SwedenFörordning (2023:676) om vissa produkters och tjänsters tillgänglighet (Ordinance on the accessibility of certain products and services), accessibility requirements for products and services, Annexes 1 to 3
Tillgänglighetsförordningen (2023:676), 4-7 a §§ och bilagorna 1-3
In force since .
An accessibility requirements rule binding public and private bodies.
- Instrument type
- a regulation made under an act
What it requires
- If you place a product covered by the Act on the market, make it meet Annex 1: easily accessible information on its function and accessibility features on or with the product, information that can be perceived by more than one sense, a user interface and functions that persons with disabilities can access, perceive, operate, understand and control, accessible support services, and accessible packaging and instructions (Ordinance, s. 4 and Annex 1; Directive (EU) 2019/882, Annex I, Section I and II).
- If you provide a service covered by the Act, make it meet Annex 2: the products used in the service meet Annex 1, information about how the service works is accessible, websites and mobile services are perceivable, operable, understandable and robust, and support services give accessibility information (Ordinance, s. 6 and Annex 2; Directive (EU) 2019/882, Annex I, Section III).
- From , where Annexes 1 and 2 do not cover a function in the design of a product or the provision of a service, use the functional performance criteria in Annex 3, which you may also use as an alternative to a specific technical requirement if the result is equivalent or better accessibility (Ordinance, s. 7 a and Annex 3; Directive (EU) 2019/882, Annex I, Section VII).
These lines are LexLint's reading of the law's text.
If you get it wrong
Penalty structure
Section 39 of the Act sets the sanction fee (sanktionsavgift) at not less than SEK 10,000 and not more than SEK 10,000,000, determined by the seriousness and extent of the breach and the circumstances, reducible wholly or partly for special reasons, and payable to the State. The same range applies to a natural or a legal person, and the Act sets no turnover-based ceiling. No fee is decided in a minor case or where the breach underlies an application to impose a vite (sections 37 and 38). An order under sections 32 to 34 may also carry a vite (section 35), which the Vite Act (1985:206) sets at an amount likely to make the addressee comply, with no statutory ceiling.
- Rule
- Fixed only
- As of
- Minimum
- 10,000
- Currency
- SEK
- Fixed cap
- 10,000,000
Who enforces it
Enforcement body
The Swedish Post and Telecom Authority (PTS) as market surveillance authority for products and, with the Swedish Media Authority, the Swedish Agency for Accessible Media, the Swedish Consumer Agency and the Swedish Transport Agency, as supervisory authorities for services, under sections 25 and 28 to 31 of the Ordinance
What this law does
Section 4 of the Ordinance requires products covered by the Act to meet the accessibility requirements in Annex 1 to the Ordinance. Section 6 of the Ordinance requires services covered by the Act to meet the accessibility requirements in Annex 2 to the Ordinance. Section 5 of the Ordinance lets PTS issue further regulations on accessibility requirements for products.
Section 7 of the Ordinance lets PTS, the Swedish Media Authority, the Swedish Consumer Agency, the Swedish Transport Agency and the Swedish Agency for Accessible Media issue further regulations on accessibility requirements for the services within their remits.
Section 7 a of the Ordinance requires the functional performance criteria in Annex 3 to be used where the requirements in sections 4 and 6 do not cover one or more functions in the design and manufacture of products or the provision of services. Förordning (2026:290) added section 7 a and Annex 3 from , so the functional performance criteria apply from that day.
Annex 1 point 1 requires products to be accompanied, if possible in or on the product, by easily accessible information on their function and accessibility features. Annex 1 point 2 requires the information on the use of the product provided on the product itself (labelling, instructions and warnings) to be perceivable by more than one sense, understandable and presented in a suitable font with sufficient contrast and adjustable spacing.
Annex 1 point 4 requires the product, including its user interface, to have features, parts and functions that let persons with disabilities access, perceive, operate, understand and control it, by means including more than one sense, alternatives to speech and to colors and sounds, flexible magnification and contrast, an alternative to biometric identification and interfaces for assistive technologies.
Annex 1 point 5 requires support services such as helpdesks, call centers, technical support, relay services and training services to give information on the product's accessibility and its compatibility with assistive technologies through accessible means of communication. Annex 1 point 6 requires, for every product other than a self-service terminal, the packaging and the instructions for installation, maintenance, storage and disposal to be made accessible.
Annex 2 point 2 requires information on how the service works, and on the accessibility of any products used to provide it, to be perceivable by more than one sense, understandable, available in a text format usable for alternative formats, and accompanied by an alternative presentation of any non-text content.
Annex 2 point 3 requires websites, including related web applications, and mobile device services, including mobile applications, to be made accessible in a consistent and adequate way by making them perceivable, operable, understandable and robust. Annex 2 point 4 requires support services, where they exist, to give information on the service's accessibility and its compatibility with assistive technologies through accessible means of communication.
Annex 3 sets functional performance criteria for use without vision, with limited vision, without perception of color, without hearing, with limited hearing, without speech, with limited manipulation or strength, with limited reach, minimizing photosensitive seizure triggers, with limited cognition, and privacy.
Section 37 of the Act allows a market surveillance authority or a supervisory authority to order an economic operator to pay a sanction fee for breach of sections 6, 8, 11 to 13, 15 to 17 or 19 to 26, section 28 second paragraph point 6, or rules made under them.
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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