As early as June 28, 2025, the Law of April 26, 2024 on Ensuring that Business Entities Meet Accessibility Requirements for Certain Products and Services1 (hereinafter: the Law) will come into force. This is the moment when businesses – regardless of industry – will have to take a serious look at how they design their products and provide services. The new legislation introduces an obligation to ensure that solutions are accessible to people with various functional limitations – not only people with strict disabilities, but also seniors, people with temporary injuries or, finally, those for whom digital tools are sometimes simply unintuitive. The Act implements EU Directive 2019/882 and introduces into the Polish legal order an approach in which accessibility for the aforementioned people is no longer an option, but a standard.
Who is affected by the Act?
The subject scope of the Act is very broad. The new obligations will cover business entities as defined in the Act – that is, manufacturers, importers, distributors and service providers2 . In practice, this means that almost everyone who markets certain products or provides the services indicated in the Act will be required to adjust them in terms of accessibility. The standards introduced will not be just a symbolic recommendation – compliance with them will become a condition for avoiding very high fines 3.
The law focuses on product groups that play a key role in the daily functioning of society. Starting June 28, 2025, almost every product put on the market will have to meet accessibility requirements, including easier use, compatibility with assistive technologies or alternative ways of interaction.
The new regulation will essentially cover four types of products 4:
- General-purpose computer hardware systems and their operating systems
- Consumer terminal devices with interactive computing capabilities used to offer or provide services:
- Payment terminals and self-service terminals including ticket vending machines or check-in machines.
- E-book readers
However, the law is not limited to products – it also introduces important requirements in the context of providing services, the lack of availability of which may have hindered many users until now. The law covers the following industries5: - Telecommunications
- Audiovisual services
- Public transport
- Retail banking
- Distribution of electronic books
- E-commerce.
Who does not have to adapt?
Not every entity will be covered by the obligation to implement the new regulations. The law provides for several exceptions, the most important of which concerns micro-entrepreneurs – that is, those who employ fewer than 10 people and have an annual turnover or balance sheet total not exceeding €2 million. In their case, the legislator decided to completely exempt them from the new requirements .
Selected websites and mobile applications, such as interactive maps, are also exempted from compliance, as long as they are not financed or controlled by an economic entity 7. The exemption also covers local transportation services, including, in principle, public transportation8 .
New requirements for Retail Banking
The law does not bypass the financial sector – on the contrary, it provides for it a series of specific obligations that will realistically affect the way services are provided to consumers. Importantly, the regulations are not limited to banks. The new requirements will also cover payment institutions (small payment institutions, national payment institutions), electronic money institutions or brokerage houses.
The law introduces its own definition of retail banking, distinguishing within it three basic categories of services9 :
- conclusion of consumer credit and mortgage contracts
- services involving brokerage activities,
- electronic money services, and payment services.
The scope includes a significant portion of services provided by financial institutions to consumers, but does not apply to the entire market. Among others, mutual fund companies, crowdfunding platforms, and a very large part of the banking business escape the above classification.
One of the key obligations that the Act imposes on retail banking service providers is to ensure the digital accessibility of websites, mobile applications and transaction systems. What is required above all is that these solutions be readable, functional, understandable and compatible with assistive technologies. Although the Act itself does not impose a specific method for their implementation, in practice the most widely used and recognized standard that meets these requirements remains the WCAG guidelines10 – both version 2.1 and the newer 2.211 .
In the context of payment services, this means that the entire process – from logging into the system, to authorizing a transaction, to confirming it – must be intuitive, understandable and manageable also for people with functional limitations. Websites and mobile apps used to process payments should be keyboard-enabled, allow the use of screen readers, and take into account the needs of people with vision limitations, such as through an option to increase contrast.
For example, according to the rules under WCAG:
- the login form should be fully keyboard-enabled 12,
- field labels must be readable by screen readers13 ,
- there should be a mechanism for changing the contrast14 ,
- error messages (e.g., when entering the wrong password) should be unambiguous and readable regardless of how you interact with the system15
Also, the transaction confirmation process itself – whether by SMS code, mobile application or electronic signature – must be designed in such a way that it does not exclude people with limited manual, visual or auditory dexterity16 .
Self-service devices will also be subject to adaptation – ATMs and payment terminals must, among other things, provide voice service or have headphone jacks. Contrasting markings and buttons distinguishable by touch will also be required17 .
The law also covers documentation related to financial services, requiring institutions to make contracts, rules and regulations and other content available in formats that are friendly to people with disabilities 18. These documents will have to be available as text files, audio recordings, Braille versions or in a format that can be read by screen readers, among others.
Importantly, it’s not just the form – the language of the documents must also be simplified. The legislator requires that they be written in a comprehensible, clear manner and free of unnecessary legal terminology that could make them difficult to interpret for those without legal training19 .
In addition, communication with customers will have to be in Polish, and at the customer’s request – also in another language, provided that its knowledge (on the part of the customer or employee) corresponds to at least level B2 according to the Council of Europe’s Common European Framework of Reference for Languages20 .
How to implement new responsibilities?
Contact us! We will help you adapt your Company to the requirements of the indicated legal regulation.
@: kancelaria@rsplegal.pl
M: + 48 603 969 569
Maciej Raczynski – Legal Counselor | Partner
Kamil Ciupka – Junior Lawyer
[1] (Dz.U. poz. 731);
[2] Art. 2 Ustawy;
[3] Art. 73 Ustawy;
[4] Art. 3 ust. 1 Ustawy;
[5] Art. 3 ust. 2 Ustawy;
[6] Art. 4 pkt. 1 Ustawy;
[7] Art. 4 pkt. 2 Ustawy;
[8] Art. 4 pkt. 3 Ustawy;
[9] Art. 5 pkt. 30 Ustawy;
[10] Web Content Accessibility Guidelines (WCAG) 2.1, W3C Recommendation z 5 czerwca 2018 r., opracowane przez World Wide Web Consortium (W3C), dostępne online: https://www.w3.org/TR/WCAG21/
[11] Aktualną wersję WCAG 2.2 opublikowano 5 października 2023 r.: https://www.w3.org/TR/WCAG22/.
[12] WCAG 2.1 – Kryterium sukcesu 2.1.1: Keyboard (poziom A). Treść musi być w pełni obsługiwana przy użyciu samej klawiatury, bez konieczności korzystania z myszy. https://www.w3.org/TR/WCAG21/#keyboard;
[13] Ibidem, kryterium 1.3.1: Info and Relationships (poziom A),
https://www.w3.org/TR/WCAG21/#info-and-relationships
[14] Ibidem, kryterium 1.4.3: Contrast (Minimum) (poziom AA),
https://www.w3.org/TR/WCAG21/#contrast-minimum
[15] Ibidem, kryterium 3.3.1: Error Identification (poziom A),
https://www.w3.org/TR/WCAG21/#error-identification
[16] Ibidem, kryterium 2.1.2: No Keyboard Trap (poziom A),
https://www.w3.org/TR/WCAG21/#no-keyboard-trap
Zob. również kryterium 1.3.5: Identify Input Purpose (poziom AA). https://www.w3.org/TR/WCAG21/#identify-input-purpose;
[17] Art. 9 Ustawy;
[18] Art. 32 Ustawy;
[19] Art. 16 ust. 2 Ustawy;
[20] Ibidem;
