Sweden accessibility laws: Act 2023:254, DOS Act & the EAA

Which digital accessibility laws apply in Sweden?

Three laws determine digital accessibility obligations, and each covers a different slice of the economy. The Act on the Accessibility of Certain Products and Services (2023:254) applies to private companies selling specific products and services covered by the EAA. The Discrimination Act applies broadly, across public and private sectors, whenever inadequate accessibility disadvantages someone with a disability. The Web Accessibility Directive, implemented through the Act on Accessibility to Digital Public Services (2018:1937), applies to public sector bodies specifically.

None of the three replaces the others. A public university's website answers to the DOS Act because it's a public body; a private bank operating in Sweden answers to the 2023:254 Act because banking is one of the sectors the EAA covers. Which category an organization falls into determines which rulebook, deadline, and regulator apply.

What is the Act on the Accessibility of Certain Products and Services (2023:254)?

Lag 2023:254 is Sweden's transposition of the EAA into national law, decided by the Swedish Parliament on 11 May 2023. It sets requirements for a defined list of products and services — banking, e-commerce, telecom, passenger transport, e-books, and self-service terminals like ATMs and ticketing machines.

The Act applies from 28 June 2025, and that deadline applies to existing offerings, not only new ones — a service that already existed still has to meet the requirements from that date.

One practical exception: transitional provisions. Service contracts already running when the law took effect can continue unchanged for up to five years. Self-service terminals already in use, like ATMs, get up to twenty years before they need to be replaced with accessible equipment.

How does the Discrimination Act protect accessibility rights?

The Discrimination Act (2008:567) treats "bristande tillgänglighet" — inadequate accessibility — as a distinct form of discrimination, added to the law in 2015 following Sweden's commitment to the UN Convention on the Rights of Persons with Disabilities.

A person with a disability is discriminated against when an organization fails to take reasonable accessibility measures that would put them in a comparable position to someone without that disability. What counts as "reasonable" is assessed against existing legal requirements and practical factors like cost and the nature of the relationship.

This is broader than a digital-accessibility rule — it applies across employment, education, healthcare, and goods and services, with a few carve-outs. It functions as a backstop: even where no sector-specific law applies directly, failing to provide reasonable accessibility can still amount to unlawful discrimination. The Equality Ombudsman (DO) oversees this part of the law.

How does the Web Accessibility Directive apply in Sweden?

The EU's Web Accessibility Directive (2016/2102) applies through the Act on Accessibility to Digital Public Services (2018:1937), the "DOS Act," in effect since 1 January 2019 — several years ahead of the EAA's 2025 private-sector deadline.

The DOS Act's scope is narrower than the EAA's: it applies to public sector bodies specifically, requiring websites, mobile apps, and digital documents to meet standards equivalent to WCAG 2.1 AA, referenced through EN 301 549. A public authority has already been operating under binding requirements longer than any private company subject to the 2023 law.

What is the EAA, and how does it apply in Sweden?

The European Accessibility Act (Directive (EU) 2019/882), adopted April 2019, harmonizes accessibility requirements for a defined set of products and services across all member states — less about accessibility for its own sake and more about market function, removing the situation where each country sets its own rules.

In Sweden, the EAA doesn't operate as a directly applicable EU regulation — it's implemented through Act 2023:254, covering computers and operating systems, ATMs and ticketing/check-in machines, smartphones, TV equipment, telephony, audiovisual media, passenger transport, banking, e-books, and e-commerce.

The enforcement date is the same across the EU and EEA: 28 June 2025 — deliberate consistency that lets a multi-country business work toward one deadline. One scope limit: the EAA applies to business-to-consumer services; purely B2B services fall outside it.

Who must comply, and who's exempt

• Public sector bodies — bound by the DOS Act since January 2019, regardless of size
• Banks, e-commerce, transport, telecom/audiovisual media providers — covered under Act 2023:254 because their sectors are named explicitly in the EAA
• Manufacturers, importers, distributors of covered hardware — computers, smartphones, self-service terminals, at every point in the supply chain
• Any organization named in a discrimination complaint — the Discrimination Act's inadequate-accessibility provision reaches beyond EAA/DOS Act scope

Exemptions: microenterprises providing services (fewer than 10 employees, ≤€2M turnover/balance sheet) are exempt from the EAA's service requirements — but not for products, and the exemption disappears immediately once thresholds are crossed. Disproportionate burden and fundamental alteration claims are available to any size of operator but must be documented against Annex VI criteria, not simply asserted. Pre-recorded media published before 28 June 2025 is also exempt, and an organization that received accessibility-specific funding can't claim disproportionate burden for that same work.

Standards and requirements

Two technical standards do most of the work of turning Sweden's laws into something testable: WCAG 2.1 AA and EN 301 549.

WCAG 2.1 AA covers websites, web apps, and increasingly mobile apps well, but doesn't on its own address hardware, standalone software, or physical terminals like ATMs — that gap is what EN 301 549 exists to close. A vendor's WCAG conformance claim alone doesn't tell you whether their physical kiosk or standalone software meets the law; EN 301 549 conformance is what covers those non-web components, worth asking a vendor for specifically.

• Perceivable — information presented through a sense people can actually use; images need text alternatives, video needs captions
• Operable — every function works through more than a mouse; keyboard access and enough time for timed actions
• Understandable — content and behavior are predictable and consistent; clear error messages, consistent navigation
• Robust — code is interpretable reliably by current and future assistive technology
• An accessibility statement — required for DOS Act-covered bodies; the EAA's private-sector framework carries its own information obligations
• A feedback mechanism — a way to report barriers or request an accessible format, specifically required for public sector bodies

Who enforces accessibility laws in Sweden

Enforcement splits across several regulators depending on the law and sector. DIGG (the Swedish Agency for Digital Government) enforces the DOS Act. Act 2023:254 is monitored by the Swedish Post and Telecom Authority (PTS), the Swedish Consumer Agency (Konsumentverket), and the Transport Agency (Transportstyrelsen), each surveilling its own sector. The Discrimination Act is enforced separately by the Equality Ombudsman (DO).

DIGG monitors compliance through manual reviews of selected public sector webpages, apps, and e-services rather than relying only on automated scans. When a review finds deficiencies, DIGG notifies the organization and asks for a remedy; if unresolved, DIGG can escalate to legal action, including an injunction. In 2023, DIGG reported considering fines against three public bodies — which would have been the first since the law took effect in 2019.

How to comply

• Identify which law applies first. A public body, a private bank, and a small retailer each answer to a different combination of the three laws.
• Audit against EN 301 549, not WCAG alone. An audit scoped to WCAG alone can miss gaps in documentation, support services, and product hardware.
• Check whether the microenterprise exemption genuinely applies. It only covers services, and it ends once size thresholds are crossed.
• Document any exemption before relying on it. An undocumented assumption isn't a defense.
• Publish your accessibility statement if you're a public body. If you're covered by the EAA, explain how your service meets the requirements. Either way, provide a feedback channel.
• Plan for transition periods, not just the 2025 deadline. Existing products and contracts have a transition period running until 2030.

SEK 10,000–10,000,000

Administrative fine range under Section 38 of Act 2023:254. The amount is set according to the seriousness and scope of the violation. No fine is imposed for minor cases.

Administrative order backed by a fine threat (DIGG)

If a public body doesn't remedy deficiencies within a reasonable period, DIGG can issue an administrative order. That order can be backed by the threat of a fine.

Who enforces it?

PTS enforces products and electronic communications, banking, and e-commerce services. Konsumentverket and Transportstyrelsen have authority over passenger transport, Mediemyndigheten over audiovisual media, and Myndigheten för tillgängliga medier over e-books. Discrimination claims can be raised with DO independently of EAA or DOS Act coverage.

Frequently asked questions

Does Sweden accessibility law apply to companies based outside Sweden?

Yes, where a company places covered products on the Swedish market or provides covered services to consumers in Sweden. The EAA framework applies based on where products and services reach consumers, not where the company is headquartered.

Is WCAG 2.1 AA a legal requirement in Sweden, or just a technical reference?

It functions as a legal requirement in practice because Swedish law points to it directly — the DOS Act and the standards referenced under Act 2023:254 both treat WCAG 2.1 AA, via EN 301 549, as the benchmark.

Does the microenterprise exemption mean a small business has no accessibility obligations at all?

No. The exemption only removes obligations under the EAA's service requirements, and a small business can still fall under the Discrimination Act's general prohibition, or under product-specific requirements if it manufactures covered hardware.

Are public sector organizations subject to the same 2025 deadline as private companies?

No. Public sector bodies have been subject to the DOS Act since 2019 — well before Act 2023:254's 2025 deadline, which applies to the private-sector products and services covered by the EAA.

Who should an organization contact if it's unsure which Swedish accessibility law applies?

The relevant sector regulator is the most direct starting point — DIGG for public sector digital services, or PTS, Konsumentverket, or Transportstyrelsen depending on the sector for organizations covered by Act 2023:254.