The legislative amendments required by the EU Accessibility Directive must be adhered to in online stores from 28 June 2025. Do the changes affect you, how do you meet the legal requirements, and what could be the consequences of non-compliance? And are you unknowingly an online retailer? An accessibility expert responds.

In this article, Crasman's accessibility expert Tiina Heikkilä answers the most frequently asked questions and summarises important information on how the Digital Services Act, which regulates accessibility, defines the concept of an online store.

Which services are affected by the legislative amendment?

The following consumer-oriented services were added to the scope of the Digital Services Act as part of the legislative changes:

• online stores

• e-books

• certain transport and banking services

• services providing access to audiovisual content

• communication services.

Are you unknowingly an online retailer?

Some online stores are easy to recognise: the user can add products to their cart and pay for their purchases online.

However, the definition under the Digital Services Act is broader: a service where a customer can enter into distance selling contracts under consumer protection law is an online store. For example, booking a hairdresser, car service, or hotel room via an online service is considered e-commerce if an agreement is made between the customer and the company at the time of booking for the purchase of a product or service. 

It is irrelevant whether the product or service is paid for online or later in person.

If you need a more precise definition of how your online service relates to the law, you can seek advice directly from the supervisory authority, Traficom. 

My recommendation is that businesses in grey areas should also be proactive on this issue, as accessibility benefits both service users and business operations.

What are the exceptions to the application of the law?

The Digital Services Act does not obligate micro-enterprises. A business is considered a micro-enterprise if it has fewer than ten employees and an annual turnover or balance sheet total of no more than two million euros.

Please note that the definition applies to the entire organisation's turnover, not just the share of the online store.

What must an online retailer do to comply with the accessibility law?

• The service must meet the accessibility requirements set by the law.

• The service must have an accessibility statement that describes the state of accessibility of the service.

• The user must be able to provide feedback on accessibility to the operator, and feedback must be answered within 14 days.

• The online store must provide information on the accessibility and ease of access of services and products if the manufacturer or importer has provided this information.

The first step towards meeting the requirements is assessing the accessibility of the online store.

How can you determine the level of accessibility of your online service?

Assessing accessibility requires expertise. By conducting an accessibility audit of your service, you receive a comprehensive report on detected shortcomings and advice on how to address them. Initial steps can also be taken with more limited checks.

At Crasman, we conduct checks ourselves and with our partners, according to your needs.

Almost all services have some areas for improvement. After evaluation, shortcomings can be systematically addressed. Issues that cannot be immediately corrected are documented in the accessibility statement.

Ensuring and maintaining accessibility requires attention in all service development and content production. Key factors are training your own staff, competent partners, and regular quality assurance.

What if the accessibility requirements are not met?

Checking accessibility and preparing a statement is a good start, but according to the law, deficiencies must also be corrected.

Services falling under the law have an obligation to report to the supervisory authority on the types of deficiencies in meeting the requirements and how these deficiencies will be corrected. There is not yet guidance on how to make this notification.

Derogation from the requirements can be made by invoking an unreasonable burden, but this is subject to strict conditions. The existence of the burden must be reassessed at least every five years.

What if someone files a complaint about the service?

The supervisory authority, Traficom, handles complaints and also conducts enforcement activities independently. 

Traficom has the right to request a report from the operator on compliance with accessibility requirements. It can require the operator to correct deficiencies within a set timeframe and, if necessary, bring the service in question under supervision.

Traficom can also impose a penalty to enforce the order.

Still have some queries?

Further information on the Digital Services Act and its requirements can be found on the site
saavutettavuusvaatimukset.fi.