European Accessibility Act Compliance in Sweden

Sections 3 and 4 of the Act set its scope: a defined list of products, and a defined list of services when they are intended for consumers. Section 4 lists the services: electronic communications, services giving access to audiovisual media services, consumer banking, e-books, e-commerce, and elements of passenger transport by bus, ship, air and rail such as websites, mobile apps, electronic tickets, travel information and self-service terminals. Section 2 defines e-commerce services as services 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.

Under section 10, services provided by a mikroföretag (micro-enterprise) do not have to meet the accessibility requirements. Section 2 defines a micro-enterprise as an enterprise with fewer than ten employees and an annual turnover or an annual balance sheet total of no more than EUR 2 million. The exemption covers services only. A micro-enterprise that deals with products still has to meet the product requirements. Section 10 only spares it from documenting its assessment of an exemption under section 7 and from notifying PTS, the market surveillance authority, that it relies on one, and PTS can still ask it for the relevant information.

Section 5 excludes third-party content on websites and apps that the business does not control and has neither funded nor developed. Transitional provision 2 excludes pre-recorded time-based media and document file formats published on websites and in apps before 28 June 2025. It also excludes archived content that has not been updated or edited since then. Digital services of public-sector bodies fall under a separate law, lag (2018:1937) om tillgänglighet till digital offentlig service, which ties its scope to the Web Accessibility Directive (EU) 2016/2102.

The transposing act is lag (2023:254) om vissa produkters och tjänsters tillgänglighet (Act SFS 2023:254 on the accessibility of certain products and services), adopted by the Riksdag on government bill prop. 2022/23:42. Post- och telestyrelsen (PTS, the Swedish Post and Telecom Authority) notes that the Act is also called tillgänglighetslagen or LPTT. The Government issued it on 11 May 2023 and it was published in Svensk författningssamling on 16 May 2023. It entered into force on 28 June 2025 under transitional provision 1, and section 1 states that it transposes Directive (EU) 2019/882.

The implementing Government regulation is förordning (2023:676) om vissa produkters och tjänsters tillgänglighet, issued on 16 November 2023 and in force since 28 June 2025. Annex 1 sets the product requirements and Annex 2 the service requirements. SFS 2025:335 amended the regulation to name Mediemyndigheten as the supervisory authority for access to audiovisual media services. SFS 2026:290 added section 7 a and Annex 3, which set functional performance criteria for functions the requirements do not cover, from 1 May 2026.

PTS has issued PTSFS 2024:5 on products, PTSFS 2024:6 on services, PTSFS 2024:7 on the criteria for disproportionate burden and PTSFS 2026:6. That last one amends PTSFS 2024:5 so that from 1 November 2026 a product's EU declaration of conformity, and information given to PTS under section 22 of the Act, may be in Swedish or English instead of Swedish only. Mediemyndigheten (MEMYFS 2025:1) and Myndigheten för tillgängliga medier (KRFS 2025:1) have issued regulations on accessibility requirements for their own sectors. Act SFS 2026:1026 replaces the consumer credit reference in section 2 of the Act from 20 November 2026.

Transposition was late. The Commission sent Sweden a letter of formal notice in July 2022. On 25 July 2024 it sent a reasoned opinion because Sweden had communicated only partial transposition measures, and on 30 January 2026 an additional reasoned opinion, INFR(2022)0322, holding that transposition gaps remain. The case was still marked active in the Commission's infringement database in September 2026.

Government bill prop. 2025/26:59 states that some of the directive's requirements cannot currently be applied in full to products and services protected by tryckfrihetsförordningen (the Freedom of the Press Act) or yttrandefrihetsgrundlagen (the Fundamental Law on Freedom of Expression). Mediemyndigheten states that the Act is not applied where that would conflict with those constitutional rules. An e-commerce service can have this protection when its operator has automatic constitutional protection for its database, as newspaper publishers and other mass media companies do, or holds an utgivningsbevis (publishing certificate) for its database.

The bill proposes amendments so that the requirements can be applied in full, including requirements for e-books and e-commerce services. On 22 April 2026 the Riksdag adopted them as vilande, the first of the two decisions a constitutional amendment needs. The second identical decision has to come after a general election, which Sweden held in September 2026. The bill proposes entry into force on 1 January 2027.

EN 301 549 is the practical reference. The Act names no standard. Section 9 presumes that products and services meeting a harmonised standard whose references are published in the Official Journal of the European Union, or a technical specification, conform to the accessibility requirements to the extent the standard or specification covers them.

Point 3 of Annex 2 to förordning (2023:676) om vissa produkters och tjänsters tillgänglighet applies to every covered service and requires websites and mobile apps to be made accessible in a consistent and adequate way, by making them perceivable, operable, understandable and robust. Section 8 of PTSFS 2024:6 adds e-commerce duties: a webshop must pass on accessibility information about the products and services it sells when the responsible economic operators provide it, and its identification methods, electronic signatures, payment services and security functions must also be perceivable, operable, understandable and robust.

PTS states that following WCAG alone is not enough, because EN 301 549 covers more than websites, and that meeting EN 301 549 requires WCAG levels A and AA. 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 Act leaves the choice of authorities to the Government in sections 28 and 30, and förordning (2023:676) om vissa produkters och tjänsters tillgänglighet makes that choice. Under section 25 of the regulation, Post- och telestyrelsen (PTS) is the market surveillance authority for all covered products. Under section 28 it supervises e-commerce services and consumer banking. The same section gives it electronic communications services and a duty to coordinate cases that involve several supervisory authorities.

Mediemyndigheten (the Swedish Agency for the Media) supervises services giving access to audiovisual media services under section 29, and Myndigheten för tillgängliga medier (the Swedish Agency for Accessible Media) supervises e-books under section 30. Under section 31, Konsumentverket (the Swedish Consumer Agency) covers the websites, mobile services, electronic tickets and electronic ticket sales of passenger transport, while Transportstyrelsen (the Swedish Transport Agency) covers travel information and services through interactive self-service terminals. From 1 January 2027 PTS and Myndigheten för digital förvaltning (Digg) become one authority, Digitaliseringsmyndigheten, and section 21 of förordning (2026:1769) med instruktion för Digitaliseringsmyndigheten makes the new authority market surveillance authority and supervisory authority under the Act.

Consumers can complain to PTS about an inaccessible product or service through its e-service at lptt.pts.se, anonymously if they wish. PTS does not reply to a complaint but can use it when planning its supervision and market surveillance. Complaints about the other sectors go to the authority responsible for them. Under section 24 of the Act, a service provider whose service does not conform must take the measures needed to bring it into line and immediately notify the supervisory authorities of the member states where it provides the service. PTS treats a report within 14 days of noticing the deficiency as sufficient.

Under section 32 the authority first asks the business to fix a deficiency within a set time. If that fails, it can issue förelägganden (injunctions), which section 35 allows it to combine with a vite (conditional fine), and the Act sets no amount for the vite. Section 37 lets the authority impose a sanktionsavgift (penalty fee) for breaches of listed provisions, among them the accessibility requirements in section 6 and the service provider duties in sections 24 to 26, and rules the fee out in minor cases. Section 39 sets the fee as an amount in kronor, at a minimum of SEK 10,000 and a maximum of SEK 10,000,000, based on the seriousness and extent of the breach, and the fee goes to the State. Under section 38, no fee can be imposed for a breach that is the basis of an application to enforce a vite.

PTS opened its first supervision in October 2025, of the websites of larger e-commerce operators established in Sweden, and had opened 28 such cases by 3 March 2026. Under section 41, decisions can be appealed to the general administrative courts, with leave to appeal required at the administrative court of appeal. The first request to fix a deficiency under section 32 or 33 cannot be appealed.