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Does your digital environment meet accessibility requirements in force from 2025?

Mari-Ell Mets & Evelin Laupa-Soonsein

Accessible digital environments are independently usable by as many people as possible. An accessible digital environment is designed and developed in such a way that its texts can be read also by the elderly, layout and functions are understandable also to first-time users, and the page is usable for people with special needs and various assistive technologies (navigable with keyboard, screen readers, voice commands, eye sensors) etc.  


More broadly, following accessibility requirements also means increasing the overall usability, because accessible digital environments are more reliable, efficient and people can find what they need faster.  


Accessibility is an increasingly important topic. Public sector websites and mobile applications have had to meet the European Union digital accessibility standard EN 301 549 since 2019.


These requirements have not yet been enforced for the private sector, and therefore accessibility guidelines have been followed mainly by companies that have wanted to bring their services to a wider audience and have seen a competitive advantage in it.


However, the situation is changing, as by 2025 many private sector companies will have to take a critical look at their online environments. 



What will change in 2025?  

In 2019, the European Union accessibility directive (EU) 2019/882 was released, which sets accessibility requirements for products and services. The new requirements were taken over into the Estonian law as the Products and Services Accessibility Act


The directive means that from 28 June 2025, private sector websites and mobile applications will also have to comply with EN 301 549 (around 100 requirements in total), which until now have only been applicable for the public sector digital environments.  


People walking on the street in old town, where signs on the shop windows indicate that the stores are inaccessible.

From 2025, online stores, among others, must meet accessibility requirements. 


With the extension of the requirements, the accessibility standard EN 301 549 is also being updated and version 4.1.1 will be published in 2025. However, the main part of the standard will likely remain the same, so today's version can safely be taken as a basis for accessibility analysis and corrections. 


It is important to note here that the European Union accessibility standard contains both the international standard WCAG 2.1 level AA requirements and additional requirements. 



Who are the accessibility requirements applicable to?  

The requirements of the accessibility standard EN 301 549 apply to both digital products (e-readers, payment terminals, ticketing machines, ATMs, self-service kiosks, etc) and digital services (online banking, telecommunication services, e-commerce, purchase of transportation tickets, access to audiovisual media, etc). Thus, the mobile applications and websites necessary for providing the service, such as online stores, must be accessible. 


However, there are certain exceptions to the requirements. For example, they do not apply to micro-enterprises or online content that will not be updated or modified after 28 June 2025. In addition, companies can apply for an exemption if following accessibility requirements would impose a disproportionate burden on the company. 


Information about whom the requirements precisely apply to and in which cases it is not necessary to follow them, can be found from the Products and Services Accessibility Act. 



What happens if my company's online environment does not meet the accessibility requirements? 

The Consumer Protection and Technical Regulatory Authority (TTJA) periodically audits the accessibility of websites and mobile applications and, in case of non-compliance, has the right to intervene and issue notices. In addition, they also check online environments based on complaints submitted by users. 


A person with closed eyes and headphones on a laptop with text read by a screen reader in the background.

In order to test the accessibility of a website, it is necessary, among other things, to test it with a screen reader.  



How to prepare for the upcoming changes?  

To understand the current level of accessibility, it is necessary to analyse the website’s or app’s compliance with EN 301 549. The analysis must be thorough in order to identify a clear input for improvements.


Improving accessibility usually means IT development, and since it takes time and can be expensive, it makes sense to start fixing accessibility issues long before 2025, among routine development investments. 


For a quick overview, online automated checking tools, such as WAVE, can be useful. However, automated tests do not replace manual control, as they can only detect a small part of accessibility issues. 


Manual accessibility analysis means testing the online environment with assistive technologies (e.g. keyboard and screen reader) and various settings (e.g. magnification and changing colours).


The manual testing can also be done in-house, but as there are so many accessibility requirements, understanding and testing them correctly can be quite time-consuming. Trinidad Wiseman's accessibility tool explains accessibility requirements in simpler language (in Estonian only), with examples and recommendations. 


For best results in assessing the accessibility of a digital environment, we recommend involving an experienced specialist who will conduct the accessibility audit and return a report of found problems and possible solutions.


It is also a good idea to involve people with special needs in the testing, who can, in addition to discovering the accessibility issues, highlight the user behind the issues. 


Trinidad Wiseman experts have extensive experience in testing web accessibility. To order an accessibility audit, please contact us: 


Liina Martõnjak, Head of Service Design

Mari-Ell Mets, UX/UI Designer and Accessibility Expert



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