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European Accessibility Act Compliance in Greece (Law 4994/2022)

Greece transposed the European Accessibility Act through Νόμος 4994/2022 (Law 4994/2022), published in the Government Gazette ΦΕΚ Α' 215 on 18 November 2022, close to five months after the EU deadline. Article 46(2) held its substantive Part B back until 28 June 2025. That Part covers e-commerce, consumer banking, e-books, passenger transport ticketing and travel information, electronic communications and access to audiovisual media services, together with a defined list of consumer hardware products.

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National law Νόμος 4994/2022, «Ενσωμάτωση της Οδηγίας (ΕΕ) 2019/882 του Ευρωπαϊκού Κοινοβουλίου και του Συμβουλίου της 17ης Απριλίου 2019 σχετικά με τις απαιτήσεις προσβασιμότητας προϊόντων και υπηρεσιών και άλλες επείγουσες διατάξεις για την ενίσχυση της ανάπτυξης», published in ΦΕΚ Α' 215 of 18 November 2022 (Law 4994/2022, transposing Directive (EU) 2019/882). Articles 2 to 28 carry the transposition, and article 46(2) sets 28 June 2025 as the date that Part applies from. Transposition was late and, on the Commission's assessment, incomplete. The deadline was 28 June 2022, a letter of formal notice followed on 19 July 2022, and on 12 March 2025 the Commission issued a reasoned opinion in case INFR(2022)0297 over remaining gaps. Νόμος 5218/2025 (ΦΕΚ Α' 125 of 14 July 2025) then amended the law: article 67 added article 6Α on free movement, corresponding to article 6 of the Directive, article 68 added article 25Α on collective action by disability associations and public bodies, corresponding to article 29, and article 69 added to article 26(2) a right of appeal to the next authority up within 30 days of a sanction decision. Whether the Commission now treats the transposition as complete could not be confirmed from a primary source.
Web standard The applicable standard is EN 301 549, reached indirectly. Law 4994/2022 does not name EN 301 549 anywhere in its text. Article 15, headed Τεκμήριο συμμόρφωσης, gives products and services that conform to harmonised standards published in the Official Journal of the European Union a presumption of conformity with the accessibility requirements, and for ICT that standard is EN 301 549, which carries the WCAG success criteria. Article 25(3) uses the same route for the separate presumption in article 25(2) that accessibility obligations in other Union acts are met. Greece has no national web accessibility standard of its own for the private sector. The public sector law is more explicit, since article 41 of Νόμος 4727/2020 names ΕΝ 301 549 V1.1.2 (2015-04) directly.
Enforcement Market surveillance for products is split by product type in article 19(2). The Διεύθυνση Ασφάλειας και Συμμόρφωσης Βιομηχανικών Προϊόντων of the Γενική Γραμματεία Βιομηχανίας at the Υπουργείο Ανάπτυξης και Επενδύσεων (Ministry of Development and Investment) covers consumer computing hardware and operating systems, e-readers, payment terminals and cash machines. The Εθνική Επιτροπή Τηλεπικοινωνιών και Ταχυδρομείων (ΕΕΤΤ, Hellenic Telecommunications and Post Commission) covers consumer terminal equipment for electronic communications. The Γενική Γραμματεία Μεταφορών (General Secretariat for Transport) covers ticketing, validation and interactive information terminals, and the Εθνικό Συμβούλιο Ραδιοτηλεόρασης (ΕΣΡ, National Council for Radio and Television) covers terminal equipment used to access audiovisual media. Both act jointly with that industrial products directorate. For services, article 22(2) names one authority, the ΕΕΤΤ, and only for electronic communications services. The law names no monitoring authority for e-commerce, consumer banking or e-book services. Under article 27(1) the Εθνική Αρχή Προσβασιμότητας (National Accessibility Authority) only advises on the implementing decision. Complaints route: article 19(3) requires product inspection teams to be formed under the annual plan and after a complaint; general consumer complaints go to the Γενική Γραμματεία Εμπορίου (General Secretariat for Commerce) through the 1520 consumer line, or to the Συνήγορος του Καταναλωτή (Consumer Ombudsman), the independent consumer mediation authority; complaints about public sector websites use article 45 of Νόμος 4727/2020. Penalties as written: article 26 applies administrative sanctions on a proportionality test and lists what a market surveillance authority may do, namely recommend corrective action, seize a product temporarily, and ban its circulation and availability. Article 26 fixes no euro amounts, and since ν. 5218/2025 its paragraph 2 also allows an appeal to the next authority up within 30 days. Article 27(2) delegates the level of the fine for each infringement to a presidential decree, and only for products. No such decree could be found published as at 27 August 2026. Sector penalties run through existing statutes: article 26(4) sends electronic communications services to the ΕΕΤΤ under article 113 of Νόμος 4727/2020, and article 26(5) sends media service providers to the ΕΣΡ under article 36(3) of Νόμος 4779/2021 or article 4 of Νόμος 2328/1995. Figures of up to EUR 100,000 circulate on Greek law firm blogs and vendor pages, and that figure does not appear in article 26.

Who has to comply in Greece

The law applies to businesses that place covered products on the Greek market or provide covered services to consumers in Greece, wherever the business is established. Article 3(2) lists the covered services: electronic communications, services giving access to audiovisual media services, defined elements of air, bus, rail and waterborne passenger transport, consumer banking, e-books, and e-commerce. Article 4(23) defines a πολύ μικρή επιχείρηση, a micro-enterprise, in the same terms as the Directive: fewer than 10 employees and annual turnover of no more than EUR 2 million or an annual balance sheet total of no more than EUR 2 million. Article 5(4) then exempts micro-enterprises that provide services from the service accessibility requirements. The exemption reaches services only. A micro-enterprise that manufactures, imports or distributes a covered product keeps the full product obligations. Public sector websites and mobile apps follow a separate regime under Chapter H of Νόμος 4727/2020, which transposes Directive (EU) 2016/2102, and article 22(3) of Law 4994/2022 routes them there.

The deadlines that matter

28 June 2022

EU deadline for transposing Directive (EU) 2019/882. Greece had not transposed by this date

19 July 2022

Commission letter of formal notice to Greece for failure to notify transposition measures, case INFR(2022)0297

18 November 2022

Νόμος 4994/2022 published in ΦΕΚ Α' 215, transposing Directive (EU) 2019/882

12 March 2025

Commission reasoned opinion in INFR(2022)0297 over remaining transposition gaps in Greek law

28 June 2025

Part B of Law 4994/2022 applies under article 46(2). Products placed on the market and services provided from this date must comply

14 July 2025

Νόμος 5218/2025 (ΦΕΚ Α' 125) adds articles 6Α and 25Α to Law 4994/2022 and amends article 26(2)

28 June 2027

Under article 3(3), the law starts to apply to the handling of emergency communications to and from the single European emergency number 112

28 June 2030

End of the article 28(1) transition for products already lawfully used to provide services before 28 June 2025

WCAG 2.2 AA, EN 301 549

Prove your Greece compliance

Conforma tests your site against WCAG 2.2 AA and EN 301 549, the standard behind the presumption of conformity in article 15 of Νόμος 4994/2022. You get a dated record of every issue found and every fix made, and a draft accessibility statement you can adapt for the Greek market. Automated testing covers part of the criteria and manual checks are still needed, so the report is evidence of testing rather than a finding of compliance.

Greece EAA questions, answered

When did the EAA start applying in Greece, and is there a transition period?

Law 4994/2022 was published on 18 November 2022, and article 46(2) held its substantive Part back until 28 June 2025. Products placed on the market and services provided from that date must comply. Article 28(1) lets providers keep using products they lawfully used before that date until 28 June 2030, and lets service contracts agreed before 28 June 2025 run on unchanged until they expire, for up to five years from that date. Article 28(3) lets self-service terminals already in lawful use before 28 June 2025 stay in service to the end of their economic life, up to 20 years from first use.

Is my small business exempt under the Greek law?

Article 4(23) defines a micro-enterprise as one employing fewer than 10 people with annual turnover or an annual balance sheet total of no more than EUR 2 million, and article 5(4) exempts micro-enterprises that provide services from the service accessibility requirements. Meeting both parts of the size test exempts you from the service obligations only. If you manufacture, import or distribute one of the covered products, the product requirements still apply in full, whatever your headcount.

Which accessibility standard does my site have to meet in Greece?

EN 301 549 applies in practice. Law 4994/2022 works through a presumption of conformity: article 15 ties that presumption to harmonised standards published in the Official Journal of the European Union, and EN 301 549 is the one covering ICT. It carries the WCAG success criteria. Greece has no national web accessibility standard of its own. The public sector law, Νόμος 4727/2020, names ΕΝ 301 549 directly in article 41.

Who enforces this in Greece, and what are the fines?

Product surveillance is split by product type between the Ministry of Development industrial products directorate, the ΕΕΤΤ, the Γενική Γραμματεία Μεταφορών and the ΕΣΡ, with the last two acting jointly with that directorate. For services, article 22(2) names only the ΕΕΤΤ, for electronic communications. Article 26 provides administrative sanctions and corrective measures and sets no euro amounts. Article 27(2) leaves fine levels to a presidential decree covering products, which could not be found published.

This page is a plain-English summary, not legal advice. Check the cited national law for specifics.

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