European Accessibility Act Compliance in Estonia (LPS)
The European Accessibility Act is transposed in Estonia by the Toodete ja teenuste ligipääsetavuse seadus (Products and Services Accessibility Act), passed on 30 May 2022 and in force since 28 June 2022. Its requirements apply to products placed on the market and services provided from 28 June 2025. The covered services include e-commerce, financial services, e-books, electronic communications, parts of passenger transport, and services giving access to audiovisual media. This is the private-sector regime. Public bodies are covered separately.
Scan your site freeWho has to comply in Estonia
The Act covers businesses that place covered products on the market in Estonia or provide covered services to consumers there, wherever the business itself is established. The service categories listed in section 2(3) are e-commerce services, electronic communications services, e-books and dedicated software, financial services, parts of air, bus, rail and waterborne passenger transport services such as websites, mobile device-based services, electronic tickets and self-service terminals, and services providing access to audiovisual media services. Section 3(4) defines a microenterprise as one that employs fewer than ten persons and has an annual turnover or annual balance sheet total not exceeding two million euros. Both limbs have to be met. Section 2(11) disapplies the Act to microenterprises that provide services. Products are not exempt. Public bodies fall under a separate regime, the Avaliku teabe seadus (Public Information Act) and the accessibility regulation made under it, which transposes Directive (EU) 2016/2102 rather than the EAA.
The deadlines that matter
Riigikogu passes the Toodete ja teenuste ligipääsetavuse seadus, published as RT I, 15.06.2022, 1
The Minister of Social Protection adopts regulation no 45 on functional accessibility requirements and regulation no 46 on disproportionate burden
The Act and both regulations enter into force, on the EU transposition deadline
The Commission sends letters of formal notice to 24 member states for not communicating full transposition. Estonia is not among them
The Commission opens infringement procedure INFR(2023)2013 against Estonia, alongside Denmark and Italy, for not fully transposing the Directive
Requirements start to apply to products placed on the market and services provided, under section 22(1)
End of the transition for service contracts signed before 28 June 2025 and for products already used to provide a service
Prove your Estonia compliance
Conforma tests your site against WCAG 2.2 AA and EN 301 549, the standard the Tarbijakaitse ja Tehnilise Järelevalve Amet points service providers to under the Toodete ja teenuste ligipääsetavuse seadus. It drafts the information explaining conformity that section 11(2) requires a service provider to prepare and make available to the public, and it keeps a dated record of the issues found and fixed. Two limits are worth stating plainly. Automated testing covers only part of the standard, so the record is evidence of testing rather than a finding of compliance. Section 11(2) also asks for that information in accessible oral form, which you have to produce yourself.
Estonia EAA questions, answered
Which businesses does the Estonian Act apply to, and from when?
The Toodete ja teenuste ligipääsetavuse seadus entered into force on 28 June 2022, but section 22(1) applies its requirements to products placed on the market and services provided from 28 June 2025. Service contracts signed before that date may run unchanged until they expire, and no later than 28 June 2030. Products already used to provide a service may also keep being used until 28 June 2030. Self-service terminals put into use before 28 June 2025 may run to the end of their economic life, and no longer than 20 years from first use.
Is my small business exempt?
Section 2(11) disapplies the Act to service providers that are microenterprises. Section 3(4) sets the test: fewer than ten employees and an annual turnover or annual balance sheet total of no more than two million euros. Both limbs must be met. The exemption covers services only. A microenterprise that manufactures, imports or distributes a covered product is still bound, with lighter documentation duties.
Which accessibility standard applies in Estonia?
The Act does not name a standard. Section 15 presumes conformity where a product or service has been assessed against harmonised standards or technical specifications covering the accessibility requirements, and regulation no 45 of 8 June 2022 sets functional requirements without naming one. In practice that standard is EN 301 549, which the Tarbijakaitse ja Tehnilise Järelevalve Amet points businesses to in its guidance. That guidance pins no version, and it says a new version of the standard is in preparation. There is no separate Estonian web standard for businesses.
Who enforces the Act and what are the penalties?
The Tarbijakaitse ja Tehnilise Järelevalve Amet supervises compliance under section 16 and conducts misdemeanour proceedings under section 21. It can require corrective measures, restrict or prohibit a service, or demand withdrawal from the market. Section 19 sets the upper limit of penalty payments for ignoring a precept at 10,000 euros. Section 20 punishes providing a non-conforming service with up to 100 fine units, currently 800 euros, or up to 20,000 euros for a legal person. Figures of 5,000 to 32,000 euros circulate on vendor sites. They are not in the Act.
This page is a plain-English summary, not legal advice. Check the cited national law for specifics.
Common fixes to check
Most sites fail the same WCAG checks first. Each guide has a plain-language fix and a before/after snippet you can copy.
See where your site stands in seconds
A free scan against WCAG 2.2 AA, a plain-language fix for every issue, and a Estonia-specific accessibility statement when you need one.