European Accessibility Act Compliance in Poland

Art. 3 ust. 2 applies the act to services offered or provided to consumers: telecommunications other than machine-to-machine transmission, access to audiovisual media services, the websites, mobile services, electronic tickets, travel information and interactive information terminals of air, bus, coach, rail and waterborne passenger transport, retail banking, e-books and e-commerce. Art. 5 pkt 32 defines e-commerce services as services offered or 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 contract. The Ministry of Digital Affairs reads this as covering any product or service sold online, including insurance, healthcare services, clothing, cosmetics and medicines. Art. 32 ust. 2 pkt 1 requires a service provider to state in its terms of service, or an equivalent document, how the service meets the accessibility requirements. The same document has to describe the service and what a consumer needs to use it.

Art. 3 ust. 1 lists the products: consumer general-purpose computer hardware and its operating systems, payment terminals, self-service terminals used for covered services (ATMs and cash deposit machines, ticket machines, check-in machines and interactive information terminals), consumer terminal equipment with interactive computing capability used for telecommunications services or access to audiovisual media services, and e-readers.

Art. 4 pkt 1 excludes services offered or provided by a mikroprzedsiębiorca (micro-enterprise). The act does not define the term. The guidelines PFRON issued for businesses in 2025 define it with the wording of Art. 7 ust. 1 pkt 1 of the Prawo przedsiębiorców (Entrepreneurs Law): in at least one of the last two financial years, fewer than 10 employees on annual average and annual net turnover or a balance sheet total of no more than the PLN equivalent of EUR 2 million. Products get no such exclusion. Under Art. 21 ust. 9 a micro-enterprise dealing in products does not have to document its assessment of fundamental alteration or disproportionate burden, or notify the authority of it, under Art. 21 ust. 5 to 8, although it has to present the relevant documents or circumstances on request.

On websites and mobile applications, Art. 4 pkt 2 also leaves out maps and interactive maps, including geoportals, where the address data and geographic location on maps intended for navigation are presented in a digitally accessible way, and content that the business neither funds nor creates and that is not under its control. Art. 4 pkt 3 excludes urban public transport and local and regional passenger transport within the meaning of the public collective transport act of 16 December 2010, except for information provided through interactive self-service terminals. Art. 86 pkt 1 and 2 leave out website and app content consisting of pre-recorded time-based media or document files published before 28 June 2025. Under Art. 86 pkt 3, archived content that has not been updated or edited since that date is also outside the act.

The transposing act is ustawa z dnia 26 kwietnia 2024 r. o zapewnianiu spełniania wymagań dostępności niektórych produktów i usług przez podmioty gospodarcze (Act of 26 April 2024 on ensuring by economic operators that certain products and services meet the accessibility requirements), published in the Dziennik Ustaw on 15 May 2024 as Dz. U. 2024 poz. 731. It covers e-commerce, retail banking, e-books, telecommunications, access to audiovisual media services and parts of air, bus, rail and waterborne passenger transport, along with a defined list of consumer hardware and terminals. Its footnote 1 states that it implements Directive (EU) 2019/882.

The Sejm passed the government bill, print no. 241, on 12 April 2024 and accepted the Senate amendments on 26 April 2024, the date the act carries. The President signed it on 9 May 2024. Under Art. 88 the act entered into force on 28 June 2025. Some provisions took effect earlier, on 30 May 2024: Art. 6 pkt 1, 2 and 5 to 9, on the tasks of the minister for regional development, and Art. 39 pkt 6, under which the President of the Management Board of the Państwowy Fundusz Rehabilitacji Osób Niepełnosprawnych (PFRON, State Fund for Rehabilitation of Disabled Persons) organises education and information work and prepares guidelines for businesses.

The act sets out the accessibility requirements itself, in Art. 7 to 19, and provides for no implementing regulation on them. The Sejm legal acts database (ISAP) lists no amending act as of 26 September 2026, so the text as published is the text in force. Poland transposed late. The directive's deadline was 28 June 2022. The European Commission opened infringement case INFR(2022)0317 with a letter of formal notice on 19 July 2022 and sent a reasoned opinion on 14 July 2023. EUR-Lex lists the 2024 act among Poland's notified transposition measures, while the Commission's infringement register still shows the case as active, with no closing decision recorded.

The act names no standard. Art. 20 ust. 1 presumes that a product or service meets the accessibility requirements to the extent that it conforms to harmonised standards or technical specifications covering them. Art. 20 ust. 2 gives passenger transport services the same presumption where they meet the information requirements of the EU passenger rights and rail interoperability regulations.

For e-commerce, the Minister Cyfryzacji (Minister of Digital Affairs) names EN 301 549 in the list of harmonised standards and technical specifications that Art. 40 pkt 3 requires it to publish. 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. The guidelines PFRON published for businesses in 2025 are based mainly on EN 301 549 and apply the WCAG 2.1 success criteria at levels A and AA. They state that they are not an interpretation of the law.

Art. 38 ust. 3 names a market surveillance authority for each sector. E-commerce services go to the minister właściwy do spraw informatyzacji (minister competent for computerisation), currently the Minister Cyfryzacji (Minister of Digital Affairs). The Prezes Urzędu Komunikacji Elektronicznej (President of the Office of Electronic Communications, UKE) covers all the covered products and telecommunications services, and also access to audiovisual media services and e-books. Retail banking goes to the Rzecznik Finansowy (Financial Ombudsman).

Passenger transport is split by mode: the wojewódzcy inspektorzy transportu drogowego (regional road transport inspectors) for bus and coach, the Prezes Urzędu Transportu Kolejowego (President of the Office of Rail Transport) for rail, the Prezes Urzędu Lotnictwa Cywilnego (President of the Civil Aviation Office) for air, and the dyrektorzy urzędów morskich (directors of maritime offices) and the Dyrektor Urzędu Żeglugi Śródlądowej w Bydgoszczy (Director of the Inland Navigation Office in Bydgoszcz) for sea and inland waterways.

The Prezes Zarządu PFRON, the President of the PFRON Management Board, supervises how these authorities apply the act under Art. 39 pkt 2, and under Art. 43 can itself inspect any covered product or service it has reasonable doubts about. A consumer can complain to the business under Art. 35. Under Art. 37 ust. 2 and 3 the business has to answer within 30 days of receipt, or within 60 days in especially complex cases. If it misses the deadline, Art. 37 ust. 4 treats the complaint as accepted, and the business has to fulfil it within 6 months of receipt. Under Art. 37 ust. 6 a rejection has to tell the consumer about notifying PFRON.

Under Art. 67 anyone may notify the Prezes Zarządu PFRON that a product or service does not meet the requirements, in writing, orally, electronically or in Polish Sign Language. Art. 68 ust. 1 gives PFRON 30 days to examine the notification or forward it to the competent authority. The gov.pl service Złóż zawiadomienie o braku dostępności produktu albo usługi takes notifications by e-mail at dostepnosc@pfron.org.pl, and a notification may be anonymous.

When an inspection finds a service non-compliant, Art. 62 ust. 1 has the authority call on the provider to bring the service into line or stop offering it, and to show evidence of this within a period of no more than 120 days. Under Art. 62 ust. 1 pkt 2 the authority may also ban the service for up to 180 days. Art. 65 ust. 1 lets it order compliance or ban the service by decision.

Under Art. 73 ust. 1 pkt 2 a service provider can be fined for a service that does not meet the requirements of Art. 12 to 19, for skipping the conformity assessment in Art. 32 ust. 1, for not reporting non-compliance to the authority under Art. 32 ust. 2 pkt 6, for not supplying requested information on time, or for missing the deadline to show corrective action. The maximum is ten times the average monthly wage in the national economy for the preceding year, as announced by the President of Statistics Poland in Monitor Polski, and never more than 10% of the turnover in the financial year before the year of the fine. Producers face the same maximum under Art. 73 ust. 1, and importers and distributors under Art. 73 ust. 2. For 2025, Statistics Poland announced an average wage of PLN 8,903.56 (Monitor Polski of 10 February 2026, item 192), and ten times that figure is PLN 89,035.60.

Art. 73 ust. 4 sets the amount by the extent of the breach, including its seriousness. The number of non-compliant products or services and the number of people affected also count. Fines go to the Fundusz Dostępności (Accessibility Fund) within 14 days of the decision becoming final, under Art. 73 ust. 5. Replies to parliamentary questions in August 2026 reported that PFRON, the Minister Cyfryzacji, UKE, the Rzecznik Finansowy and the rail, air, maritime and inland navigation authorities had not imposed any fine under Art. 73. By 27 July 2026 PFRON had received 139 notifications.