Regulatory Decision 189/2025 on the Rights of End-Users of Electronic Communications, accessible contract information, summary contract and equivalent access and published information for end-users with disabilities

Regulatory Decision 189/2025 on the rights of end-users of electronic communications rests on Articles 4(3)(ζ), 29, 30, 31, 33, 34, 43 and 45 of the Regulation of Electronic Communications Law 24(I)/2022. Regulatory Decision 189/2025 was published in the Official Gazette on 27 June 2025. Article 47 puts Regulatory Decision 189/2025 in force from the date of its publication in the Official Gazette.

Article 30(1) of Law 24(I)/2022 has the Commissioner specify by regulatory decision the additional information that providers must give to consumers with specific forms of disability, so that those consumers have access to electronic communications services equivalent to those of the majority of end-users and the same choice of undertakings and services.

Article 4(1) requires providers to submit the standard contract text for their electronic communications services to the Commissioner for approval. Article 4(2) requires providers to give end-users the information that follows it clearly on a durable medium, or in an easily downloadable document where a durable medium is not feasible, and on request in a format accessible to end-users with disabilities.

Article 4(3) requires the minimum content of the standard contract to include the details of products and services designed for end-users with disabilities and how updates of that information can be obtained. Article 7(1) requires providers, other than providers of transmission services used for machine-to-machine services, to give end-users a short and legible summary contract in the format of Implementing Regulation (EU) 2019/2243.

Article 7(2)(ε) requires the summary contract to state the extent to which products and services are designed for end-users with disabilities, including, where available, at least real-time text, total conversation, relay services, accessible emergency communications, special equipment, special tariffs and accessibility information.

Article 7(3) requires providers to give the completed summary contract to end-users free of charge before the contract is concluded, or, where that is objectively impossible at that moment for technical reasons, later and without undue delay, in which case the contract takes effect when the end-user confirms agreement after receiving it.

Article 8 requires providers of internet access services and publicly available interpersonal communications services to publish comprehensible, comparable, reliable, user-friendly and up-to-date information on the quality of their services, to the extent that they control at least some elements of the network, and on the measures taken to ensure equivalent access for end-users with disabilities.

Article 9 requires providers of publicly available electronic communications services to publish comprehensible, comparable, reliable, user-friendly and up-to-date information on the measures taken to ensure equivalent access for end-users with disabilities.

Article 9 requires that information to be published on a dedicated web page of the provider or on its existing web page, in a form that is clear, comprehensible, machine-readable and accessible to end-users with disabilities in accordance with the Union law harmonising accessibility requirements for products and services.

Article 9 provides that end-users with disabilities have access to electronic communications services, including the information in the Decision, and the possibility of choosing between undertakings and services.

Article 12(1) empowers the Commissioner to require providers of internet access services and publicly available interpersonal communications services to publish the listed information in a clear, easily accessible and comprehensible form for end-users with disabilities, and to specify additional requirements for that form.

The information listed in Article 12(1)(β)(vi) includes the details of products and services, with their functions, practices, policies and procedures and any changes to how the service operates, that are specially designed for end-users with disabilities. Article 28(1) of Law 24(I)/2022 disapplies Articles 29 to 34 for very small enterprises that provide number-independent interpersonal communications services, unless they also provide other electronic communications services.

Article 42 lets an end-user complain in writing to the Commissioner only after first complaining in writing to the provider. Article 45 lets the Commissioner impose sanctions under Article 43 of the Law where the relevant legislation or another binding decision of the Commissioner is breached. Article 43(2) of Law 24(I)/2022 caps the Commissioner's administrative fine at EUR 200,000 and, for a repeated infringement, at EUR 400,000.

Article 43(2) also lets the Commissioner add a fine of not more than EUR 1,000 for each day an infringement continues, or the provider does not comply after notice of the initial fine. Article 46(10) of Law 24(I)/2022 makes it an offence, punishable by imprisonment of up to six months, a fine of up to EUR 850, or both, for a person without reasonable cause to fail to comply with the terms of a regulatory decision of the Commissioner.

Article 43(1) of Law 24(I)/2022 also lets the Commissioner impose other administrative sanctions or revoke licences where it finds a breach. Article 46(1) of Law 24(I)/2022 makes it an offence, punishable by imprisonment of up to six months, a fine of up to EUR 5,000, or both, for a person to provide an electronic communications network or service otherwise than as the Law, a general authorisation under it or the Commissioner's regulatory decisions lay down.

Section 2 of the Interpretation Law reads a person to include a company, cooperative, association, society, foundation or body of persons, with or without legal personality. Regulatory Decision 189/2025 repeals the Electronic Communications Consumer Protection Order of 2018.

Article 102(1) of Directive (EU) 2018/1972 requires providers of publicly available electronic communications services to provide the pre-contract information, upon request, in an accessible format for end-users with disabilities in accordance with Union law harmonising accessibility requirements for products and services.

Article 102(3) of Directive (EU) 2018/1972 requires providers to give consumers a concise and easily readable contract summary that includes the extent to which the products and services are designed for end-users with disabilities.

Article 103(1) of Directive (EU) 2018/1972 requires the information in Annex IX to be published in a clear, comprehensive, machine-readable manner and in an accessible format for end-users with disabilities in accordance with Union law harmonising accessibility requirements for products and services.

Article 104(1) of Directive (EU) 2018/1972 allows the national regulatory authorities to require providers to publish information on the quality of their services and on measures taken to ensure equivalence in access for end-users with disabilities.

Article 111(1) of Directive (EU) 2018/1972 requires Member States to ensure that the competent authorities specify the requirements that providers of publicly available electronic communications services must meet so that end-users with disabilities have access, equivalent to that of the majority of end-users, to those services and to the related contractual information, and the same choice of undertakings and services.