European Accessibility Act Compliance in Lithuania

Under Article 2(1) the law applies to economic operators that supply covered products to the Lithuanian market or provide covered services, and since 1 April 2026 Article 2(4) states that the covered services are those provided to consumers. Article 2(2) lists the products: consumer general-purpose computer hardware and its operating systems, self-service terminals (payment terminals, and the ATMs, ticketing machines, check-in machines and interactive information terminals used for covered services), consumer terminal equipment with interactive computing capability used for electronic communications services, consumer interactive equipment for accessing audiovisual media services, and e-readers.

Article 2(4) lists the services: electronic communications, access to audiovisual media services, elements of air, bus, rail and waterborne passenger transport such as websites, mobile apps, electronic tickets and travel information, consumer banking, e-books and dedicated software, and e-commerce. Article 3(6) defines e-commerce services as services provided at a distance through websites and mobile devices, by electronic means, at the individual request of a consumer with a view to concluding a consumer contract. VVTAT's guidance treats a website as an e-commerce service when placing an order on it involves concluding a consumer contract.

Article 13(2) requires a service provider to explain how the service meets the accessibility requirements in its bendrasis paslaugos teikimo sąlygų aprašas (general terms and conditions of service) or an equivalent document. That information is made public, and at the request of interested persons it is also given in writing and orally, including in a way accessible to persons with disabilities. Under Article 13(5) a provider that learns its service does not conform must tell the market surveillance authority within 5 working days.

The second sentence of Article 7(1) exempts a labai maža įmonė (micro-enterprise) that provides services from the accessibility requirements and the obligations linked to them. Article 3(10) takes the definition from the Lietuvos Respublikos smulkiojo ir vidutinio verslo plėtros įstatymas (Law on the Development of Small and Medium-sized Business), whose Article 3(3) requires fewer than 10 employees and either annual revenue or balance sheet assets of no more than EUR 2 million. The exemption covers services only, so a micro-enterprise dealing in covered products keeps its product obligations.

Article 2(6) leaves out some website and app content, including pre-recorded time-based media published before 28 June 2025, office files published before that date, online maps and mapping services where maps meant for navigation give the essential information in an accessible digital form, and websites and apps kept as archives whose content is not updated or edited after 28 June 2025.

Lietuvos Respublikos gaminių ir paslaugų prieinamumo reikalavimų įstatymas (Law of the Republic of Lithuania on Accessibility Requirements for Products and Services), No. XIV-1633, adopted by the Seimas on 8 December 2022 and published in the Teisės aktų registras (Register of Legal Acts) on 22 December 2022 under No. 2022-26360. It covers e-commerce, consumer banking, e-books, electronic communications, access to audiovisual media services and parts of air, bus, rail and waterborne passenger transport, along with a defined list of consumer hardware and self-service terminals. It entered into force on 28 June 2025 under Article 30(1), and Annex 3 names Directive (EU) 2019/882 as the EU act it implements. The Lietuvos Respublikos socialinės apsaugos ir darbo ministerija (Ministry of Social Security and Labour) shapes state policy on product and service accessibility under Article 4(2).

Two laws have amended the text. Law No. XV-760 of 10 March 2026 amended 13 articles and Annex 1 with effect from 1 April 2026, and its provisions on the emergency number 112 follow on 28 June 2027. Law No. XV-907 of 12 May 2026 rewrote Article 28(2) with effect from 30 June 2026.

Transposition was late. Article 31(1) of the Directive required national measures to be adopted and published by 28 June 2022, and the Lithuanian law was published nearly six months after that date. The Commission opened infringement case INFR(2022)0311 with a letter of formal notice on 19 July 2022, and on 26 September 2026 its infringement database still lists the case as active, with no reasoned opinion recorded.

The law names no standard. Article 15(1) presumes that products and services meeting harmonised standards, or parts of them, whose references are published in the Official Journal of the EU meet the accessibility requirements those standards cover, and Article 15(2) does the same for technical specifications. Article 13(3) lets service providers apply those standards and specifications when they prepare the accessibility information that Article 13(2) asks for.

The requirements themselves sit in Annex 1. Point 10.3 requires websites and mobile apps to be accessible in a consistent and adequate way, and point 11.7 adds e-commerce duties: information on the accessibility of the products and services sold, where the responsible economic operator provides it, and accessible identification methods, electronic signatures, security functions and payment services. VVTAT's guidance names two European standards, EN 301 549 and EN 17161:2019. It also lists WCAG 2.2. EN 301 549 V3.2.1 applies the WCAG 2.1 level AA success criteria to web content. EN 301 549 V4.1.1, which adopts WCAG 2.2 AA, was published on 2 September 2026 and is not yet cited in the Official Journal. Testing to WCAG 2.2 AA covers the web criteria of both versions.

Article 6 splits market surveillance by sector. The Valstybinė vartotojų teisių apsaugos tarnyba (State Consumer Rights Protection Authority, VVTAT) supervises the covered products, consumer banking, e-books and dedicated software, and e-commerce under Article 6(4). Since 1 April 2026 that includes the audiovisual media equipment which the Lietuvos radijo ir televizijos komisija (Radio and Television Commission of Lithuania) supervised before, and the commission keeps access to audiovisual media services under Article 6(7). The Lietuvos transporto saugos administracija (Lithuanian Transport Safety Administration) covers the passenger transport services and the rail products that are interoperability constituents under Article 6(5), and the Lietuvos Respublikos ryšių reguliavimo tarnyba (Communications Regulatory Authority) covers electronic communications under Article 6(6).

The law creates no separate accessibility complaints body. Under Article 6(3) the market surveillance authorities examine complaints about non-conforming products and services, and under Article 26(2) a case starts on a complaint from a consumer, an end user, a state or municipal body, a consumer association or another interested person, or on the authority's own initiative. Requests reach VVTAT through the Vartotojų teisių informacinė sistema (Consumer Rights Information System, VTIS) or on its request form, in Lithuanian or English, and its request page describes the general consumer dispute route, in which the consumer writes to the trader first. Under Article 20(2) an authority that finds a service non-conforming sets a period of at least 3 working days to put it right, and orders the provider to stop the service if it does not.

Article 23(1) sets a fine of EUR 500 to 2,500 for placing a non-conforming product on the market or providing a non-conforming service. Ignoring a ban, restriction, withdrawal, recall or destruction order for a non-conforming product, or continuing a service after being told to stop, carries a fine of EUR 1,000 to 6,500 under Article 23(2). The highest band, EUR 2,500 to 15,000 under Article 23(3), applies where a non-conforming product or service has harmed the health of a consumer or end user. Under Article 23(4) a fine starts at the midpoint of its band and moves down for mitigating or up for aggravating circumstances, and Article 23(6) allows a warning in place of the Article 23(1) fine where the operator withdrew a product voluntarily before it reached consumers.

At VVTAT, a commission formed by order of its Director imposes fines and warnings under the procedure approved by Order No. 1-123 of 11 June 2025. Article 25 allows a fine up to 5 years after the breach, or for a continuing breach 5 years after it came to light. The fine is paid into the state budget within one month under Article 28(1). Article 28(2) makes the fine decision an enforceable document, and since 30 June 2026 it is enforced under the Law on Tax Administration and the Code of Civil Procedure. Decisions on fines and market restrictions can be appealed within one month under Article 27(1). Since 1 April 2026, Article 2(9) keeps Chapter VII, which holds the fines, from applying to operators taking part in public procurement procedures.