Law / Estonia

Social Affairs Minister Regulation No. 45, functional accessibility requirements for products and services and requirements on the information given about them

Sotsiaalkaitseministri määrus nr 45 „Toote ja teenuse funktsionaalsed ligipääsetavusnõuded ja nõuded nende kohta antavale teabele” (RT I, 15.06.2022, 5)

In force since 28 Jun 2025.

An accessibility requirements rule binding public and private bodies.

Instrument type: a regulation made under an act

What it requires

Where the nature of the product allows, give information on how the product works and on its accessibility elements in or on the product; make the instructions for use cover the accessibility functions and how to activate them, and present information on using the product, including labeling, instructions and warnings, so that it is perceivable through more than one sense, understandable, and set in contrasting type that takes expected user needs into account; make instructions found on a website or otherwise available in a text format that can be used to create alternative assistive formats, with non-text content presented in an alternative way; and make the instructions describe the product's user interface and functionality against section 7 and the software and hardware that interface with assistive devices, with a list of the assistive devices tested with the product (s. 6(1) to (6)).
Make a product and its user interface perceivable, usable, understandable and controllable by a person with a disability: operating modes usable with limited reach and strength, no triggering of photosensitive seizures, an alternative to biometric identification, functional consistency with enough flexible time for interaction, connection to assistive technologies, and protection of user privacy when accessibility elements are used (s. 7(1) and (2)).
Offer alternatives to speech, voice, visual elements, sound and color or sound signals used to convey information, request a response or identify elements, flexible magnification, brightness and contrast, adjustable volume and speed, and manual operation that can be sequenced and uses tactilely distinguishable parts (s. 7(3) to (9)).
Make the packaging of the product, and the information on it about opening, closing, use and disposal, accessible, and add existing information about the product's accessibility features where possible; these requirements on packaging and web-based instructions do not apply to a self-service terminal (ss. 1(4) and 8).
When providing a service, give information on how the service works, on the accessibility features of the product used and on its interoperability with assistive technologies, and, where a support service exists, give information on the accessibility of the product or service and its compatibility with assistive technologies through accessible means of communication (s. 9).
When providing a service, ensure the accessibility of the product used to provide it, and make a website and a mobile-device-based service perceivable, usable, understandable and robust (s. 10).
If you provide a self-service terminal, include speech synthesis, allow personal headphones, warn the user through more than one sense when response time is limited, allow the time for use to be extended, give it sufficient contrast and tactilely distinguishable keys and controls where they exist, make it compatible with assistive technologies when it uses audio signals, and allow a user with a disability access without activating an accessibility element (s. 11).
If you supply an e-reader, give it a function for audio presentation of text (s. 12).
If you supply consumer terminal equipment used for electronic communications services, allow real-time text and support high-level audio devices where it sends text and voice, allow total conversation where it also sends video, make it compatible with hearing technologies over a wireless connection, and do not let its functions disturb assistive technology (s. 13).
If you supply consumer terminal equipment used to access audiovisual media services, make available to a user with a disability the accessibility elements the service provider transmits, for access, selection, control, personalization and transfer to assistive devices (s. 14).
If you provide an electronic communications service, allow real-time text in addition to voice and text, allow synchronized total conversation where video is used, and ensure an emergency connection that allows an emergency message to be answered in the same format in which it was received, with voice and text (including real-time text) synchronized, or voice, text and video synchronized in total conversation where video is used (s. 16; Directive (EU) 2019/882, Annex I, Section IV, point (a)).
If you provide a service giving access to audiovisual media services, offer perceivable, usable, understandable and robust electronic program guides that give information on the availability of accessibility features, deliver the accessibility elements (subtitles for the deaf and hard of hearing, audio description, spoken subtitles and sign-language interpretation) completely and in sufficient quality with synchronized sound and video, and let the user adjust display and use (s. 17).
If you provide a long-distance air, bus, rail or waterborne passenger transport service, give information on the accessibility of the vehicle, the surrounding infrastructure and the built environment and on assistance for users with disabilities, on the smart ticketing system and its functions, on real-time travel information and on the availability of additional services, and meet the service requirements of sections 9 and 10 (s. 18); for municipal, city and county lines, make the self-service terminals accessible under sections 6, 7, 9, 10(1) and 11 (s. 19).
If you provide a financial service, make the authentication methods, electronic signatures, payment instructions, execution of payment transactions and security measures, including blocking a payment instrument, perceivable, usable, understandable and robust, and give information that is understandable and not more complex than level B2 of the Common European Framework of Reference for Languages (s. 20).
If you provide an e-book service, present text and sound synchronously where an e-book contains both, make the digital file let assistive technology work properly, let a user with a disability access, navigate and perceive the structure of the content and use it flexibly, make alternative presentations of the content and its interoperability with assistive technologies perceivable, understandable, operable and robust, make the e-book findable through metadata on its accessibility elements, and make the accessibility elements usable regardless of digital rights management measures (s. 21).
If you provide an e-commerce service, include information on the accessibility of the product or service sold when the responsible business has made it available to you beforehand, and make the authentication, electronic signature and payment methods and the security functions perceivable, usable, understandable and robust (s. 22).
Use the functional performance criteria of sections 24 to 29 only as an alternative to a technical requirement and only where they lead to equivalent or better access for a user with a disability; they cover at least one mode that eases cognitive use, privacy in the accessibility elements, a visual mode for limited vision and one that needs no vision, a mode that needs no color perception, an auditory mode with enhanced audio and one that needs no hearing, a mode that needs no voice input, and a manual mode that needs no fine motor control and works within limited reach (ss. 24 to 29).

These lines are LexLint's reading of the law's text.

If you get it wrong

Penalty structure

Section 20 of the LPS sets the fine for providing a service that does not meet the accessibility requirements at up to 100 fine units (up to EUR 800) for a natural person and up to EUR 20,000 for a legal person. For products, section 2(13) of the LPS applies the Product Conformity Act, whose section 59 sets up to 300 fine units (up to EUR 2,400) for a natural person and up to EUR 32,000 for a legal person for infringing the conditions for placing a product on the market and making it available, and whose section 61 sets up to 200 fine units (up to EUR 1,600) and up to EUR 32,000 for misuse of the conformity marking. The fine unit is EUR 8 from 1 January 2025 (Penal Code section 47(1)). Section 19 of the LPS sets the ceiling of the penalty payment (sunniraha) for a precept not complied with at EUR 10,000.

Rule: Fixed only
As of: 5 November 2026
Currency: EUR
Fixed cap: 32,000

Who enforces it

Enforcement body

the Consumer Protection and Technical Regulatory Authority (Tarbijakaitse ja Tehnilise Järelevalve Amet, TTJA), the supervisory authority under section 16 of the LPS

What this law does

Drafted with AI

Drafted with AI from the cited sources under the direction of UnGovr staff. UnGovr holds editorial responsibility for this page. How this site is made

Research summary

Legal information, not legal advice. This is LexLint's own research summary of a public legal source, and it creates no attorney-client relationship. For decisions that matter, consult qualified counsel in the relevant jurisdiction. About LexLint

Regulation No. 45 of the Social Affairs Minister is made under section 4(4) of the LPS. Section 1 applies the Regulation to the products and services within the LPS and to the information given about them, and to a service also when it is provided through a website or mobile application.

Section 6 requires information on how a product works and on its accessibility elements to be given in or on the product where possible, and requires the instructions for use to cover the accessibility functions and how to activate them.

Section 6(4) requires information on the use of the product, including labeling, instructions and warnings, to be perceivable through more than one sense, presented in an understandable and perceivable way, and set in contrasting type that takes expected user needs into account.

Section 6(5) requires instructions for using, installing, maintaining, storing and disposing of a product that are found on a website or otherwise to be available in a text format that can be used to create alternative assistive formats, and to present non-text content in an alternative way.

Section 6(6) requires the instructions on the product's accessibility functions, labeling, use and warnings to describe its user interface and functionality against the requirements of section 7 and to describe the software and hardware that interface with assistive devices, with a list of the assistive devices tested with the product.

Section 7 requires a product and its user interface to contain features, elements and functions that let a person with a disability perceive, use, understand and control the product.

Section 7(2) requires a product to have operating modes usable with limited reach and strength, not to trigger photosensitive seizures, to offer an alternative to biometric identification, to be functionally consistent and allow enough flexible time for interaction, to allow connection to assistive technologies, and to protect user privacy when accessibility elements are used.

Section 10 requires the service provider to ensure the accessibility of the product used to provide the service, and requires a website and a mobile-device-based service to be made accessible in a consistent and appropriate manner by making it perceivable, usable, understandable and robust.

Section 11 requires a self-service terminal to include speech synthesis technology, to allow the use of personal headphones, to warn the user through more than one sense when response time is limited, to allow the time allowed for use to be extended, to have sufficient contrast and tactilely distinguishable keys and controls where they exist, to be compatible with assistive technologies when it uses audio signals, and to allow a user with a disability access without activating an accessibility element.

Section 12 requires an e-reader to have a function for audio presentation of text. Section 13 requires consumer terminal equipment used for electronic communications services to allow real-time text and to support high-level audio devices where it can send text, to allow total conversation where it can also send video, to be compatible with hearing technologies over a wireless connection, and not to disturb the operation of assistive technology.

Section 14 requires terminal equipment used to access audiovisual media services to make available to a user with a disability the accessibility elements that the service provider transmits, for access, selection, control, personalization and transfer to assistive devices.

Section 16 requires an electronic communications service to allow real-time text in addition to voice and text, to allow synchronized total conversation where video is used, and to ensure an emergency connection that allows an emergency message to be answered in the same format in which it was received.

Section 17 requires a service giving access to audiovisual media services to offer perceivable, usable, understandable and robust electronic program guides, to deliver the accessibility elements of the media service completely and in sufficient quality with synchronized sound and video, and to let the user adjust display and use.

Section 17(3) lists the accessibility elements of an audiovisual media service as subtitles for the deaf and hard of hearing, audio description, spoken subtitles and sign-language interpretation.

Section 18 requires a long-distance air, bus, rail and waterborne passenger transport service to meet the information requirements of section 9 and the service requirements of section 10, and requires information to be given on the accessibility of the vehicle, the surrounding infrastructure and the built environment and on assistance for users with disabilities, on the smart ticketing system, on real-time travel information and on the availability of additional services.

Section 20(1) requires the authentication methods, electronic signatures, payment instructions, execution of payment transactions and security measures used to provide a financial service, including blocking a payment instrument, to be perceivable, usable, understandable and robust.

Section 20(2) requires information given in providing a financial service to be understandable and its complexity not to exceed level B2 of the Council of Europe's Common European Framework of Reference for Languages.

Section 21 requires the text and sound of an e-book that contains both to be presented synchronously, the digital file to let assistive technology work properly, and a user with a disability to be able to access, navigate and perceive the structure of the e-book content and to use it flexibly.

Section 22 requires the information given in an e-commerce service to include information on the accessibility of the product or service sold when the responsible business has first made it available to the seller, and requires the authentication, electronic signature and payment methods and the security functions to be perceivable, usable, understandable and robust.

Section 24(2) provides that the functional performance criteria are used as an alternative to a technical requirement, and only where they lead to equivalent or better access for a user with a disability. Section 30 applies the Regulation to products placed on the market and services provided from 28 June 2025, taking account of the exceptions in section 22 of the LPS. Section 19 of the LPS sets the ceiling of the penalty payment for a precept that is not complied with at EUR 10,000.

Section 20 of the LPS sets the fine for providing a service that does not meet the accessibility requirements at 100 fine units at most for a natural person and EUR 20,000 at most for a legal person.

Section 2(13) of the LPS applies the Product Conformity Act to the obligations of the manufacturer, authorized representative, importer and distributor of a product within the Act, to the conformity assessment of the product, to market surveillance and to liability, with the exceptions that follow from the LPS.

Section 59 of the Product Conformity Act sets the fine for infringing the conditions for placing a product on the market and making it available at up to 300 fine units for a natural person and up to EUR 32,000 for a legal person. Section 61 of the Product Conformity Act sets the fine for misuse of the conformity marking at up to 200 fine units for a natural person and up to EUR 32,000 for a legal person. Section 47(1) of the Penal Code sets the fine unit at EUR 8.

When LexLint raises it

When your app profile says your app ships a consumer interface, ships a mobile app, provides telecom services, provides financial services or distributes a software product.

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Page updated 5 November 2026.