Accessibility requirements for products and services
source: Legal Industry Review
authors: Mgr. Michal Nulíček, LL.M., Mgr. Ing. Ivan Fencl
On 28 June 2025, Act No. 424/2023 Coll., on accessibility requirements for certain products and services, comes into force. This legislation represents a significant step towards harmonizing accessibility rules across the European Union, as it transposes Directive (EU) 2019/882 of the European Parliament and of the Council (the European Accessibility Act). While its main objective is to improve accessibility for persons with disabilities, it will also enhance the overall user experience for a wide spectrum of consumers.
Who is Affected by the New law?
Even though the concept of accessibility is nothing new in Europe or Czechia, this new law will significantly affect number of businesses that offer products or services to consumers both online and offline. It includes telecommunication providers, transport providers, financial institutions (banks) and e-commerce platforms. The obligation applies regardless of whether the product or service is offered free of charge or for a fee. It applies to enumerated products and services such as electronic communications services, services providing access to audiovisual media content, transport services, financial services, and others. As for the products, the law applies to e-book readers, certain self-service terminals (such as ATMs or payment or information terminals), computers, mobile phones, and more.
Core Accessibility Requirements for Digital Interfaces
Entities subject to the act must ensure their digital interfaces meet basic accessibility requirements. These focus on perceptibility, operability, understandability, and stability. Technical specifications are listed in the annex and should match harmonized norms and standards. Currently, no fully applicable harmonized norms or standards exist. For example, EN 301 549, covering website and mobile accessibility, applies only to older laws and not fully to the EAA or new Czech rules. It is under revision by the European Commission and should be updated by 2026. Until then, businesses must rely on existing norms. This creates uncertainty about how to meet the requirements. However, authorities are not expected to enforce fines strictly for now.
Beside the technical changes, other obligations also apply. Obliged service providers must ensure that only accessible products are used (e.g. banks must use accessible ATMs, even if they are not the manufacturers). An accessibility memorandum must also be published on the website.
Although the new legislation is often seen as a regulatory burden, it also offers an opportunity. Accessible digital environments benefit not only persons with disabilities, but also older adults and users in diverse situations. For many companies, this can enhance credibility, user experience, and competitive advantage.
