Slovenia Accessibility Laws: ZDSMA and ZDPSI

What are the main accessibility laws that apply in Slovenia?

Two national laws govern digital accessibility in Slovenia. They cover different organizations.

Web and Mobile Applications Accessibility Act (ZDSMA)

In force since 2018. It transposes EU Directive 2016/2102 and applies to public sector websites and mobile apps.

Act on Accessibility of Products and Services for Persons with Disabilities (ZDPSI)

In force since 28 June 2025. It transposes the European Accessibility Act (Directive (EU) 2019/882) and extends accessibility obligations to private businesses for the first time.

The shared technical standard

Both laws point to the same benchmark: WCAG 2.1 at level AA, incorporated into the European standard EN 301 549.

That shared standard matters in practice. A website built to meet ZDSMA's public-sector requirements is largely already aligned with what ZDPSI expects from a comparable private-sector service.

Where the two laws diverge

ZDSMA and ZDPSI differ in scope and enforcement.

ZDSMA is overseen by the Inspectorate of the Republic of Slovenia for Information Society, under the Ministry of Digital Transformation. ZDPSI falls under the Market Inspectorate (TIRS).

A public-facing government service deals with one authority. A private company selling regulated products or services deals with the other.

Who must comply with Slovenia's accessibility laws?

Public sector bodies

State authorities, municipalities and public institutions are bound directly. There's no size threshold or exemption. If a body is part of the public sector, its websites and apps fall under the law.

Private businesses in scope

Manufacturers, importers, distributors and service providers must meet ZDPSI once their product or service falls into a regulated category and reaches the Slovenian market.

Micro-enterprises providing services

Slovenia exempts micro-enterprises acting as service providers. A very small business offering an online booking service isn't bound the way a larger competitor is.

The exemption doesn't extend to manufacturers, importers or distributors of physical products. They stay in scope regardless of size.

Foreign companies selling into Slovenia

A business based outside Slovenia, or outside the EU, is still subject to ZDPSI if it places a covered product or service in front of Slovenian consumers. Where the customer is located determines scope, not where the company is incorporated.

Which digital products and services must meet the requirements?

ZDPSI lists specific categories. It doesn't regulate "digital accessibility" as a general concept. Only products and services on this list carry a legal obligation.

• E-commerce websites and apps — browsing, checkout and account management all need to work with a screen reader or keyboard-only navigation.
• Consumer banking services — online banking, ATMs and related interfaces, covering everyday actions like transfers and balance checks.
• Electronic communications services — the apps and portals telecom and internet providers use for account management and support.
• Audiovisual media services — platforms providing access to TV and video-on-demand content, such as a broadcaster's streaming app.
• E-books and their reading software — both the file format and the reading application need to support assistive technology.
• Self-service terminals — ATMs, ticketing machines and check-in kiosks, where the physical interface has to stay operable without relying on vision or fine motor control.
• Passenger transport information and ticketing — websites, apps and electronic ticketing for air, bus, rail and water transport. Urban, suburban and regional transport carry lighter obligations.
• Access to the emergency number 112 — an emergency call has to be answerable and understandable regardless of the caller's disability. Slovenia has until 2027 to fully implement this requirement.

A product or service outside this list — a general marketing website with no e-commerce, banking or transport function — isn't directly regulated by ZDPSI. Following WCAG on it still remains good practice.

What accessibility requirements must organizations meet?

Both ZDSMA and ZDPSI rest on the same four WCAG principles. Content has to be perceivable, operable, understandable and robust.

In practice, that means sufficient color contrast, full keyboard operability, meaningful alt text, video captions, and markup that assistive technology can interpret reliably.

How the two laws differ in depth

The two laws differ in how granular their technical requirements get.

ZDSMA applies WCAG largely as written, since a website is a website regardless of who runs it. ZDPSI sets out requirements tailored to each regulated category instead.

A self-service terminal needs a headphone jack and tactile controls in a way a banking website doesn't. So EN 301 549 breaks its requirements down by product and service type, rather than applying one flat checklist everywhere.

Accessibility statement

An accessibility statement is a published document. It describes how well a website or app conforms to the required standard, and what isn't yet compliant.

Under ZDSMA, public sector bodies must publish one. It has to cover the entire site, not just selected pages.

A compliant statement declares a conformance status — fully compliant, partially compliant or non-compliant. It also lists specific content that falls short, along with the reason.

Common reasons include disproportionate burden, where fixing certain legacy content would cost more than the benefit justifies, or content that falls outside the law's scope, like documents aimed at a narrow professional audience.

The statement also needs a way for users to report accessibility barriers. Publishing a list of known gaps is only useful if there's a channel for reporting the ones that weren't caught.

How can organizations achieve compliance?

Compliance isn't a single action. It's a sequence of three connected phases. Skipping or reordering them tends to produce accessibility work that looks complete on paper but doesn't hold up when a real user relies on it.

Accessibility audit

An audit establishes where an organization actually stands against WCAG 2.1 AA, before any fixing happens.

A blend of automated scanning and manual testing works best. Automated tools catch structural issues quickly across many pages — missing labels, contrast failures. They can't judge whether a heading structure makes logical sense, or whether a screen reader user can complete a checkout flow.

Remediation

Not every issue gets fixed on the same timeline. The deciding factor is impact on a real user, not how an issue looks on a spreadsheet.

An issue that blocks a core task entirely — a checkout button a keyboard user can't reach — needs fixing before the next release. An issue with a workaround can move into a regular sprint. Purely cosmetic gaps get logged and batched.

Monitoring

Accessibility compliance has no finish line. New content, new features and design changes keep reopening the question of conformance.

What restarts the cycle is rarely a calendar date. It's a specific trigger — a new feature shipping, a design system component being updated, or WCAG itself moving to a new version.

State what the audit actually covered

An audit should state its own coverage. A report that tested a representative sample of page templates needs to say so explicitly, rather than implying every page was checked.

A compliance decision based on an overstated audit is a decision made on bad information.

Treating a single completed audit as a permanent achievement is the most common reason organizations end up out of compliance again within a year of passing one. A product that passed its last audit can fail the next one after a single unreviewed template change.

What are the penalties for non-compliance?

Penalties differ depending on which law applies and which authority is enforcing it. ZDSMA and ZDPSI carry separate sanction regimes. Under ZDPSI, the fine varies by whether it's a product or a service, and by the type and size of the organization.

Products (ZDPSI Art. 34)

• €3,000–€40,000 — manufacturer, importer or authorized representative, as a legal entity.
• €2,000–€15,000 — sole trader in the same role.
• €1,200–€4,000 — the responsible person at a legal entity.
• €1,200–€3,000 — distributor, as a legal entity.

Services: e-commerce and banking (ZDPSI Art. 39–40)

• €500–€5,000 — legal entity.
• €1,000–€10,000 — medium or large company.
• €250–€2,500 — sole trader (e-commerce).
• €50–€250 — responsible person.

Who enforces it?

The Market Inspectorate (TIRS) enforces products and e-commerce. AKOS has authority over electronic communications, audiovisual media and e-books. Banka Slovenije and other financial authorities are involved for banking.

Costs beyond the fine

An enforcement authority can order non-compliance to be corrected. For products, it can restrict the product's placement on the market, recall it or have it withdrawn from sale. That's often more disruptive to a business than the fine itself.

A wider EU trend

Slovenia's approach is part of a wider EU trend. In France, disability rights associations filed suit against four major retailers in November 2025. The case is before the Paris judicial court, on grounds that the retailers' online shopping services are inaccessible.

How do these laws improve accessibility for persons with disabilities?

Slovenia reports that 13.1% of its population lives with some form of disability. Accessibility law converts what used to be a voluntary design choice into an enforceable baseline.

Before ZDSMA and ZDPSI, whether a government website or a banking app worked with a screen reader depended entirely on whether that organization chose to prioritize it. Now a defined set of digital products and services has to meet that baseline regardless of individual company priorities.

That's a meaningfully different guarantee for someone who depends on assistive technology to complete an everyday task.

One improvement, two sectors

The two-law structure means the improvement isn't confined to one sector.

ZDSMA already gave persons with disabilities working access to government services. ZDPSI extends that same expectation to private-sector services people rely on just as often — online banking, online shopping, e-books and transport bookings.

Which accessibility features support persons with disabilities?

• Screen-reader-compatible markup — correct use of headings, labels and semantic HTML lets a screen reader announce a page's structure and content accurately, instead of reading it as one undifferentiated block of text.
• Full keyboard operability — every interactive element has to be reachable and usable without a mouse. This matters for users who navigate via keyboard, switch device or voice control.
• Captions and transcripts — these give deaf and hard-of-hearing users access to the same information a hearing user gets from the audio track.
• Sufficient color contrast — text and interface elements need enough contrast against their background to stay legible for users with low vision or color blindness.
• Plain, predictable language and navigation — consistent menus and clear instructions reduce cognitive load for users with cognitive or learning disabilities, and for anyone using unfamiliar assistive technology.
• Accessible self-service terminals — tactile buttons, headphone jacks for audio guidance and screen readability at a range of viewing angles let users operate ATMs and ticketing machines independently.
• Sign language access for emergency and customer communication — where required, this ensures Deaf users aren't dependent on a third party to relay urgent or time-sensitive information.

Each feature addresses a different barrier. That's why accessibility compliance gets evaluated criterion by criterion, not as a single pass/fail judgment. A product can support keyboard navigation well while still failing users who depend on captions. Both gaps need separate attention to close.