Applicable Framework for Accessibility in Other European Countries

For private sector actors, the legal framework regarding accessibility stems from the transposition of European Union Directive (EU) 2019/882, known as the European Accessibility Act (EAA).

Framework Applicable in Luxembourg #

• Directive (EU) 2019/882 has been transposed into Luxembourg law by the Law of March 8, 2023, amended by the Law of August 29, 2023.
• The law comes into force on June 28, 2025.

Accessibility Requirements and Obligations for Companies: #

Luxembourg’s transposition of the EAA aligns with the directive’s requirements without exceeding them. Accessibility requirements are therefore those of the harmonized standard EN 301 549 (whose next version will be available in February 2026), equivalent to WCAG 2.1 level AA. Harmonized standards related to non-digital accessibility requirements for products or assistive services are not yet available. Their publication is expected by March 2026.

Obligations for companies are the same as those in France.

Control and Sanctions: #

Control Authority:

• Office for the Monitoring of Accessibility of Products and Services (OSAPS).

Sanctions:

• The law provides for administrative sanctions ranging from €250 to €15,000 and criminal sanctions between €251 and €500,000 (or €1,000,000 in case of proven recidivism).

Framework Applicable in Belgium #

• Directive (EU) 2019/882 has been almost entirely transposed into Belgian law. Regarding the sectors of the Orange Group, six different laws cover the obligations of the EAA. This fragmentation of Belgian law is largely due to the country’s political organization.
• The law enters into force on June 28, 2025.

Accessibility Requirements and Obligations for Companies: #

Belgium’s transposition of the EAA aligns with the directive’s requirements without exceeding them. Accessibility requirements are those of the harmonized standard EN 301 549 (next version available in February 2026), equivalent to WCAG 2.1 level AA. Harmonized standards for non-digital accessibility requirements for products or assistive services are not yet available. Their publication is expected by March 2026.

Obligations for companies are similar to those in France.

Control and Sanctions: #

Control Authorities:

• Belgian Institute for Postal Services and Telecommunications (IBPT) (for products, electronic communication services, and audiovisual media services in the bilingual Brussels-Capital region).
• Economic Inspection (for banking and e-commerce sectors).

Sanctions:

• For IBPT: administrative sanctions up to €200,000.
• For Economic Inspection: administrative sanctions between €200 and €8,000, and criminal sanctions between €400 and €16,000.

Framework Applicable in Slovakia #

• Directive (EU) 2019/882 has been fully transposed into Slovak law by Act No. 351/2022 and related regulations.
• The law comes into force on June 28, 2025.

Accessibility Requirements and Obligations for Companies: #

Slovakia’s transposition of the EAA aligns with the directive’s requirements without exceeding them. Accessibility requirements are those of the harmonized standard EN 301 549 (next version available in February 2026), equivalent to WCAG 2.1 level AA. Standards related to non-digital accessibility requirements for products or assistive services are not yet available. Their publication is expected by March 2026.

Obligations for companies are relatively similar to those in France. However, in case of non-compliance, a maximum period of 12 months is allowed to achieve conformity. Additionally, accessibility declarations (for services) are valid for five years.

Control and Sanctions: #

Control Authorities:

• Slovak Trade Inspection (SOI) (for products, banking services, and e-commerce services).
• Electronic Communications and Postal Services Regulatory Authority (Teleoff) (for electronic communications).
• Media Services Council (CSM).

Sanctions:

• Up to €30,000 administrative sanctions for SOI.
• Up to €3,000 administrative sanctions for Teleoff and CSM.

Framework Applicable in Poland #

• Directive (EU) 2019/882 has been fully transposed into Polish law by the Law of April 26, 2024.
• The law enters into force on June 28, 2025.

Accessibility Requirements and Obligations for Companies: #

Poland’s transposition of the EAA aligns with the directive’s requirements without exceeding them. Accessibility requirements are those of the harmonized standard EN 301 549 (next version available in February 2026), equivalent to WCAG 2.1 level AA. Standards for non-digital accessibility requirements for products or assistive services are not yet available. Their publication is expected by March 2026.

Obligations for companies are similar to those in France. The law also includes a section dedicated to consumer rights, requiring companies to respond to complaints within 30 days (or 90 if the request is complex and justified). Companies must also provide a clear identifier of the complainant and describe the available mechanisms for recourse (internal or external).

Control and Sanctions: #

Control Authority:

• A market surveillance system composed of the President of the State Fund for Rehabilitation of Disabled Persons, customs authorities, and various sectoral market surveillance authorities.
• These include the Minister responsible for digitization or the Office of Electronic Communications.

Sanctions:

• The risk of sanctions is ten times the average salary of the previous year in Poland. In 2024, this could amount to approximately 80,000 zlotys (around €20,000).

Framework Applicable in Spain #

• Directive (EU) 2019/882 has been fully transposed into Spanish law by Law 11/2023 of May 8, 2023.
• The law enters into force on June 28, 2025.

Accessibility Requirements and Obligations for Companies: #

Spain’s transposition of the EAA aligns with the directive’s requirements without exceeding them. Accessibility requirements are those of the harmonized standard EN 301 549 (next version available in February 2026), equivalent to WCAG 2.1 level AA. Standards related to non-digital accessibility requirements for products or assistive services are not yet available. Their publication is expected by March 2026.

Obligations for companies are similar to those in France. Additionally, the law mandates training for all relevant actors involved in service provision.

Control and Sanctions: #

Control Authority:

Market surveillance is entrusted to existing sectoral authorities. However, the law does not specify these authorities precisely. The following list is not exhaustive:

• National Commission for Markets and Competition (CNMC) (for electronic communications, audiovisual services, and e-commerce).
• Bank of Spain (for banking services).

Sanctions:

Sanction regimes include minor, serious, and very serious violations, with corresponding fines. The exact scope remains difficult to predict due to the lack of detailed definitions.

Framework Applicable in Romania #

• Directive (EU) 2019/882 has been fully transposed into Romanian law by Law of July 25, 2022.
• The law comes into force on June 28, 2025.

Accessibility Requirements and Obligations for Companies: #

Romania’s transposition of the EAA aligns with the directive’s requirements without exceeding them. Accessibility requirements are those of the harmonized standard EN 301 549 (next version available in February 2026), equivalent to WCAG 2.1 level AA. Standards for non-digital accessibility requirements for products or assistive services are not yet available. Their publication is expected by March 2026.

Obligations for companies are the same as those in France.

Control and Sanctions: #

Control Authority:

• Consumer Protection Authority (ANPC) (for products).
• National Authority for Management and Regulation of Communications (ANCOM) (for telecommunications).
• National Audiovisual Authority (CNA) (for audiovisual media).

Sanctions:

• Administrative sanctions up to 15,000 lei (approximately €3,000).

Framework Applicable in Moldova #

Although Moldova is not yet a member of the European Union, it obtained candidate status in 2022. According to the Copenhagen criteria, it must gradually adopt the acquis communautaire, including the EAA. A draft law transposing the EAA is underway and should be finalized by December 2025.