New accessibility obligations for business effective from 28 June 2025!

As of 28 June 2025, businesses in sectors such as e-commerce, banking, telecommunications, media and transport will be required to comply with some new, harmonised accessibility obligations introduced under the European Accessibility Act and implemented in Poland through the Act on Ensuring Accessibility Requirements for Certain Products and Services by Economic Operators.

The objective is to ensure that selected products and services are accessible not only to persons with disabilities and elderly users, but also to other individuals experiencing functional limitations – including, for example, persons with temporary impairments, pregnant women or people travelling with luggage.

The new rules apply to both digital and physical service environments.

Who is affected by the regulations? List of products and services covered by the obligations

The scope of the new regulations includes a broad range of consumer-facing offerings. In particular, the accessibility obligations apply to:

• general-purpose computers and operating systems,
• smartphones, e-readers and other electronic devices,
• ATMs, ticketing machines, check-in machines and similar self-service terminals,
• websites and mobile applications used for online commerce, banking, transport or media access,
• electronic banking, payment interfaces and e-book platforms.

These requirements apply to all relevant products placed on the market or services provided to consumers from 28 June 2025 onwards.

Who must comply with the new requirements? Not just manufacturers

The rules apply to manufacturers, importers, distributors and service providers operating in the EU. All entities placing covered products or services on the market are in general responsible for ensuring compliance.

An exception applies to microenterprises providing services, defined as businesses with fewer than 10 employees and annual turnover or balance sheet total not exceeding EUR 2 million.

What does “accessibility” mean in practice? New functional requirements

The new legal framework does not prescribe specific technologies. Instead, it introduces functional accessibility requirements that must be met throughout the lifecycle of a product or service. These include:

• ensuring that information about services is clear, understandable and perceivable for users with various disabilities,
• making essential functionalities accessible via multiple sensory channels, where applicable,
• enabling interoperability with assistive technologies,
• providing accessible customer support and documentation,
• making available public information about how services meet accessibility standards.

Businesses must actively evaluate compliance and adapt their processes to maintain conformity over time.

Who will monitor compliance?

National supervisory authorities, including market regulators and customs authorities, will be responsible for enforcement. Their powers include:

• conducting inspections and requesting documentation,
• ordering modifications or withdrawal of non-compliant offerings,
• imposing administrative penalties, including financial fines calculated as a percentage of the company’s turnover.

Non-compliance may also expose businesses to reputational risks, particularly if deficiencies are raised through complaints or become subject to regulatory scrutiny.

Which products and services are excluded?

Products placed on the market before 28 June 2025 are not subject to the new accessibility requirements. However, services provided before that date may continue to be delivered in their original form until 28 June 2030, even if they involve the use of non-compliant products.

Self-service terminals introduced before the effective date may remain in operation for the same type of service for up to 20 years from the start of their use, provided they remain economically viable.

Recommended next steps for business operators

To ensure compliance, businesses should initiate preparatory measures, including:

• reviewing the accessibility of current websites, mobile apps and service platforms,
• updating development and procurement procedures to address new accessibility obligations,
• training relevant staff on legal and operational requirements,
• implementing internal monitoring and documentation processes.

Accessibility as a legal obligation, not a choice

Accessibility is no longer a technical or design consideration – it is a binding regulatory standard. Failure to comply may result in operational disruption, enforcement action and loss of market access. At the same time, early adaptation can enhance customer experience, broaden the user base, and strengthen a company’s position in regulated sectors.

Would you like support in assessing the impact of the new framework on your operations? Our regulatory and commercial law team advise clients across industries on implementing accessibility obligations.