Accessibility Act, products: duties of manufacturers, authorised representatives, importers and distributors, conformity, market surveillance and fines

Nr. XIV-1633, 2 str. 2 ir 3 d., 7–12, 14–19 ir 21–28 str., Gaminių ir paslaugų prieinamumo reikalavimų įstatymas (gaminiai)

In force since 28 Jun 2025.

An accessibility requirements rule binding public and private bodies.

What it requires

If you place on the market a consumer general-purpose computer hardware system or operating system, a self-service terminal (payment terminal, ATM, ticketing machine, check-in machine or interactive information terminal for a covered service), consumer terminal equipment for electronic communications, a device for access to audiovisual media services or an e-reader, make it meet the accessibility requirements of Annex 1 (Art. 2(2), 7(1)); the Act has applied since 28 June 2025 (Art. 30(1)).
As a manufacturer, design and make the product to the Annex 1 requirements (Art. 8(1)), draw up the technical documents, carry out or commission the conformity assessment, draw up the EU declaration of conformity in the Decision No 768/2008/EC form translated into Lithuanian, and affix the CE marking (Art. 8(2), 16, 17(1)).
Give the information on the use of the product that is on the product itself (labelling, instructions and warnings) through more than one sensory channel, in an understandable and perceivable way, in a font of adequate size and shape for the foreseeable conditions of use, with sufficient contrast and adjustable spacing between letters, lines and paragraphs (Annex 1, point 2.1).
Where instructions for use, including on the product's accessibility functions, how to activate them and their interoperability with assistive solutions, are given other than on the product (for instance on a website), make them publicly available when the product is placed on the market, through more than one sensory channel, in text formats from which alternative assistive formats can be generated, with an alternative presentation of any non-text content, and include a description of the user interface, of the functionality, and of the software and hardware interfacing with assistive devices, with a list of the assistive devices tested with the product (Annex 1, point 2.2).
Design the product, its user interface included, so that persons with disabilities can access, perceive, operate, understand and control it: more than one sensory channel for communication and operation, alternatives to speech and voice input, flexible magnification, brightness and contrast, alternatives to color and to auditory signals, user control of volume and speed, sequential control and alternatives to fine motor control, no modes of operation needing extended reach or great strength, no triggering of photosensitive seizures, protection of the user's privacy while using accessibility features, an alternative to biometric identification and control, consistent functionality with enough and flexible time for interaction, and software and hardware for interfacing with assistive technologies (Annex 1, point 3).
For products other than self-service terminals, make the packaging and the information on it accessible, on the packaging where possible, and make instructions for installation, maintenance, storage and disposal that are given other than on the product publicly available when it is placed on the market, under the same presentation rules (Annex 1, point 4).
Where possible, have your support services (help desks, call centers, technical support, relay and training services) give information on the product's accessibility and its compatibility with assistive technologies through accessible means of communication (Annex 1, point 5).
For self-service terminals, provide text-to-speech technology, allow the use of personal headsets, warn the user through more than one sensory channel where a response must be given within a time limit, allow the time to be extended, give appropriate contrast and tactually discernible keys and controls where there are any, do not require an accessibility feature to be activated before the user who needs it can turn it on, and make sound or audio signals compatible with assistive devices and technologies available at EU level, hearing technology included (Annex 1, point 6).
For e-readers, provide text-to-speech technology (Annex 1, point 7).
For consumer terminal equipment with interactive computing capability used for electronic communications services: where it has text capability besides voice, handle real-time text and support high-fidelity audio; where it has video capability, handle total conversation, including synchronized voice, real-time text and video at a resolution that allows communication in sign language; ensure effective wireless coupling to hearing technologies; and avoid interference with assistive devices (Annex 1, point 8).
For consumer interactive devices for access to audiovisual media services, let persons with disabilities use the accessibility components the audiovisual media service provider supplies, for user access, selection, control and personalization and for transmission to assistive devices (Annex 1, point 9).
Where the requirements in Chapters I to V of Annex 1 do not cover a function of the product or the service, make it accessible by meeting the related functional performance criteria of Chapter VI; those criteria may replace a specific technical requirement only where they give equivalent or greater accessibility (Annex 1, points 15 to 17).
As a manufacturer, keep the technical documents and the EU declaration of conformity for 5 years from the day the product is placed on the market, and keep procedures that keep series production in conformity (Art. 8(3)-(4)).
As a manufacturer, put a type, batch or serial number on the product (or on the packaging or accompanying document), your name or trade mark and a contact e-mail or business address, and supply instructions and safety information that consumers can easily understand (Art. 8(5)-(7)).
As a manufacturer, if you find or have reason to believe a product you placed on the market does not meet the accessibility requirements, within 3 working days of learning of it take the measures needed to bring it into conformity or withdraw it, and inform the market surveillance authority; register non-conforming products and the complaints about them (Art. 8(8)-(10)).
As a manufacturer, on the authority's reasoned request give it in writing, within the period it sets (not shorter than 3 working days), the information and documents needed to show conformity, and cooperate in corrective action (Art. 8(11)).
As an importer or distributor, you are treated as the manufacturer, with the manufacturer's duties, if you place a product on the market under your own name or trade mark or modify a product already on the market so that its conformity may be affected (Art. 8(12)).
As an authorised representative, act under a written mandate that cannot cover the manufacturer's design duty in Art. 8(1) or drawing up the technical documents; the mandate must require you to keep the EU declaration of conformity and technical documents for 5 years, give the authority the information and documents it asks for, and cooperate with it (Art. 9).
As an importer, place only conforming products on the market; before doing so make sure the conformity assessment was carried out, the technical documents exist, the CE marking and required documents are present and the manufacturer has marked the product and supplied instructions (Art. 10(1)-(2), (5)).
As an importer, do not place a product on the market while you have reason to believe it does not conform; if it does not conform, within 3 working days of learning of it inform the manufacturer and the authority in writing, giving your name and company code or your name and surname, and contact details (Art. 10(3)).
As an importer, show your name, trade name or trade mark and a contact e-mail, business address or telephone number on the product, packaging or accompanying document, keep storage and transport conditions from endangering conformity, and keep a copy of the EU declaration of conformity for 5 years while keeping the technical documents available to the authority (Art. 10(4), (6)-(7)).
As an importer, if you have reason to believe a product you placed on the market does not conform, at once take corrective measures or withdraw it, inform the authority within 3 working days, register non-conforming products and complaints, and give the authority the information and documents it asks for within the period it sets (not shorter than 3 working days) (Art. 10(8)-(9)).
As a distributor, before making a product available verify the CE marking, the required documents, instructions and safety information, and that the manufacturer and importer met their marking duties; do not supply a product you believe does not conform, and inform the manufacturer or importer and the authority in writing within 3 working days of learning of the non-conformity (Art. 11(2)-(3)).
As a distributor, keep storage and transport conditions from endangering conformity, take or ensure corrective measures for a product you believe does not conform, inform the authority within 3 working days, and give the authority the information and documents it asks for within the period it sets (not shorter than 3 working days) (Art. 11(4)-(6)).
As a manufacturer, authorised representative, importer or distributor, identify to the authority on request each operator that supplied you the product and each operator you supplied it to, and be able to do so for 5 years after the product was supplied to you and for 5 years after you supplied it (Art. 12).
The accessibility requirements apply only to the extent that compliance does not require a significant change that fundamentally alters the product's basic nature and does not impose a disproportionate burden on the operator (Art. 14(1)).
To rely on that limit, carry out the assessment against the criteria in Annex 2, document it, keep the report for 5 years after the product was last made available on the market, and give the authority a copy in writing within the period it sets (not shorter than 3 working days) (Art. 14(2)-(3)); the Act puts these duties on every economic operator, a term Art. 3(3) defines to include importers and distributors, and sets no separate rule for an importer or distributor of a product whose manufacturer relies on the limit.
If you rely on the limit for a product, send the information in the assessment report to the authority in writing, in the way it sets, at once and within 3 working days of carrying out the assessment; name in the EU declaration of conformity the requirements for which the limit is used (Art. 14(7), 16(1)).
You cannot rely on the disproportionate-burden limit if you receive funding for improving accessibility from other public or private sources rather than using your own resources (Art. 14(6)).
A very small enterprise that makes products does not have to prepare the assessment report, but if it relies on the limit it gives the authority on request, within the period set (not shorter than 3 working days), the facts relevant to the assessment, and it is not bound by the notification duty of Art. 14(7) (Art. 14(4), (7)).
As a manufacturer, where several EU acts require an EU declaration of conformity draw up a single declaration for all of them; by drawing it up you take responsibility for the product's conformity (Art. 16(3)-(4)).
As a manufacturer, draw the technical documents up so that conformity can be assessed against the applicable requirements; if you rely on Art. 14, show that the requirements would require a fundamental alteration or impose a disproportionate burden (Art. 16(5)).
As a manufacturer, take all necessary measures so that the production process and its monitoring keep the products in conformity with the technical documents and the requirements, and run internal production control (Art. 16(6)-(7)).
As a manufacturer, mark each conforming product with the CE marking before placing it on the market, visibly, legibly and indelibly on the product or its data plate or, if that is impossible, on the packaging and the accompanying documents, applying the general principles in Art. 30 of Regulation (EC) No 765/2008 (Art. 17(1)).
Make sure all appropriate action is taken in respect of all the products you have placed on the market throughout the EU (Art. 19(7)).
Products that meet harmonised standards or technical specifications, or parts of them, whose references the EU has published in the Official Journal are presumed to meet the applicable accessibility requirements to the extent those standards or specifications cover them (Art. 15(1)-(2)).
Take the corrective action the authority requires within the period it sets (not shorter than 3 working days); if it orders withdrawal because you took none, withdraw the product at your own cost within the period it sets and report to it in writing within 3 working days, naming yourself, the action taken and its date (Art. 19(2)-(3), (5)).
Bring a product into conformity if it carries the CE marking in breach of the marking rules, lacks the CE marking, lacks or has an incorrect EU declaration of conformity, lacks or has incomplete technical documents, or breaches another duty of Art. 8 or 10; otherwise the authority restricts or bans supply or has the product withdrawn, and recovers its costs from you (Art. 19(8), (12)-(13)).
Keep a product subject to a ban or restriction on supply separate in your warehouse from other products, and treat the authority's decisions on banning or restricting supply as enforceable from receipt unless they set a later date (Art. 19(14)-(15)).
During an inspection carry out the authority's lawful instructions and demands, give officials access to the territory, buildings and premises where products are made, sold or stored, appoint a person to take part, and give them the information, data and documents needed, whatever the medium (Art. 21(4)).

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

If you get it wrong

Penalty structure

Article 23(1) sets a fine of EUR 500 to 2,500 for an economic operator that places on the market or supplies a product, or provides a service, that does not meet the accessibility requirements. Article 23(2) sets EUR 1,000 to 6,500 for disregarding the authority's ban or restriction on placing or supplying non-conforming products, or its order to withdraw, recall or destroy a product, or for continuing to provide a service after the authority has ordered it to stop. Article 23(3) sets EUR 2,500 to 15,000 where non-conforming products or services have harmed the health of a consumer or end user. Under Article 23(4) the fine is set at the mean of the minimum and the maximum, lowered toward the minimum for the mitigating circumstances and raised toward the maximum for the aggravating circumstances in Article 24, and the authority gives reasons for any adjustment. Article 23(6) allows a warning instead of a fine under Article 23(1) where a non-conforming product that has not reached consumers is voluntarily withdrawn by the operator that supplied it. The market surveillance authority examines the violation and imposes the fine under Article 26(1), within 5 years of the violation under Article 25, and a fine does not relieve the operator of compensating consumers or of withdrawing the product or stopping the service under Article 23(5). Article 23(4) also takes account of the nature, duration and extent of the violation. For a continuing violation the 5 years in Article 25 run from the day the violation comes to light. Article 22 makes an economic operator that breaches the Act liable under the procedure the Act itself sets. Under Article 28(1) the fine is paid into the State budget within one month of the day the operator receives the decision, and under Article 27(2) going to court does not suspend execution of a decision unless the court rules otherwise. From 30 June 2026 Article 28(2), as amended by Act No. XV-907, makes a decision imposing a fine an enforcement document executed under the Law on Tax Administration and the Code of Civil Procedure; a fine decision adopted and in force by 29 June 2026 is executed under the provisions in force until that day (Act No. XV-907, Article 2(2)).

Rule: Fixed only
As of: 7 November 2026
Minimum: 500
Currency: EUR
Fixed cap: 15,000

Who enforces it

Enforcement body

The State Consumer Rights Protection Authority (Valstybinė vartotojų teisių apsaugos tarnyba, VVTAT) for all the products in Article 2(2) under Article 6(4); the Lithuanian Transport Safety Administration (Lietuvos transporto saugos administracija) for products that are interoperable constituents of the rail system under Article 6(5)

What it reaches

Instrument type

an act of a legislature

Applicability criteria

Article 2(2) lists the products. A very small enterprise that makes products is not exempt: Article 14(4) and 16(8) lighten its documentation duties only.

As of

7 November 2026

Combinator

Any of

Criteria

consumer general-purpose computer hardware systems and the operating systems made for them, placed on the market of Lithuania
self-service terminals: payment terminals, and ATMs, ticketing machines, check-in machines and interactive information self-service terminals used to provide a service the Act covers, except terminals built into vehicles, aircraft, ships or rolling stock
consumer terminal equipment with interactive computing capability used for electronic communications services
consumer interactive devices for access to audiovisual media services
e-readers: special equipment, hardware and software included, for access to e-book files and for browsing, reading and otherwise using them

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

Article 2(1) applies the Act to economic operators that supply the products listed in Article 2(2) or provide the services listed in Article 2(4), and does not distinguish public from private ownership. Article 3(3) defines an economic operator as a manufacturer, authorised representative, importer, distributor or service provider. Article 2(2) covers the hardware systems of consumer general-purpose computers and the operating systems made for them.

Article 2(2) covers self-service terminals, namely payment terminals and the ATMs, ticketing machines, check-in machines and interactive information terminals used for the services the Act covers, except terminals built into vehicles, aircraft, ships or rolling stock. Article 2(2) also covers consumer terminal equipment with interactive computing capability that is used for electronic communications services, consumer devices for access to audiovisual media services, and e-readers.

Article 2(3) requires a product that is also an interoperable constituent of the rail system to meet the rail interoperability specifications as well, and assesses its conformity under the Law on Railway Transport Traffic Safety and the Act. Article 7(1) requires economic operators to ensure that the products they place on the market meet the accessibility requirements set out in Annex 1. Chapter I of Annex 1 sets the accessibility requirements for all the products.

Chapter II of Annex 1 sets accessibility requirements that apply to certain products, beginning with self-service terminals. Point 7 of Annex 1 requires e-readers to provide text-to-speech technology. Point 15 of Annex 1 requires a function of a product or a service that Chapters I to V of Annex 1 do not cover to be made accessible by meeting the related functional performance criteria.

Article 15(1) presumes that products which meet harmonised standards, or parts of them, whose references the European Union has published in its Official Journal meet the applicable accessibility requirements to the extent the standards cover them. Article 15(2) gives the same presumption to products that meet technical specifications or parts of them.

Article 15(4) presumes that a product or service whose features, elements or functions meet the accessibility requirements meets the related accessibility duties in other European Union acts, unless those acts provide otherwise. Article 8(2) requires a manufacturer to draw up the technical documents, to carry out or commission the conformity assessment procedure, and to draw up the EU declaration of conformity and affix the CE marking where the product meets the requirements.

Article 8(12) treats an importer or distributor as the manufacturer when it places a product on the market under its own name or trade mark, or modifies a product already on the market so that its conformity may be affected. Article 9 lets a manufacturer appoint an authorised representative by written mandate. Article 10(1) requires an importer to place on the market only products that meet the accessibility requirements.

Article 10(2) requires an importer, before placing a product on the market, to ensure that the manufacturer carried out the conformity assessment and drew up the technical documents, that the product bears the CE marking and the required documents accompany it, and that the manufacturer met its marking duties.

Article 11 requires a distributor to verify, before supplying a product, that it bears the CE marking, that the required documents, instructions and safety information accompany it, and that the manufacturer and importer have met their marking duties. Article 12(1) requires every manufacturer, authorised representative, importer and distributor to identify, on the authority's request, the operators that supplied it a product and those it supplied a product to.

Article 12(2) requires them to be able to provide that information for 5 years after the product was supplied to them and 5 years after they supplied the product on the market. Article 14(1) limits the accessibility requirements to the extent that compliance does not require a fundamental alteration of the product's basic nature and does not impose a disproportionate burden on the operator.

Article 14(2) requires economic operators to carry out an assessment, against the criteria in Annex 2, of whether compliance would require a fundamental alteration or impose a disproportionate burden. Article 16(1) requires the manufacturer's EU declaration of conformity to name the requirements for which the exception in Article 14(1) is used.

Article 14(4) relieves a very small enterprise that makes products of the duty to prepare the assessment report, and requires it to give the authority the facts relevant to the assessment on request. Article 16(8) provides that the authority's requirements on technical documents must not become an excessive administrative burden for very small, small and medium-sized enterprises.

Article 18(1) applies to products Articles 15(3), 16 to 19, 21, 23 to 28 and 29(2) and (3) of Regulation (EC) No 765/2008. Article 21(5) gives economic operators the rights in Article 18 of Regulation (EU) 2019/1020. Article 19 lets the authority require corrective action within a reasonable period that it sets.

Article 6(4) makes the State Consumer Rights Protection Authority the market surveillance authority for the products in Article 2(2), and Article 6(5) gives the Lithuanian Transport Safety Administration supervision of the products that are interoperable constituents of the rail system. Before 1 April 2026 the State Consumer Rights Protection Authority supervised only the products in points 1 to 3 and 5 of Article 2(2), and the Radio and Television Commission supervised the products in point 4.

The State Consumer Rights Protection Authority approved by director's order No. 1-123 of 11 June 2025 its procedure for examining violations of the Act. Article 26(1) has each market surveillance authority approve its own rules for examining violations of the Act and applying liability.

Article 21 empowers the authority to inspect, take product samples, demand explanations and documents, enter premises, warn an operator and oblige it to remedy a violation within a reasonable time, and propose that the licensing authority suspend or revoke a licence. Article 26(2) opens the examination of a violation on a complaint from a consumer, an end user, a State or municipal body, a consumer association or any other interested person, or on the authority's own initiative.

Article 27(1) allows the authority's decisions on market restriction measures, fines and warnings to be appealed within one month of service under the Law on Public Administration or the Law on Administrative Proceedings. Article 28(2) treats a decision imposing a fine as an enforcement document executed under the Law on Tax Administration and the Code of Civil Procedure.

Article 7(1) of the Act implements Article 4(1) of Directive (EU) 2019/882, which provides that Member States ensure that economic operators place on the market only products, and provide only services, that comply with the accessibility requirements of Annex I. Article 8(1) of the Act implements Article 7(1) of the Directive, which provides that manufacturers ensure that products have been designed and manufactured in accordance with the applicable accessibility requirements.

Article 14 of the Act implements Article 14 of the Directive, which provides that the accessibility requirements apply only to the extent that compliance does not require a fundamental alteration and does not impose a disproportionate burden on the economic operators. Article 23 of the Act is the penalty rule that Article 30 of the Directive requires, which provides that the penalties are effective, proportionate and dissuasive.

Article 7(2-1) bars restricting the supply of products in Lithuania that meet the accessibility requirements of Annex 1 on grounds of non-conformity with accessibility requirements. Article 17(1) requires the manufacturer to mark each conforming product with the CE marking before placing it on the market, visibly, legibly and indelibly on the product or its data plate or, if that is impossible, on the packaging and the accompanying documents.

Article 18(3) gives consumers the right to receive from the authorities, in an accessible format, information on how economic operators comply with the accessibility requirements and with Article 14, unless confidentiality prevents it. Article 21(3) gives an operator the right to be present at an inspection, to refuse officials who do not show their service card and the director's order, to see the material gathered, and to appeal against the officials' acts.

Article 24 treats as mitigating that the violator voluntarily prevented the harmful consequences or compensated the losses, and as aggravating a repeat of the same violation within a year of the decision on the earlier one taking effect, or obstructing the investigation or concealing the violation. Article 26(8) requires the authority to examine a violation within 3 months of receiving the investigation material.

Annex 2 sets the criteria for the disproportionate-burden assessment: the ratio of the net costs of compliance to the operator's overall costs, the operator's costs and benefits set against the benefit to persons with disabilities, and the ratio of the net costs of compliance to the operator's net turnover. Act No. XV-907 of 12 May 2026 amended Article 28 and took effect on 30 June 2026.

Act No. XV-760 of 10 March 2026 amended Articles 1, 2, 3, 6, 7, 14, 16, 17, 18, 19, 20, 26 and 29 and Annex 1 from 1 April 2026.

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Page updated 7 November 2026.