varies and will take place in 2026 and 2027.

The topics of the new harmonised accessibility standards to be developed will be:

• Non-digital product information
• Support services for products and services
• EN 303 919 Emergency communication and emergency number

The harmonised standards to be updated are:

• EN 301 549, new version 4.1.1, Accessibility requirements for Information and Communications Technology
• EN 17161, Design for All
• EN 17210, Accessibility and usability of the built environment

Other standardisation products, such as technical reports or technical specifications, will also be developed and the process of preparing and approving them is faster compared to the official standard. These can be referred to, for example, in harmonised standards. For more information, see the harmonised standards of the European Accessibility Act. 

Harmonised standards are not the only option for demonstrating compliance. In principle, compliance with standards is considered voluntary, as only the essential requirements set out in the Directive are legally binding. The manufacturer therefore has the opportunity to demonstrate compliance by other means, which requires an expert and thorough assessment of compliance.

The product must bear the CE marking, the requirements of which are laid down in Regulation (EC) No 765/2008. 

The CE marking must be attached to the product before the product is placed on the market and the product must meet all valid requirements at the moment it is placed on the market.

The CE marking indicates that the manufacturer declares that the product meets all the requirements and that the manufacturer assumes full responsibility for the product. Several EU-level statutes requiring a CE marking, of which the European Accessibility Act is one example, may apply to the same product. As a result of the adoption of the European Accessibility Act, the CE marking will also be extended to cover accessibility requirements.

The EU Declaration of Conformity must include:

• a general description of the product
• a description of the product's compliance with accessibility requirements 
• a list of applicable harmonised standards 

The declaration must also: 

• identify any requirements from which the product deviates  

Deviation from the requirements of the Act requires a documented assessment by the manufacturer that compliance with the requirements of the Act causes a fundamental change to the basic nature of the product or service or an undue burden on economic operators.

The Declaration of Conformity must be kept up to date and available to the authorities, together with the technical documentation, for a period of five years from the date of the placement on the market. The Declaration of Conformity must be in Finnish and Swedish for products sold in Finland.

A model structure of the declaration of conformity is set out in Annex III to Decision No 768/2008/EC of the European Parliament and of the Council.

Only one declaration of conformity may be drawn up for the product and must contain the required information on compliance with all the regulations applicable to the product.

The information on the use of the product, i.e., labelling, warnings and instructions provided on the product itself, must be made available through more than one sensory channel and presented in fonts of adequate size and contrast.

In addition to instructions provided separately from the product, such as general use instructions and the accessibility functions of the product and how to activate them they must be in a text format that is also suitable for providing instructions using assistive technologies. 

The packaging of products and the information provided in it, such as on opening and disposing of the packaging, must also be designed to be accessible. 

The user interface of the product must be such that the use of the product does not require extensive reach or great strength and that the product can be connected to assistive devices. In addition, it must be ensured that the product features can also be accessed through more than one sensory channel. For example, when the product uses speech it must also be operable with alternatives to speech and vocal input regarding operation control and orientation and when the product uses visual elements it must provide flexible magnification, brightness and contrast adjustment. 

Product-specific requirements have also been set for products. 

• For example, self-service terminals must have a text-to-speech feature and allow the plugging in of headphones. 

Products used for the provision of electronic communications services must be equipped with features such as real-time subtitling and high-quality audio support if the audio is accompanied by text.

As a rule, products must be designed and manufactured so that as many people as possible can use them. The product must be easily accessible to persons with disabilities.

For example, the use of a product must not require great strength or rely on one sense alone. This means, for example, that ticketing machines must include an option for a text-to-speech feature.  If the product uses colour to convey information, alternatives to colour must be provided. Products must ensure the consistency of the functionality and provide enough time for user interaction.

A digital converter box is a product used to provide audiovisual media services. It is subject to the accessibility requirements for all products within the scope of application (see question 22) and also to the product-specific requirement to ensure that the product provides the accessibility features in the range of the AV media service provider for persons with disabilities.

When providing voice communications, interpersonal communications services must also offer a real-time text (RTT) feature. If the service provides video in addition to voice communication, the service must be provided with so-called Total Conversation (ToCo), i.e., synchronised voice, text and video.

In addition, communication services must provide information on the functioning of the service and, if products are used to provide the service, information on how the products in question relate to the service, what accessibility features they include (e.g., alternative speech and voice communication solutions for a smartphone) and their interoperability with assistive devices and arrangements. The information must be provided in an accessible format, for example through more than one sensory channel and with a sufficiently large font size and sufficient contrast. 

Support services, such as call centres and technical support, must also provide information on the accessibility and compatibility of the service with assistive technology using accessible communication methods, where appropriate.

The accessibility requirements aim to ensure that everyone is able to use audiovisual content services as widely as possible. As a result, the access to these services must also be accessible. The electronic programme guides and the information provided in them must be perceivable, operable, understandable and robust, and contain information on the availability of accessibility features. 

• Perceivable means, for example, that the information is presented to users in ways they can perceive. For example, images are accompanied by alternative text that conveys the same information. 
• The user interface components and navigation must be operable, i.e., it must be possible to access the site using a keyboard, for example. 
• Text content must be legible and understandable. 
• Robustness means that the service must be robust enough to be interpreted reliably by assistive technologies, for instance. 

The services must also ensure that the accessibility features of the content services are communicated in a high-quality and accurate manner and so that the user can manage how they are presented and used. Services providing access to content must support the possibility of choosing and customising accessibility services for the content service, including subtitles, audio description and spoken subtitles. Accessibility controls should be easy to find and their features, such as subtitle font size or audio description volume, easily adjustable.

In addition, services must provide information on the functioning of the service and, if products are used to provide the service, information on how the products in question relate to the service, what accessibility features they include and their interoperability with assistive devices and arrangements. The information must be provided in an accessible format, for example through more than one sensory channel and with a sufficiently large font size and sufficient contrast. 

Support services, such as call centres and technical support, must also provide information on the accessibility and compatibility of the service with assistive technology using accessible communication methods, where appropriate.

For accessibility requirements for products used to provide services, such as digital converter boxes, see questions 22-23.

Yle Areena’s website, mobile application and smart TV applications are services providing access to audiovisual content services, for which accessibility requirements are described in question 25.

Yes, it does. The requirements of the European Accessibility Act also apply to public procurement when the procurement concerns products or services that fall within the scope of application of the Act. The products and services within the scope of application must meet the accessibility requirements upon procurement. 

If a product or service meets the requirements of the Accessibility Act in accordance with harmonised standards, it meets the accessibility criteria required by the legislation on public procurement. 

The supervision of products may be carried out on the basis of notifications and contacts received by the supervisory authority or on the operator’s initiative on the basis of a risk assessment by the supervisory authority. For example, an economic operator may be ordered to bring the product into conformity or to withdraw it from the market. For the methods used in supervision, see also question 3.

A significant part of the monitoring consists of self-declaration by economic operators regarding product deficiencies and corrective measures as well as invoking exemption grounds (see question 4). The operator must provide the authority with an assessment of the fulfilment of the conditions in order to invoke undue burden or fundamental change. If the authority finds deficiencies in the assessment, it requests that the operator rectify the deficiencies.

In addition, the authority must publish a list of products that do not meet accessibility requirements. 

In the supervision of services, the authority responds to notifications and contacts or enquiries. Messages may be received from consumers, service providers, stakeholders or other authorities. A significant part of the supervision consists of notifications of non-compliance by service providers themselves. The authority receives service providers' notifications of deficiencies in services and corrective measures as well as appeals to exemption grounds (see question 4). The service provider must prepare an assessment of the fulfilment of the conditions in order to invoke undue burden or fundamental change and notify the authority of the appeal. If the authority finds deficiencies in the assessment, it will invite the service provider to rectify the deficiencies within the set deadline and, if necessary, to perform a new assessment. 

The authority may check whether the service is compliant on the basis of notifications or contacts and also on its own initiative. In the event of non-compliance, a notice may be issued to the service provider and the service provider may be obliged to bring the service into conformity. For the methods used in supervision, see also question 4.

The buyer may return the device to the seller and demand that the sale be cancelled. It is also advisable to notify the supervisory authority (Traficom) of the matter, which may take the necessary measures to assess non-compliance and possibly withdraw the device from the market. However, the Finnish Competition and Consumer Authority (FCCA, www.kkv.fi) supervises the actual cancellation of the sale and any related disputes and compensation matters.

Having the same accessibility requirements in all EU countries ensures that products and services can be offered throughout the EU without a need to produce different versions for different countries.

The national implementation of the European Accessibility Act has progressed at different paces in different Member States. However, most Member States have completed or are close to completing their national legislation.

In this case, it is worth contacting the supervisory authority of the country in question.