European Accessibility Act Compliance in Slovenia

The Act applies to economic operators that make covered products available on the market and to providers of covered services. The Act covers e-commerce, consumer banking, e-books and dedicated software, electronic communications, access to audiovisual media services and parts of air, bus, rail and waterborne passenger transport, together with a defined list of consumer hardware and self-service terminals. Article 3(1) lists the products: consumer general purpose computer hardware and its operating systems, payment terminals, ATMs, ticketing machines, check-in machines and interactive information terminals (except those built into vehicles, aircraft, ships or rolling stock), consumer terminal equipment with interactive computing capability used for electronic communications services or for access to audiovisual media services, and e-readers.

Article 3(2) lists the services: electronic communications services, services providing access to audiovisual media services, the websites, mobile services, electronic tickets, transport information and interactive self-service terminals of air, bus, rail and waterborne passenger transport, consumer banking services, e-books and dedicated software, and e-commerce services. Under Article 3(3), urban and interurban transport is covered only for interactive self-service terminals. Article 5, point 33, defines an e-commerce service as a service provided at a distance, through websites and mobile device-based services, by electronic means and at the individual request of a consumer, with a view to concluding a consumer contract.

Article 8(2), added by ZDPSI-A, requires a service provider to state in its general terms and conditions, or an equivalent document, how the service meets the accessibility requirements, including a general description of the service in accessible formats. Article 9.a, also added by ZDPSI-A, requires an e-commerce provider to pass on accessibility information about the products and services it sells where the responsible economic operator supplies it, and to make the identification, security, electronic signature and payment functions of the service accessible.

Article 4(2) states that the Act does not apply to micro-enterprises that provide services. Article 5, point 17, defines a mikropodjetje as an enterprise with fewer than ten employees and an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million. The exemption covers services only. For a micro-enterprise that deals with products, Article 22(4) lifts the Article 22(3) requirement to keep the Article 22(2) assessment and submit it on request, unless it has decided to meet the requirements of Article 22(1), in which case it submits the facts relevant to the assessment to the market surveillance authority.

Article 4(1) also leaves out some website and app content, including pre-recorded time-based media and office file formats published before 28 June 2025, online maps and mapping services where the essential information for navigation is provided in an accessible digital manner, third-party content that the economic operator neither funds nor develops and does not control, and archived content that is not updated or edited after that date.

The transposing act is the Zakon o dostopnosti do proizvodov in storitev za invalide (ZDPSI), the Act on the Accessibility of Products and Services for Persons with Disabilities. The Državni zbor Republike Slovenije (National Assembly) adopted it on 24 January 2023, and it was published in Uradni list RS, No. 14/2023 on 3 February 2023. It entered into force on 18 February 2023 and, under Article 46, has applied since 28 June 2025. Article 2 states that it transposes Directive (EU) 2019/882.

The Act was amended by the Zakon o spremembah in dopolnitvah Zakona o dostopnosti do proizvodov in storitev za invalide (ZDPSI-A), which the National Assembly adopted on 11 February 2026. ZDPSI-A was published in Uradni list RS, No. 14/2026 on 24 February 2026 and has been in force since 25 February 2026 under its Article 19. ZDPSI-A added rail passenger transport to the scope, extended the Act in Article 3(4) to answering emergency communications through the single European emergency number 112 and two other numbers, the police number 113 and the missing children hotline 116 000, made the accessibility requirements mandatory in the technical specifications of public procurement in Article 3(5), and inserted Article 9.a on e-commerce and Article 25.a on consumer proceedings.

Slovenia has notified four ministerial regulations under the Act to the Commission as transposition measures: the Pravilnik o dostopnosti proizvodov za invalide, o označevanju in postopku ugotavljanja skladnosti (Uradni list RS, No. 61/2023, amended in No. 109/2025), the Pravilnik o merilih za oceno nesorazmernega bremena (No. 84/2023), the Pravilnik o podrobnejših pogojih glede dostopnosti storitev, ki invalidom zagotavljajo dostop do avdiovizualnih medijskih storitev (No. 82/2024) and the Pravilnik o merilih glede funkcionalne učinkovitosti dostopnosti proizvodov in storitev za invalide (No. 16/2026). The lead ministry is the Ministrstvo za delo, družino, socialne zadeve in enake možnosti (Ministry of Labour, Family, Social Affairs and Equal Opportunities).

Transposition was late. The Commission opened INFR(2022)0324 with a letter of formal notice on 19 July 2022 and sent a reasoned opinion on 25 July 2024 because Slovenia had communicated only partial transposition measures. On 30 January 2026, before ZDPSI-A was adopted, it sent an additional reasoned opinion holding that transposition gaps remain. Its infringement database lists no later decision and still marks the case as active.

Slovenian law names no standard. Article 23(1) of the ZDPSI presumes that products and services meeting harmonised standards whose references are published in the Official Journal of the European Union meet the accessibility requirements, as far as those standards cover them. Where no such reference is published, Article 23(2) gives the same presumption to products and services that meet an implementing act published in the Official Journal of the European Union that sets technical specifications.

Article 8(3) lets a service provider apply those standards and specifications in whole or in part when it describes how its service meets the requirements, and Article 6(2) allows functional performance criteria, set by the minister responsible for disability protection in a regulation published in February 2026, as an alternative to one or more technical requirements. The Act and its implementing regulations do not mention EN 301 549 or WCAG. EN 301 549 is the European standard for ICT accessibility. 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.

Supervision is split by sector. Article 26(2) gives market surveillance of all covered products to the Tržni inšpektorat Republike Slovenije (TIRS, Market Inspectorate of the Republic of Slovenia), and Article 30(8) makes TIRS the supervisor of e-commerce services. The Agencija za komunikacijska omrežja in storitve Republike Slovenije (AKOS, Agency for Communication Networks and Services) supervises electronic communications and access to audiovisual media services under Article 30(1) and e-books and dedicated software under Article 30(7). Article 30(9) also gives AKOS the supervision of emergency communication services.

Under Article 30(6) consumer banking services are supervised by Banka Slovenije, TIRS, the Informacijski pooblaščenec (Information Commissioner) and the Agencija za trg vrednostnih papirjev (Securities Market Agency), each within the powers given by the sector laws that paragraph refers to. Passenger transport is divided by mode in Article 30(2) to (5): the Uprava Republike Slovenije za pomorstvo (Slovenian Maritime Administration) and TIRS for waterborne transport, the Javna agencija za civilno letalstvo Republike Slovenije (Civil Aviation Agency) for air, the Inšpektorat Republike Slovenije za infrastrukturo (Infrastructure Inspectorate) for bus, and, since ZDPSI-A, the inspectorates listed in Article 30(5) for rail.

Under Article 31(1) the body supervising a service checks its compliance, including the Article 22(2) assessment of whether compliance would fundamentally alter the service or impose a disproportionate burden, and handles complaints and reports about non-compliant services. Article 25.a, added by ZDPSI-A, lets a consumer start proceedings before the bodies named in Articles 26 and 30 and seek judicial protection before the competent courts, and lets public or private legal persons with a legal interest take part in proceedings before those bodies on the consumer's behalf or in support, with the consumer's approval. TIRS takes reports through its gov.si service page Prijava kršitve Tržnemu inšpektoratu and treats a report only as a prompt for a possible inspection procedure. AKOS takes reports of violations, including through its online form and through a report form sent by e-mail to info.box@akos-rs.si.

Chapter VII sets fixed fine ranges in euro for most breaches. For e-commerce, Article 40 fines a legal person EUR 500 to 5,000 for failing to ensure accessibility, a legal person that counts as a medium or large company under the companies act EUR 1,000 to 10,000, a sole trader or self-employed individual EUR 250 to 2,500, and the responsible person EUR 50 to 250. Articles 35 and 36 set the same bands for electronic communications and for access to audiovisual media services, and Article 39 sets EUR 500 to 5,000, or EUR 1,000 to 10,000 for a medium or large company, for consumer banking. Article 37 sets EUR 400 to 2,000, or EUR 800 to 4,000, for e-books.

The highest band in the Act is EUR 3,000 to 40,000 under Article 34(1), for product breaches by a legal person in one of the roles that paragraph lists, such as manufacturer or importer. Article 38 refers breaches of the passenger transport requirements in Article 12(1) to (3) to separate government decrees implementing the EU passenger rights regulations. Under Article 41 a fine above the statutory minimum may be imposed in the fast-track procedure.