As early as June 28, 2025, companies will have to comply with new accessibility requirements - ignoring them can mean hefty fines and lost opportunities for public procurement. At the same time, however, systematic implementation of accessibility requirements can bring tangible competitive and reputational benefits.
On June 28, 2025, the Act of April 26, 2024 on Ensuring that Business Entities Meet Accessibility Requirements for Certain Products and Services, commonly referred to as the Polish Accessibility Act, will come into force. This act, which implements Directive 2019/882 of the European Parliament and the Council (EU) (the so-called European Accessibility Act), imposes a number of new obligations on businesses in selected sectors aimed at eliminating barriers to accessing products and services for people with special needs.
In practice, implementation of accessibility requirements includee: providing clear navigation on digital platforms, enabling accessibility through various sensory channels, customizing user interfaces, using contrasting colors and scalable fonts, optimizing mobile applications for assistive technologies, producing corporate documentation in simple and understandable language, building customer service systems with full access for all users.
Accessibility obligations - do they apply to your organization?
Most medium and large entrepreneurs will be covered by the new regulations. The law only exempts micro-entrepreneurs in the provision of services, while for products they are mostly subject to similar obligations as larger entities. Separately, organizations with larger-scale operations must prepare for full compliance.
However, it is not the size alone that matters - before proceeding:
- Check whether your business includes products or services covered by the law,
- Assess the complexity of the supply chain and distribution channels,
- Identify all consumer touch points.
What services and products does the Accessibility Act cover?
The Accessibility Act covers six main types of services and four product categories:
Services:
- Audiovisual media services (e.g., streaming/VOD platforms, hybrid TV),
- Electronic communications (telephony, Internet, including emergency calls),
- Digital information in passenger transportation (air, bus, rail, water),
- Retail banking (e.g., banking apps, call centers, help desks),
- Distribution of electronic books (creation and sale via the Internet),
- Online stores (e-commerce, marketplace platforms),
Products:
- Consumer computer hardware and operating systems,
- Consumer terminal equipment for telecommunications and audiovisual services,
- E-book readers,
- Payment and self-service terminals (ATMs, ticket machines, airport check-in machines).
Practical examples of accessibility implementations
A practical example of implementation for regulations on services For example, an online store will provide:
- Navigation by keyboard (without using a mouse),
- Alternative descriptions for all product images (known as alt text),
- Contrasting colors (contrast ratio min. 4.5:1),
- Font scaling (up to 200% without loss of functionality).
For products, the best example is a payment terminal in a store, which must provide, for example:
- Speech synthesis in Polish - the terminal will „talk” about any activity,
- A headphone jack to connect private headphones,
- Tactile markings on keys - raised dots on key buttons,
- Sufficient display contrast to ensure readability for the visually impaired.
What does this mean for your business?
For organizations, this means taking a systemic approach to accessibility at all levels: from IT architecture, to business processes, to staff training and supply chain management. Implementing accessibility is not just a matter of compliance - it's a strategic business decision. In practice, it's a must:
- Customization of websites, mobile applications,
- Changes in purchasing and customer service processes,
- Creating clear documentation (regulations, operating instructions),
- Staff training and availability management in the supply chain.
Who is affected by supply chain responsibilities? Responsibilities according to the Polish Accessibility Act
The Accessibility Act is aimed at entrepreneurs whose activities fall within the catalog of services and products covered by the law. The law imposes joint and several liability on the entire supply chain:
- Manufacturers - Accessibility-compliant design,
- Importers - Verification of compliance of products imported from outside the EU,
- Distributors - Ensuring that the marketed products are compliant,
- Service providers - The availability of the services provided and information about them.
Can your company take advantage of the exemptions?
Most of the exemptions will not apply to medium and large entrepreneurs:
- Websites and map applications (subject to the availability of digital contact information),
- Content not funded by the organization and beyond its control,
- Public transport services As well as municipal, metropolitan, county and provincial transportation.
When can the availability obligation be waived?
An organization may waive a specific accessibility requirement only after demonstrating that:
- Would represent a disproportionate financial burden (requires detailed economic analysis),
- It would require a fundamental change in the basic properties of the product/service.
The assessment of disproportionality is made on a case-by-case basis for each entity, regardless of its size. The use of protective provisions requires detailed documentation.
What are the penalties for lack of accessibility? Progressive system of sanctions in the Polish Accessibility Act
The Polish Accessibility Act introduces multi-level accountability system, which prioritizes correcting violations over punishment. The legislature applied the philosophy of „first help comply, then punish for persistent noncompliance.”.
Stage 1: Corrective action instead of immediate penalties
The system starts with corrective actions. When the regulator detects noncompliance, it first issues orders to ensure compliance, withdraw problematic products from the market or notify consumers of the risks. Only persistent noncompliance with these orders or total lack of cooperation leads to financial penalties.
Stage 2: Financial penalties - how much can they amount to?
Fines reach up to 10 times the average salary (currently about 80-90 thousand zlotys), but A maximum of 10% of the company's annual turnover. These are significant amounts of money that can make a real difference to a company's financial health. Penalty money feeds into the Accessibility Fund, creating a full cycle: from sanctions for barriers to investments in accessibility.
Who controls compliance with the law?
Supervision has been separated by sector - The UKE controls IT and telecommunications, the Financial Ombudsman controls banking, and transport inspectors control transportation services. The President of the Management Board of PFRON coordinates the entire system and can conduct cross-cutting inspections.
Most serious consequences: exclusion from public contracts
The most severe consequence may be exclusion from public contracts - particularly painful for companies working with the state sector. On top of that, there are reputational effects when information about violations is published on regulators' websites.
How do you protect yourself? Proactive compliance is the key
A key defense strategy is proactive compliance. Companies using harmonized standards (EN 301 549) receive a presumption of compliance with the law. Regular internal audits and full cooperation with regulatory authorities significantly reduce the risk of severe sanctions.
The system is designed as a progressive - authorities will favor solutions that enable compliance before the harshest penalties are applied. The goal is not to punish, but to actually make products and services more accessible to people with special needs.
Transitional regulations - how does the Polish Accessibility Act protect the market from chaos?
The Polish Accessibility Act was designed with the following in mind minimize economic disruption while ensuring progress in accessibility. The legislature applied the principle of „not to punish for the past, but to require in the future,” which translated into a thoughtful system of transitional provisions.
Products: „Legal status freeze”.”
If a product hit the market before June 28, 2025, it means that it was introduced in accordance with the regulations in effect at the time. Retroactively imposing new obligations would be unfair to businesses and could destabilize the market.
In practice, this means, that a product sold in May 2025 can be sold and serviced for its entire lifespan without having to comply with the requirements of the Accessibility Act. However, an identical model introduced after June 28, 2025 must already comply with all accessibility requirements.
The special situation of terminals: The legislator has taken into account that self-service terminals (ATMs, ticket machines) are investments with a long life cycle. A terminal installed in 2020 can be used until a maximum of 2040, regardless of availability requirements. This solution protects investments already made by banks, carriers and others.
Services: protection of concluded contracts
The principle of pacta sunt servanda in action - contracts concluded before the law's entry into force can be implemented unchanged until their natural expiration. The legislature recognized that forcing the renegotiation of thousands of contracts would be a disproportionate burden, but at the same time no longer than until June 2030 - here the legislature has set a maximum time limit.
A service company can use the products it used before the law took effect until 2030, even if they do not meet the new requirements.
Internet content: protecting the digital archive
The legislature recognized that requiring the adaptation of millions of already published materials would be technically impossible and economically unjustifiable.
A podcast recorded in 2024 does not have to have a transcript, but a new episode from July 2025 does.
In summary, exemptions include:
- Existing contracts (Article 85) - Service contracts entered into before June 28, 2025 may continue unchanged until June 28, 2030.
- „Old” Internet content (Article 86).
- Registered media published before the law came into force
- Document files published earlier
- Content archived, outdated since the law came into force
- Terminals (Article 85(3)) - Non-compliant terminals may be used for the duration of their economic useful life, max. 20 years from the start of use.
Strategic implications for business - time to decide
The following will follow in a moment moment of truth - from June 28, 2025 every new product introduced to the market and every new service must be fully compliant with accessibility requirements. There is no „implementation period” or „gradual adaptation” - compliance must be immediate and complete.
Entrepreneurs can consciously use the transitional regulations in their planning. Case in point: if your company plans to implement a new CRM system in 2026, it makes sense to design it in accordance with EN 301 549 today.
June 28 marks the end of the preparation period, but begins an era of new opportunities. The history of technology development shows that accessibility standards are no longer a „legal requirement” and are becoming the basis for innovation. Companies that understand this will shape the future of the Polish digital market.
In just a few days, every new product and service will have to meet accessibility requirements. There is no turning back from this transformation. Take the first step and learn how your company can gain an advantage through compliance with the Polish Accessibility Act.
Authors: Michał Klimowicz, Mateusz Banach
