New accessibility requirements

• Consumer general purpose computer hardware systems and operating systems for those hardware systems
  • e.g. personal computers, in particular desktops, notebooks, smartphones and tablets
• Self-service payment terminals
• Self-service automated teller machines, ticketing machines and check-in machines
• Certain interactive self-service terminals providing information in passenger transport that can be controlled by the passengers themselves
• Consumer terminal equipment with interactive computing capability, used for electronic communications services
  • e.g. smartphones, but also equipment such as routers or modems
• Consumer terminal equipment with interactive computing capability, used for accessing audiovisual media services
  • e.g. set-top boxes and smart televisions
• E-readers
• Products used for providing the services referred to in section 3, subsection 1, paragraph 4 and chapter 3a of the Act on the Provision of Digital Services 
  • E.g. if a service provider offers its digital service through a self-service terminal, the self-service terminal (product) must comply with the accessibility requirements.
  • In turn, the digital service itself must comply with the requirements of chapter 3a of the Act on the Provision of Digital Services. E.g. these requirements impose the obligation to explain how the service works with the product.

The accessibility requirements for products apply to product manufacturers, importers and distributors. The products must meet e.g. the following requirements: 

• products must be designed and produced in such a way as to maximise their use by persons with disabilities
• the information on the use of the product and on their accessibility features must be accessible 
• the product’s user interface must allow persons with disabilities to access, operate, understand and control it easily 
• the packaging of the product must be made accessible and the instructions for the packaging, use, installation, maintenance and disposal of the product must be easily accessible
• an EU declaration of conformity must be drawn up and the product must have the CE marking. 

If a product complies with a standard or the technical specifications of the European Commission, it must be considered compliant with the above requirements.

• Electronic communications services, such as voice and text message services, email and instant messaging services
• Services providing access to audiovisual content services, such as electronic programme guides, the applications of set-top boxes and smart televisions, as well as their websites and mobile applications
• Certain elements of air, bus, rail and waterborne passenger transport services, such as websites, mobile device based services, including mobile applications, electronic ticketing services and electronic tickets
• Digital banking services for consumers. (Some of the digital services of banks have already been covered by the Act on the Provision of Digital Services.) 
• E-books and dedicated software 
• E-commerce services

Read more about the new digital services and their additional requirements:

Electronic communication services, such as the traditional voice, text message and broadband services and services providing access to audiovisual content services, must comply with the general accessibility requirements demanding that service providers must: 

• ensure that procedures are in place so that the provision of services remains in conformity with the applicable accessibility requirements 
• provide information about the functioning of the service, and where products are used in the provision of the service, its link to these products as well as information about their accessibility characteristics and interoperability with assistive devices and facilities 
• ensure that its support services provide information on the accessibility of the service and its compatibility with assistive technologies in accessible modes of communication.

Interpersonal electronic communications services must also comply with additional accessibility requirements demanding that the service must:

• provide real-time text in addition to voice communication
• provide total conversation services where video is provided in addition to voice communication. Total conversation services, i.e. synchronised real-time text, voice and video, are required when the service provider offers video in addition to voice communications. 

Services providing access to audiovisual content services must comply with the following additional requirements demanding that the service must:

• provide electronic programme guides (EPGs) which, along with the information provided, are perceivable, operable, understandable and robust 
• provide information about the availability of accessibility
• ensure that the accessibility components of the audiovisual content services are fully transmitted with adequate quality for accurate display, and synchronised with sound and video, while allowing for user control of their display and use.

If a service complies with a standard or the technical specifications of the European Commission, it must be considered compliant with the above requirements. 

In so far as the electronic communications service or the service providing access to audiovisual content services are digital services as referred to in the Act on the Provision of Digital Services, i.e. websites or mobile applications, the supervisory authority is Traficom. Traficom supervises the above-mentioned additional accessibility requirements also for these services under the Act on Electronic Communications Services.   

The application and supervise of the new accessibility requirements begins on 28 June 2025. In terms of products, this means that only products meeting the accessibility requirements may be placed on the market after this date. For example, computer hardware systems provided to consumers must comply with the accessibility requirements after this date. Services provided for consumers must also comply with the accessibility requirements after 28 June 2025.

The regulation includes transitional periods within which certain products or agreements on certain services must be brought into conformity with the accessibility requirements.

• According to the transitional provisions, the products within the scope of accessibility requirements used by a service provider to provide a service must be brought into conformity with the act by 28 June 2030.
• A transitional period for self-service equipment within the scope of accessibility requirements (e.g. payment terminals, automated teller machines and check-in machines) specifies that self-service terminals put into service prior to 28 June 2025 must be brought into conformity with the act within 20 years of their entry into use. A service provider may thus use the self-service terminals until the end of their economically useful life, but no longer than 20 years after their entry into use. Self-service terminals are terminal devices used e.g. for checking in or buying a travel ticket and for providing information with the help of interactive self-service terminals

Traficom’s responsibility in the supervision of compliance of accessibility requirements for products is to:

• supervise that accessibility requirements are complied with
• supervise that an economic operator deviating from the accessibility requirements has drawn up a reasoned assessment as required by law 
• publish a list of products that do not meet the accessibility requirements
• evaluate the conformity of a product if it has grounds to assume that the product does not meet the accessibility requirements
• as necessary, call on an economic operator to correct the observed deficiencies in the conformity with accessibility requirements and in the assessment carried out when deviating from the accessibility requirements
• as necessary, issue an order or prohibition in accordance with the Act on the Market Surveillance of Certain Products (1137/2016) if it becomes apparent that a product does not comply with the necessary accessibility requirements
• as necessary, notify the European Commission and the other Member States of the European Union and the European Economic Area of a decision it has made under the Act on the Market Surveillance of Certain Products, when it considers that the non-conformity of the product is not restricted to the national territory of Finland.

Traficom’s particular responsibility in the supervision of services is to:

• supervise and inspect that the services providing access to audiovisual content services as well as electronic communications services meet the accessibility requirements set out in the Act on Electronic Communications Services
• supervise the processing of complaints and reports made under the Act on Electronic Communications Services.

The accessibility requirements are also applied to certain elements of transport services, such as websites and mobile device based services. 

Traficom supervises the accessibility of websites and mobile applications as well as e-commerce services also in the area of transport services and supervises compliance with requirements related to passenger transport accessibility information and information provision.

The Ministry of the Interior supervises compliance with the provisions on answering to the single European emergency number and the accessibility of the number.

The standards required by the European Accessibility Act are prepared in multiple working groups. has initiated the preparation of a total of six harmonised standards, three of which will be revisions of existing standards and three completely new standards. In addition, documents to support the harmonised standards will be prepared.

The subjects of the harmonised standards have been described below.

New standards:

• Non-digital product information
• Support services for products and services
• EN 303 919 Emergency communication and emergency number 112

Standards to be revised:

• EN 301 549 Accessibility requirements for ICT products and services
• EN 17161 Design for all 
• EN 17210 Accessibility and usability of the built environment – functional requirements

The standardisation mandate also proposes the revision of two technical reports related to ensuring the accessibility of public procurements (CEN/CLC/ETSI TR 101551 and 101552). 

The standardisation process has brought forward the need to draw up other documents, such as the ETSI standard ES 204 009 Total Conversation and the technical report TR 104 060 providing for the application of the accessibility requirements for digital television. It is likely that other guidelines or technical reports will also be prepared.

Key accessibility standard

Functional accessibility requirements for information and communications technology products and services are already defined in standard EN 301 549 (Accessibility requirements for ICT products and services) prepared by ETSI. The standard also includes testing and assessment methods for the needs of public procurements in particular. 

The first version of the standard was published in 2014. It is the harmonised standard of Directive (EU) 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies, i.e. the Web Accessibility Directive. The translation of the current version of the standard into Finnish has been started and is expected to be completed in summer 2024. 

Key focus areas of the revision

The structure of the standard will be made clearer. The actual revision will cover the following:

1. Alignment of the standard with WCAG 2.2. (WCAG, short for Web Content Accessibility Guidelines, is a central and widely applied guideline for web accessibility.)
2. Addition of general accessibility requirements for services and their adaptation to fit the standard.
3. Adaptation of accessibility requirements for devices to correspond to the scope of application of the European Accessibility Act.
4. Compilation of requirements imposed by total conversation services and real time text on devices and their addition to the standard. 
5. Compilation of requirements imposed by total conversation services and real time text on services and infrastructure and their addition to the standard. 

Importance of the harmonised part of the standard

Harmonised standards are key to demonstrating compliance with all the directives and regulations based on the new approach. Such directives and regulations only lay down so-called essential requirements. The actual implementation of compliant solutions and their verification are based on harmonised standards and technical specifications approved for this purpose. The European Accessibility Act lays down also this presumption of conformity: 

• Products and services which are in conformity with harmonised standards or parts thereof the references of which have been published in the Official Journal of the European Union, shall be presumed to be in conformity with the accessibility requirements of this Directive in so far as those standards or parts thereof cover those requirements.

Standard EN 301 549 will include annexes ZA and ZB to describe the requirements of the Web Accessibility Directive and the European Accessibility Act and detail which sections of the standard correspond to the requirements. Product manufacturers will need to prepare declarations of conformity in which they declare that they meet the requirements of the standard – at least the requirements detailed in the new annex (Annex ZB). Based on such a declaration, the product in question is presumed to be in conformity with the accessibility requirements of the European Accessibility Act. Correspondingly, service providers will need to ensure that their services are in conformance with the standard by complying with the requirements of annex ZA and prepare accessibility statements for them.

Harmonised standards often include a lot more than the harmonised part designated in the standardisation mandate issued by the European Commission. To describe this harmonised part, standards include an annex – usually Annex Z, which details which sections of the standard are included in the harmonised part and which requirements of the relevant directive they correspond to. In some cases, the annex also details the procedures for demonstrating conformance.

Timetable 

• The revision of standard EN 301 549 was started on 1 February 2023 with the planning of the work and application for funding. 
• The first draft of the standard was prepared on 1 February 2024. 
• The final draft is planned to be completed on 30 April 2025.
• ETSI intends to publish the standard as a European standard on 15 February 2026, following a voting and approval process. 
• The publication of the reference of the standard in the Official Journal of the European Union is planned to take place on 31 May 2026, at which point the standard will gain the status of a harmonised standard. 
• The schedule for the preparation of other new accessibility standards deviates from the aforementioned schedule.

Although it appears that the harmonised standard will be completed after the application of the requirements of the European Accessibility Act has already begun, there will already be a largely final draft of the standard available at the end of 2024.

More information on telecommunications standardisation https://static.traficom.fi/en/communications/communications-networks/traficom-coordinates-telecommunications-standardisation